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Case Name Valdez v. WCAB
Date 05/29/2012
Note California's Labor Code does not prohibit the admission of medical reports from doctors who are not a part of an employer's properly noticed and valid medical provider network.
Citation B237147
WCC Citation WCC 39002012 CA
VALDEZ v. WCAB ELAYNE VALDEZ, Petitioner, v. WORKERS' COMPENSATION APPEALS BOARD and WAREHOUSE DEMO SERVICES et al. Respondents. We therefore annul the decision of the WCAB and remand with directions for further proceedings that are consistent with this opinion. "*fn1 The WCAB found that the WCJ "relied on the non-MPN reports of Dr. Nario for this finding [temporary disability] and award of benefits. "'"*fn2 The WCAB concluded that reports from non-MPN physicians are inadmissible and may not be relied on to award compensation. In its second en banc opinion, the WCAB did not limit itself to holding that section 4616. 6 made Dr. Nario's report inadmissible.

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