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Case Name Custard v. WCAB
Date 08/10/1992
Note Letter requesting advisory PD rating is valid petition to reopen; procedural rules construed informally.
Citation 57 CCC 545
WCC Citation WCC 27701992 CA
Ardie Faye Custard, Petitioner v. Workers' Compensation Appeals Board of the State of California, A. C. OPINION: In this case, we hold that petitioner Ardie Faye Custard (applicant) effectively instituted supplemental proceedings for an increased permanent disability award within the five-year period of limitations set forth in Labor Code sections 5410 and 5804. In the WCJ's opinion, however, counsel's letter of February 13, 1986, requesting advisory ratings for the medical reports of Drs. 'II Section 5410 [n8] governs an injured employee's supplemental request for new and further disability, including an increase in permanent disability. Together with section 5405. 5, [n10] these sections cover the entire spectrum of the Board's continuing jurisdiction over workers' compensation matters.

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