WCPanelIQ
PanelMed-legalLienGranted in Part

Claudia Erazo — ADJ21161039

CLAUDIA ERAZO, Applicant vs. DEDICATED BUILDING SERVICES; SERVICE AMERICAN INDEMNITY COMPANY, administered by LWP CLAIMS, Defendants

ADJ number
ADJ21161039
Decision date
Sep 3, 2026
District office
Santa Ana
WCJ
Nate Halprin
Claim administrator
LWP Claims (LWP Claims Solutions-Glendale)
Commissioners
—

Injury / body parts: bilateral wrists, bilateral hands, fingers, bilateral shoulders, bilateral knees, neck, thoracic spine, lumbar spine

LC §5909LC §5903LC §5952LC §5705LC §3202.5LC §3600LC §5412LC §3600(a)(10)CCR §10682

Summary

Applicant Claudia Erazo, a janitor, claimed cumulative trauma injury during employment with Dedicated Building Services from June 26, 2024 through June 26, 2025. After the claim was denied, three treatment lien claimants litigated the bifurcated issue of injury AOE/COE, relying solely on the medical reports of Dr. Nikakhtar. The WCJ found industrial injury based on those unrefuted reports, and defendant sought reconsideration arguing the reports lacked substantial evidence because the medical history was not independently corroborated. The Appeals Board granted reconsideration solely to formally admit the lien claimants' Exhibits 1-3 into evidence (correcting the WCJ's procedural error of only referencing admission in the Opinion on Decision), and otherwise affirmed the WCJ's finding of injury AOE/COE. The Board adopted the WCJ's Report, holding that a physician's report based on an adequate history and examination constitutes substantial evidence, and that defendant bears the burden of proving a false or misleading history rather than the lien claimant bearing the burden of collateral corroboration.

Issues

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Holding

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Analysis

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Applicant takeaway

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Defense takeaway

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Provider takeaway

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