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Case Name Carpenter v. WCAB
Date 04/11/1986
Note Time limit for filing petition for reconsideration runs from date of actual receipt when WCAB serves findings to attorney at unauthorized address.
Citation 51 CCC 175
WCC Citation WCC 27781986 CA
The change-of-address form was dated August 23, 1983, but bears a WCAB stamp showing receipt by the Board at 1025 a. m. on August 31, 1983. The Board also found 'applicant's attorney has agreed to receive service of process from the Sacramento office [of the WCAB] in that manner [by mail slot]. 'Petitioner's counsel, as an attorney, is presumed to know that service by 'mail slot' is not authorized by statute or by WCAB regulations. Petitioner is therefore bound by his attorney's agreement to accept service of process at his WCAB 'mail slot. 'n3 It is undisputed that delivery by 'mail slot' does not constitute 'personal service' within the meaning of the Labor Code and WCAB regulations.

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