Gregorio Vallecillo Mena — ADJ13427439

Applicant's attorney sought reconsideration of a First Amended Order imposing $500 in sanctions and costs for failing to comply with the WCJ's March 17, 2025 discovery orders requiring production of medical reports showing applicant needed a guardian ad litem and affidavits regarding contacts with applicant. The WCAB found that the sanction order and the underlying discovery orders were issued without any evidentiary record, admitted evidence, or testimony, in violation of due process and WCAB Rule 10787. The Board held that the Notice of Intent to Sanction, buried in the last page of a lengthy minute order, did not provide proper notice, and that no pending guardian ad litem petition existed to make the ordered discovery ripe. The Board granted reconsideration, rescinded the Amended Order, and returned the matter to the trial level for further proceedings.