ALLIED WASTE INDUSTRIES, INC. , et al. Petitioners, v. WORKERS' COMPENSATION APPEALS BOARD and ROGELIO ROJAS, Respondents. FACTS AND PROCEEDINGS Rogelio Rojas (applicant) was seriously injured while working as a garbage truck driver for petitioner Allied Waste Industries, Inc. The ALJ ordered additional medical treatment for applicant and awarded counsel a total of $386,515. 32 in attorney fees. However, the Board rejected respondent's challenge to the COLA calculation, concluding that it too was constrained by the Duncan decision. DISCUSSION Before embarking on our analysis of petitioner's claim, we briefly review some fundamentals of the workers' compensation system.

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