Happy Monday dear readers! Quick question for you – do you ever feel like you’re not getting the credit you deserve?  Well, that’s typical for workers’ compensation in California, particularly for defendants, and ESPECIALLY when you’re paying benefits.

Specifically, getting credit for TTD overpayment against PD benefits can be a pain, and the case law is not making it any less so.

Typically what happens is that the defendant is paying temporary disability benefits to applicant, but something happens that terminates the liability for TD.  For example, a declaration of P&S by the QME or the PTP.

But, just like Homer Simpson laughing at people waiting in line to file their taxes on April 15 because he “filed his taxes last year,” there’s usually a delay between events and knowledge of those events – a fog of litigation shall we say?

Well take your typical case: IW is getting TD benefits at $800 per week based on a $1,200 per week average weekly wage.  IW attends a QME exam on March 1, and on March 30 defendant gets a report from the QME via facsimile: Permanent and Stationary as of the day of the exam.  Well, depending on when the checks went out, the injured worker could have gotten almost $5,000 in overpayment of TD.  After all, there will be a delay between getting the report and processing it to under the P&S declaration.

Just a note, dear readers, one very common pitfall here is to just assert the TTD overpayment against PD.  So let’s say the PD comes out to 9% or $7,830.  If there’s some 20% non-industrial apportionment on questionable grounds, the PD goes down to 7% or $6,090.  After holding back 15% for attorney fees, there’s only $5,176.50 in PD left.  If defendant is asserting six weeks of TTD overpayment or $4,800, does that mean advances need only go to $376.50?

No!  Credit against PD for TTD overpayment can only be asserted AFTER an Order of Credit.  Taking credit without such an Order can lead to penalties and sanctions.  What’s more, the credit is not automatic.  A petition needs to be filed, and, pursuant to the WCAB rules of practice and procedure section 10555, the petition must include a description of the payments made, the benefits against which the defendant seeks credit, and the amount of claimed credit.

Even after all these obstacles have been navigated by the nimble defendant there’s more: the credit is usually in the Judge’s discretion.  Among the factors to be considered by the WCJ are whether the TTD overpayment credit would wipe out the PD recovery and whether the TD overpayment was the fault of applicant, defendant, both, or neither.

This came up recently in the case Pacheco de Avila v Taco Station, a panel decision issued in March of 2020.  There, the WCJ had awarded TTD overpayment credit of $7,349.60 against a PD award of $6,111.56.  In terms of facts, applicant was seen by a PQME who declared a P&S date retroactively by about 5.5 months.

The WCAB returned the issue of TTD overpayment to the trial judge, with instructions to consider the case of Maples v. WCAB (1980), in which the Court of Appeals held that since TD served the purpose of replacing wages during the healing period and PD served the purpose of adjusting the residual impairment after a P&S declaration, in some cases, allowing credit against one for overpayment of another disrupts the purpose of the benefit.

Defendants are often in this rock-and-hard place situation, and the Pacheco de Avila case is no different.  Defendant is out the extra money it paid and applicant got the benefit.  But, as time drags on, defendant is paying defense attorney fees and the maintenance of an open file.  So, as in this case, defendant already paid the TD, then paid its attorney to pursue the credit and get the order.  But now the WCAB is prolonging the experience by remanding the issue.

If your humble blogger was drafting law, which, surprisingly the Sacramento Legislature is not asking me to do just that, I would remind everyone of common sense principles: if the employer can be penalized for holding on to benefits that it should have paid out, so, too, should injured workers be ordered to pay back money to which they are not entitled and received erroneously. 

Even if the injured worker is not able to pay back the money, there should be a credit against future benefits, particularly those other benefits are not coming as medical treatment but as more money.

Despite the reasoning in Maples, defendants still have constitutional rights to due process and equal protection under the law, and the concept of unjust enrichment is no less offensive because it is in the workers’ compensation setting.

In any case, dear readers, let this panel opinion be a reminder to all us of to carefully handle issues of TTD overpayment and credit.

Health and Safety to you all, dear readers!

Woohoo dear readers, you made it to another Friday.

Yes, it’s Friday.  Just check your calendar it really is Friday.

You know, as an Officer of the Court, you can just take my word on this one.

Well anywho, enough doom and gloom.  I have some cheerful news for a change.

While the debate continues about whether grocery workers should have a presumption of industrially caused COVID19 infection, your tech-loving humble blogger stumbled upon this article about a lovely town called Milton Keynes.

Neither hunger nor thirst respect shelter-in-place obligations, and everyone still has to eat.  But little delivery droids from a company called Starship are making grocery deliveries instead.  After logging over 100,000 successful deliveries in the last two years, the robots are serving to minimize the person-to-person interactions your humble blogger loves so much in every trip to the grocery store.

So is this a solution?  As I love to quote from HBO’s show The Wire character, Frank Sobotka, “you can’t get hurt if you’re not working.”  If such machines could be deployed to make deliveries and thereby reduce the volume of people in-store, is there still a need for a presumption?  If grocery store employees no longer interact with the general public but simply pack the robots and send them on their way, where is the injury?

Right now, your humble blogger sees Instacart employees performing this same task.  But, employees get injured and file claims – robots do not as they are not human.  Apologies to Lt. Commander Data, of course.

Fortunately, for the time being at least, we’re still in a somewhat free market.  In such markets, people and companies vote with their feet.  Perhaps grocery store employees (or rather the Unions and applicant attorneys trumpeting in their names) win the battle and secure a COVID19 presumption.  If the cost of labor only goes up, what alternative is left to automation?

To do some basic field research, I asked one group of applicant attorneys to react to such a robot and captured the following footage:

Have a good weekend, dear readers!

So dear readers, as we keep on keeping on, going into May of 2020, it looks like the trend remains: work from home is the name of the game.

Sure, essential workers continue to leave the house, but a huge chunk of us continue to do our duties from the comfort of our homes (if we can). 

So here’s a fun question for anyone in such a situation contemplating retirement: how can you claim workers’ comp benefits if you’re working at home?

Well, it’s been done, and not just while we’re under shelter-in-place orders.  The WCAB issued a panel decision in 2017 (writ of review was subsequently denied by the Court of Appeal) upholding the WCJ’s ruling that the injury sustained at home was compensable.

In Tidwell v. Santa Clara VTA, applicant was working at home when she fell while using the restroom, resulting in a broken right leg.  According to applicant’s testimony, she had been working for several hours and only took a break to use the restroom with the intent to return to work.

Particular to this case, applicant’s doctors, even prior to this injury, recommended a germ-free environment for the restroom, and her employer’s restroom did not meet this requirement.  Accordingly, she opted to work from home, although she would have otherwise preferred to work at the office.

The facts also showed that applicant had been working at home for 10 months prior to the industrial injury.

The panel adopted and incorporated the opinion of the WCJ and, as noted above, the Court of Appeal denied review.

In the Tidwell case, applicant worked from home because of medical necessity.  The WCJ reasoned that the employer derived benefit from this as there was always the option of not allowing the employee to work from home. 

What about all the folks sitting at home right now, continuing to do their jobs as best as they can under shelter-in-place?  While the employers can take steps to ensure a workplace is relatively safe (guardrails, anti-slip floor mats, prohibiting the consumption of alcohol during business hours), how is an employer to enforce such measures remotely?

Well, as we all continue to work at home, are we to anticipate injuries sustained at home in the discharge of work duties?  The ergonomic chairs and sit-stand desks installed at such great expense by employers in the office sit idle, while your humble blogger may or may not still have an old computer chair from his college days at home.

What’s more, as experience sprinkled with a bit of cynicism has taught us, anticipation of lay-offs prompts specific injury claims; notice of lay-offs prompts cumulative trauma claims.  Can we expect those from the folks working from home?

If those do start coming in, what are the options for the defense community?  Well, for starters, an investigation of the injury might include an investigator visiting the “scene of the injury” for signs of non-industrial causes. 

Are there signs of alcohol consumption during work hours? Of injury being sustained in non-industrial activities unrelated to work?  As Tidwell rightly reminds us, going to the restroom may be industrial, but going for a run and twisting one’s ankle is probably not.

If the work is being done remotely, was there any remote monitoring of the work?  For example, some remote work software makes note when there is general inactivity on a computer for a certain amount of time.  Was that the case in this claim?

Social media searches in particular would be helpful here as well, your humble blogger submits.

What do you think, dear readers, is your humble blogger being paranoid again?  Or is workers’ compensation yet again about to be the piggy bank for the survivors of an economic decline?

Well, it’s Groundhog Day again… I mean Monday again, dear readers.  Here we are, watching with bated breath as we wait to see what happens to the citizens of those states opening up in the face of looming Corona virus threats.  Will it all be ok?  Will there be massive spikes in Corona virus cases and deaths?

Well, while we’re waiting to see the results of yet another great experiment in Federalism, let’s turn our attention back to California.  The first of the COVID-19 presumption bills is now before the California Legislature.  Assembly Bill 664 would amend the Labor Code to make active firefighters, peace officers, and health care employees who provide direct patient care, eligible for a presumption of compensability in certain cases.

So here’s the basic idea:

1. If you’re a firefighter, peace officer, or healthcare worker involved in direct patient care, this will apply to you!
2. The scope of “injury” now includes being sent into quarantine, even if there are no actual symptoms or health effects, so long as there is a state of emergency declared in California (before or after the order to go into quarantine);
3. In addition to the typical workers’ compensation benefits, an employee so “injured” is entitled to reimbursement for temporary housing and PPE costs, both to prevent infection/exposure to self and to others;
4. An injury of this sort shall be conclusively presumed to arise out of and in the course of employment up to 90 days after the last day worked, presumably without regard for the reason the employment ended.

So, let’s take a look at some wacky scenarios under the proposed AB664.

Nurse retires and to celebrate her career goes on a trip around the world.  Her flight leaves 30 days after her retirement party and she gets back 30 days later, showing her first symptoms as she gets back from the airport.  Industrial? Under AB 664 it would be.

Peace officer is driving home from work in his own car when he gets T-boned by a distracted driver.  He gets taken to a hospital and stays there for a spell in intensive care.  A week after being sent home from the hospital to recover he starts showing COVID19 symptoms.  Industrial?  Under AB 664 it would be. 

Firefighter’s brother falls ill with COVID19 symptoms.  After a week of toughing it out his brother asks him to take his kids so that he can try to recover without childcare burdens.  A week after the fighter’s niece and nephew move in, he develops COVID19 symptoms of his own.  Industrial? Under AB 664 it would be.

Needless to say, your humble blogger is not a fan of this and finds it a legislative overreach.  There is no basis in science or even reason to extend a presumption of industrial causation up to 90 days from the last day worked.  There is no reason to consider the need for quarantine an “injury” as contemplated by the Labor Code, especially if the “injured” worker shows no symptoms and suffers no harm other than the quarantine itself.

Buckle in dear readers, the fun is just beginning. 

Happy Monday, dear readers!  How are we all holding up?  So far so good on this end of the computer screen – the COVID19 has had quiet the impact on attending hearings before the WCAB.

Starting last Monday, April 13, 2020, each Workers’ Compensation Judge had an assigned phone number to allow parties attending Mandatory Settlement Conferences to call in and discuss the matter over the phone.  The parties were instructed to complete 5-pagers and e-file or email them to WCJ’s the night before the hearing.

I had three such MSCs and let me tell you – this is awesome.  If your humble blogger was asked, I would urge us to consider making mandatory settlement conferences via conference telephone call the norm.  Parties are required to appear having already reviewed their cases and ready to either settle or go to trial. 

The cases are given attention by the WCJ over the phone in a systematic process without having to track down the opposing counsel whether that be in the cafeteria, outside having a cigarette, or in the secret bar-and-lounge that only humble bloggers know about.

It’s only been one week, but, so far, the system has been efficient and relatively smooth.  If you nurture a grudge that the opposing side shows up to court completely unprepared and learns his or her file on the go, perhaps this is the system to weed such behavior out.

Now, since my last blog post, where I valiantly argued that there is absolutely no need to have a presumption of compensability for COVID19 cases among grocery workers, your humble blogger has received a surprising bit of e-mail traffic making some very valid points.  The thrust of the arguments has been that whereas I, your humble blogger, would only spend 30 minutes to an hour at the local grocery store, the grocery store worker would spend 8 hours or more there.

As such, the e-mails argued, perhaps the grocery store worker is at greater risk than the public, because the grocery store worker cannot retreat to shelter-in-place until completion of the 8 hour shifts (plus commute time) that are part of the job.

I completely and totally agree.  It sounds like there are going to be cases where the injured worker can show, through timesheets alone, that it is more likely than not that the COVID19 applicant has come down with and suffered from is industrial.

But your humble blogger submits this to you, my beloved readers, and especially to the folks that took the time to send these points my way: why, then, do you need a presumption?  If it’s this obvious, then file for a priority conference and get a finding of fact that the injury is industrial.  It’s not like you have to pay for a QME, right?  Defendants are forced to do that, sometimes even when the dispute could be resolved by a factual inquiry. 

But let’s get real for a second – what presumption is going to be limited in scope to the 8-hour employee valiantly providing grocery service to the teeming masses for 40 hours a week?  No, of course not, the presumptions would also include the recent hire that has only worked one week when the incubation period for COVID19 can last as long 11.5 days (if not longer).  What about the employee that doesn’t interact with customers but is on the night shift re-stocking?  What about the loading dock employee that doesn’t see customers?  The butcher? The baker?

Although the points raised by some of my readers are well taken, I urge you to remember that this only proves the overarching point – there is no basis for a presumption.  If your case is so slam dunk do exactly what we were all trained to do for three years: go to court and prove your case. 

And with that, my beloved readers, your humble blogger wishes you good health and another week surviving cabin fever. 

Happy Monday, dear readers!  How are we doing?  Hanging in there?

It’s all gravy in your humble blogger’s navy here, although I can’t tell you enough how much I miss daily hearings and depositions – it seems like just about every deposition and hearing (with the exception of expedited hearings) is being kicked over again and again.  Even AME and QME exhibits don’t seem to be happening much – despite all the talk about telemedicine, many of the QMEs and AMEs are just cancelling the appointments.  I guess the opportunity of a standard QME exam and report fee isn’t worth losing one’s life over – who would have guessed?

In any case, if you have not yet heard, you should know that CAAA and some of its Union allies are trying to get a presumption into California law that contracting Corona Virus is industrial.

For some reason, Governor Newsom isn’t taking my calls so if you’ve got any influence in Sacramento, I urge you, my beloved readers, to exert it to prevent such a presumption from entering our beloved workers’ compensation swamp.

California Labor Code section 3600 specifically limits compensability to injuries arising out of and in the course of employment.  We receive allegations of injury, investigate them, and them determine if they are work related or not.

The standard for compensability for diseases such as COVID19, without any presumption, would be to either establish a specific point of infection at work (which would be nearly impossible given how wide spread the illness is) or to show that the employee is at a higher risk of exposure than the general public. 

Hospital employees working with hepatitis patients are much more likely to be exposed to hepatitis than the general public – sure!  What about COVID19?  Unless you are a hospital worker treating COVID19 patients, in what scenario would a worker be more likely to be exposed than the general public?  Probably none. 

CAAA and the involved Unions want a presumption for that exact reason: employees working in stores or making deliveries aren’t at higher risk than the general public, because their only risk of exposure is by interacting with the general public.  When your humble blogger goes to the grocery store to buy his ration of toiler paper, he is just as exposed to COVID as the check-out clerk because our source of danger is the exact same: other members of the public.

Without a presumption, absent some showing of direct exposure at work (such as, perhaps, an co-worker who tested positive for COVID19 and a point of contact contemporaneous enough to fit with the incubation period) the worker is just as likely to have gotten it doing his or her own grocery shopping as at work.  And in those cases, the applicant cannot carry his or her burden of proof – showing it is more likely than not that the infection occurred AOE/COE.

Of course, CAAA and the Unions involved want to skip this inconvenient fact and get a free pass.  Well they shouldn’t – workers’ compensation is not a lottery ticket and it is intended to cure or relieve from the effects of non-industrial injuries.  If an applicant can establish that the infection occurred more likely than not at work, then no presumption is necessary for benefits.  If it is less likely than so that the infection was work-related, the worker should not receive benefits.

So, we circle back dear readers – I urge you to do what you can to oppose any efforts at such a presumption.  And if I’m wrong, which, legend has it, I have been from time to time, let me know please!

Hello dear readers! It is a very unlikely but certainly possible state of affairs that long-term social isolation has reduced you to confirming the current day of the week through the blog posts.  If that is the case, your normally eloquent and verbose humble blogger, though certainly made even more humble by such a duty, cannot find the words to describe the enormous sadness he would feel if this really was the situation.  Well… happy WEDNESDAY, dear readers (just in case).

Speaking of sad news, I’ve got a bitter-sweet item to report to you.  A former Los Angeles Police Department officer, Michael Simon, of Redondo Beach, plead no contest to grand theft and insurance fraud.  As reported by MyNewsLA.com, convict Simon was accused of “misrepresenting the nature of his injuries to his employer to collect additional financial assistance” and “of engaging in activities inconsistent with his claimed injuries while he was off work in disability.”

The article reflects that he had been an LAPD officer for 12 years before resigning.

As this blog often points out, the conviction of a law enforcement officer or, really, any person in a particular position of trust in our society, is bitter-sweet.  On the one hand, it is justice being served to have a person engaged in deceit and fraud to be caught, publicly shamed, and for restitution to be made to the victims – in this case the tax-payer funded budget of the public sector employer.

But there is a bitter taste to such victories as well – every time a law enforcement officer is convicted of fraud, the testimony of honest LEOs in the prosecution of any trial is just a little bit less persuasive.  Even the convictions that Mr. Simon contributed to in his 12 years as an LAPD officer, perhaps fairly and honestly reached, are now tainted and impeached.

Of course, every defense attorney who ever represented a criminal defendant convicted even in part by the testimony of Mr. Simon is cracking open his or her old file for a new appeal and a new trial – one that the County of Los Angeles’ DA office probably has limited resources to re-try (perhaps several years later!).

Unfortunately, “what’s to be done?” has a very limited option for meaningful response. In your humble blogger’s estimation, the right thing was done here: upon finding a rotten apple in the barrel, the local authorities investigated and removed it.

Unfortunately, few details are available of how Mr. Simon was caught with his hand in the proverbial cookie jar.  Such details would help educate the defense community in how to better identify and document fraud, but, in all likelihood, would also shape more elaborate fraudsters. 

Congratulations to the Los Angeles County District Attorney’s Office on a successful prosecution, from the bottom of your humble blogger’s cabin-fevered heart!

Alrighty dear readers – how are we doing?  Is the cabin fever kicking in yet?  Remember, unlike our predecessors, we have the joy of the internet to keep us company while we teach home school and work from home as well.  Goods are delivered, communication is done over the world wide web, and so long as we can keep those living with us a safe distance away, video conference can proceed without leaving our homes.  Surviving shelter-in-place, for most of us, is not as bad as it would have been a single generation ago.

But, the workers’ compensation community struggles to adapt – not everything, it seems, can be done from the kitchen table in our pajamas. 

Last week, your humble blogger had the privilege of rebroadcasting the efforts of the DWC and the WCAB to limit the spread of infection, primarily by limiting in-person appearances at the WCAB to expedited hearings, moving most other hearings to court call and changing “walk-throughs” to “email-ins.”

Well, the cry has been raised by some QMEs and stake-holders to allow all QMEs to shift to telemedicine – conducting evaluations via Skype or some alternative, to avoid face-to-face and Corona-to-Lungs interactions.  In response, the DWC has published a statement, although it stops short of giving a firm directive.

“The use of telemedicine for a QME evaluation may be appropriate where all parties agree that there is a medical issue in dispute which involves whether or not the injury is AOE/COE… and all parties to the action, including the physician, agree to a telemedicine evaluation in order to resolve the dispute.”

So basically, if the dispute is AOE/COE, the DWC is giving a wink and a nudge that it might be ok to do a video chat instead of an in-person exam, but only if all parties agree.

So why would an applicant agree to this?  Well, some QMEs are cancelling in-person examinations for personal safety already, so if an applicant is looking to get benefits on a denied case, he or she might be eager to agree to just about anything to get a report that says “yep, that’s industrial!” 

But, why then, would a defendant agree to this?  If the defendant already has a denied claim, what benefit does a defendant see in expending an examination that will be less precise and reliable than a standard, in-person exam?

As far as your humble blogger can tell, there’s only one benefit – and it is not provided for in the DWC guidance, so it would have to be agreed to in addition to a telemedicine exam: a recording of everything that goes on during the exam.

Many members of the community have suspicions about one or another QME. Applicant attorneys sometimes suspect that certain “conservative” QMEs are purposefully recording altered responses that their clients give, or leaving out pertinent facts. Many defense attorneys and adjusters suspect that certain “liberal” QMEs are purposefully coaching the injured workers to give responses resulting in more benefits.

Well, for those harboring such suspicions, now might be your chance. Perhaps the desire of the QMEs to continue the stream of income based on conducting exams, the desire of the applicant to get an exam date sooner, and the desire of the adjuster to move a denied file towards closure can form the perfect storm for such an arrangement.

If you wait this out, there is going to be an exam like before – closed doors and no evidence of ignoring responses or coaching.  But if you agree to a telemedicine exam on the condition that to be admissible, the entirety of the exam must be recorded and produced to the parties, well… there’s a reason why police misconduct watch-dogs demand body cameras for Law Enforcement Officers and encourage civilians to film any interaction with the police.

The only reason I would be tempted to recommend a telemedicine QME exam is if the entire exam will be recorded and the parties will each get a copy.  What’s more, the parties would have to agree ahead of time that there would be no communication of any sort between the QME and the injured worker that was NOT recorded in both video and audio.

What do you think, dear readers?  Would you be tempted by an offer such as this?

Now to the three applicant attorneys still speaking to me… what do you think?  Would you allow your client to be examined over telemedicine?  Would you allow it to be recorded?

Alright dear readers – congratulations! You made it to the end of the week.  Of course, if you’re sheltering in place, every day is kind of the weekend, isn’t it?  For those of us working from home, I suppose the weekdays and weekends all meld into one, but let me tell you – the grocery store shelves are bare and clearing your throat in public triggers death by a thousand stares from everyone around you, so perhaps it’s best to stay inside.

In any case, I know your media streams continue to be wall to wall Corona Virus, so let your humble blogger continue his mantra of gentle distraction with a non-Corona blog post.

If you were to splice the DNA of Fred and Rod, what would you get? Fraud! And that’s what we’re posting about today.

A former Foster Farms employee was charged with workers’ compensation fraud and pled no contest.

Get it? Chicken?  Because he worked at Foster Farms and Foster Farms raises chickens… Tip your waitress folks, and try the veal!

Convict Gurmail Singh apparently attempted this experiment himself as he has now pled no contest for “unlawfully and knowingly [making] a false and fraudulent material statement in support of obtaining workers’ compensation insurance benefits.”

The described mechanism of the fraud, as alleged, was “Singh presented false statements and material misrepresentations during his deposition and at a medical appointment. Singh misrepresented facts as it related to his physical abilities and limitations associated with his injury and prior medical history.”

This all stems from a workers’ compensation claimed injury from November of 2014 against his employer at the time, Foster Farms.  He was ordered to pay $3,200 in restitution to Foster Farms for investigation costs and will be on probation for 3 years.  The Turlock Journal did not disclose if he would also have to reimburse to Foster Farms the benefits paid.   

A review of EAMS shows the case was resolved by way of C&R in September of 2018.

So there you go, dear readers – some relatively good news?  A successful fraud conviction and a closed file to boot!

Keep the faith, dear readers, and keep those hands clean!

Ok, dear readers, I’m trying my best to keep Corona news to a minimum, but there’s no escaping it in this case. We’ve had some serious developments both focused on the Bay Area and state wide.

Starting with the Bay Area, six counties have instituted orders to “shelter in place” and shut down all non-essential businesses for the next 3 weeks or so. Most of the county orders provide an exception for legal services if those services are “essential,” which probably provides sufficient wiggle room to keep workers’ compensation firms at least partially open, but the general approach right now is that if one can work from home, one should work from home.

The DWC has, likewise, announced as of yesterday that it will close its San Francisco, San Jose, and Oakland offices.

The San Mateo ordinance, for example, where your humble blogger hangs both his hat and his shingle, provides an exemption for “Professional services, such as legal or accounting services, when necessary to assist in compliance with legally mandated activities.” (See page 5 of 7, paragraph xx). The other ordinance seem to have something similar in place.

Take heed, dear readers, there’s a good chance this is coming to your county as well and I would take all necessary steps to prepare for working remotely, including moving file and hardware as necessary.

The other issue is presently state-wide. The DWC has severely restricted access to the Board. From March 17 (yesterday) to March 20, only expedited hearing will be heard at the Board. From March 23 to April 3, expedited hearing will continue to be heard in person, but status conferences, MSCs, and priority conferences will be by Court Call only.

Trials and lien conferences will not be heard at all during this time.

As for filings, the filing date deadlines will be extended to Monday, April 6, 2020 (assuming this doesn’t continue past then!) There will be no walkthroughs, but it looks like parties can still e-file. Furthermore, the individual boards may set up a method of having settlements e-mailed directly to the Judges for review and approval. But, nothing will be accepted as a walk-in or in-person walkthrough.

Let’s remember the key lesson here, dear readers: We, as Americans, rebelled against a monarch and so hate everything crown related, especially a virus named Corona. Therefore we must fight this virus to the bitter end!

In the alternative, let’s remember that we’re all trying our best to make sure medical facilities and resources are not overwhelmed with cases, especially for at-risk population. So please do your best to practice social distancing, wash your hands, don’t touch your face, and let’s get this thing under control!

Your humble blogger hopes you will continue to stay safe, stay healthy, and, after this high-and-mighty and somewhat condescending lecture of a blog post, stay a reader 🙂