Archive for November, 2014

“Or in the exercise of reasonable diligence should have known…” and 5412

November 26th, 2014 No comments

Now and then, your humble blogger is denied sleeping the sleep of the just by the thoughts that plague his over-worried and overworked mind.  Sometimes the thing keeping your humble blogger up is a simple thought, like “why do they call grapefruit grapefruit? There’s already a fruit that’s a grape and it’s called grape.”   Other times, though, it is a question more germane to your humble blogger’s life calling, such as “what is that giant blank space in the middle of Labor Code section 5412?”

Go ahead and flip to any copy of any Labor Code, dear readers, even this one online.  In the middle of Labor Code section 5412 is a giant blank space that the Legislators left for no apparent reason.  It reads as follows: “[t]he date of injury in cases of occupational diseases or cumulative injuries is that date upon which the employee first suffered disability therefrom and either knew, … … … … … … …, that such disability was caused by his present or prior employment.”

What’s that, you say, dear readers?  Your copy of the labor code includes the language “or in the exercise of reasonable diligence should have known”?   That’s odd, because there doesn’t seem to be a lot of case law supporting the theory that this section of 5412 exists.

Well, it’s hard to find cases where the WCAB applied that oft-overlooked clause of 5412, but a couple of cases that are citeable authority are actually out there.  (May thanks to Ms. L.L. for pointing these out).

In the case of Alford v. Industrial Acci. Com.a 1946 Supreme Court opinion, it was held that an injured worker’s own, subjective connection of his respiratory symptoms with his work activities, was enough to provide knowledge of industrial causation.

Mr. Alford had, for months, asked his employer to install a ventilator to carry off the excess dust he found himself breathing in at the plaster cast plant where he worked.  He was even coughing up plaster!  At one point, prior to any medical reports confirming industrial causation for his respiratory illness, he went to his employer complaining that continuing this work was detrimental to his health.

The Supreme Court held that his own subjective connection between breathing in the plaster particles and the resulting respiratory symptoms was enough notice to be barred by the statute of limitations.

Another case is that of Nielsen v. WCAB, a 1985 Court of Appeal opinion which held that “[w]ithout more, applicant’s emphatic testimony he thought from the very first day he was off work that his condition was caused by the work assembling and disassembling the bottle racks … would be sufficient to support the determination of  both the WCJ and the Board that he knew or reasonably should have known as of that date that his disability was caused by his employment.”

The Court of Appeal held that if a doctor had told applicant his injuries were not industrially caused, then the requirements of section 5412 would not have been met (probably), but that wasn’t the case in the Nielsen matter.  The Court of Appeal further rejected the writ denied case in International Paper Co., which held that “there can be no ‘legal knowledge’ or knowledge of industrial causation sufficient to start the statute of limitations running where the employee actually believes the disability was industrially caused, but has not obtained a medical opinion verifying that belief.”

In other words, if the injured worker reasonably believes that the injury is industrially caused, and there is no medical opinion to the contrary steering him or her astray, 5412 should be satisfied.  But, what if the injured worker doesn’t subjectively believe it?  Well, perhaps the same logic could apply: what would a reasonable person with the same education and experience of the injured worker have done?

From your humble blogger’s even more humble experience, there appears to be some judicial resistance to the theory that the injured worker knew or should have known of the industrial causation without a medical report.  But, at the very least, it’s worth a try, backed up with a solid brief, of course.

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WCAB: Communication of UR Decision MUST Be Timely Made to go to IMR

November 24th, 2014 No comments

Welcome back from your weekend, dear readers!  The rains are a ‘coming.  The cold is setting in.  Turkey day is almost upon us, which, of course, means that we can expect a flood of “Black Friday” related injuries and Christmas decorations starting November 28.  But, before we look too far ahead, there’s this Monday, and a “Significant Panel Decision” issued by the WCAB.

This one is on the subject Utilization Review, which continues to be somewhat of a clumsy, frequently mutating wolf in the deep dark woods of workers’ compensation.

It makes sense – no? Arguably the most expensive and most valuable benefit available to injured workers is the potentially limitless medical treatment.  The UR-IMR procedure puts a pretty solid clamp-down on this, no?

In the matter of Bodam v. San Bernardino County, the issue of UR timeliness was again explored, as UR timeliness appears to be the only effective challenge to UR nowadays (other than a vigorous applicant’s attorney repeatedly changing treating physicians until the requested treatment is authorized).

Applicant’s primary treating physician requested authorization for a three-level fusion surgery by facsimile (the request was made by facsimile, the procedure was not to be performed over facsimile), and defendant referred the request to Utilization Review that same day.  The UR vendor denied treatment three days later, and defendant mailed the decision five days after that (on the eighth day after the request was made).

So what’s the big deal?  Treatment was timely denied… right?  Not so much.

The WCAB held, in this significant panel decision, that the timelines for communicating the decision are equally mandatory.  The WCAB cited Labor Code section 4610(g)(1) noting that a UR decision “to approve, modify, delay, or deny requests by physicians for authorization prior to … the provision of medical treatment services to employees shall be communicated to the requesting physician within 24 hours of the decision.  Decisions resulting in modification, delay, or denial of all or part of the requested health care service shall be communicated to physicians initially by telephone or facsimile…”

In other words, if UR denies, modifies, or delays a request prior to the treatment being provided, then the decision has to be faxed or called in to the doctor within 24 hours.

Do not go to IMR; do not collect $200; go directly to WCAB Medi-Jail.

The WCAB held that the defendant’s UR process was defective because the UR decision was not communicated to the doctor within 24 hours of reaching a decision, AND because it was not communicated in writing to the injured worker, the applicant’s attorney, and the doctor within 2 business days of the decision being made.

The WCAB then held that the WCJ properly ordered development of the record prior to making a determination as to the merits of the request for authorization.

Your humble blogger is aware that some UR vendors immediately fax and mail out the determination directly to the injured worker, requesting physician, applicant’s attorney, adjuster, and even defense attorney.  Perhaps this is a good practice for all UR vendors to adopt?

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UR: Used to Avoid Medical Bills, Side Effects May Include AD Audit and Sanctions

November 21st, 2014 No comments

Your humble blogger had a brilliant idea recently: why not skip the coffee for a few days?  What could possible go wrong?

Well, I came *THIS* close to filing a workers’ comp claim for the resulting withdrawal symptoms (workers’ comp drives me to drink coffee, among other things, you see).  In the words of Master Yoda: “Path to the dark side, comp is.  Comp leads to exhaustion; exhaustion leads to coffee; coffee withdrawal leads to suffering.” (Thanks for the correction, MC)

So, if your humble blogger suffered so greatly from declining coffee for just a few days, how badly would an injured worker have suffered if deprived of serious pain medication upon which he or she relied for any extended period of time?

Consider, if you will, the matter of McCool v. Monterey Bay.  Applicant was in a car accident way back when in 1983, resulting in several back surgeries, and ultimately a 52% award which included future medical care.

Well, lo and behold: a UR decision elected to deny authorization for various pain medications which applicant had been receiving regularly.  Defendant elected to override UR and provide the pain medication anyway, but three months after the UR denial, applicant requested an expedited hearing out of concern that defendant would one day withdraw its good will.

At the hearing, the WCJ found applicant is entitled to future medical treatment, including the pain medication, until there is a documented change in circumstances, even though defendant continued to provide the medication at the time of the hearing.

Well, defendant sought reconsideration, and the WCAB granted.  Initially, the WCAB held that absent a finding that the UR report was untimely, there’s no basis to review the merits of the UR decision, as per the en banc Dubon holding of the WCAB.  Additionally, as applicant was receiving the sought-after medical treatment, there was nothing for the Board to do, as the commissioners and WCJs are not in the business of issuing advisory opinions to become effective in the event of some possibility in the future.

That being said, the WCAB also pointed out that the UR decision was internally inconsistent, both citing the need to slowly taper off pain medication, and then deciding to make applicant go cold turkey.  Well, in the words of Homer Simpson “going cold turkey isn’t as delicious as it sounds.”

The WCAB cautioned that blind reliance on a UR decision that is internally inconsistent could result to a defendant’s referral to the administrative director for investigation and possible penalties.

So, all in all, a happy ending – applicant gets the treatment she needs!  The defendant gets a victory!  You get a blog post!

Here are some thoughts from your humble blogger:

So, for each UR decision, it’s not only important to review the decision for timeliness, but it appears that there is some threshold the WCAB would like to see met, which in this case was internal consistency.  It would be interesting to note if the same burden is placed upon the defense for multiple UR decisions.  For example, if UR denies surgery because of an injured worker’s weight, but the next UR decision denies lap band surgery because the injured worker is not overweight enough – is that internally inconsistent?

Also, it looks like the applicant took three months to file for an expedited hearing on the matter of medical treatment – shouldn’t there be some time limit on challenging a UR decision for any reason, timeliness or otherwise?  After all, don’t circumstances change, opinions become stale, etc?

As far as your humble blogger is concerned, defendant did the right thing in this case – it’s both prudent and, dare I say it, human.  But, often enough, it’s easy to put away a “denied” UR decision and let the applicant worry about the particulars, such as requesting IMR or challenging timeliness.  This panel opinion serves as a cautionary tale for all of us.

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Silverlake Hills Health Center Billed for Diagnostics; Performed Pilates

November 19th, 2014 No comments

Have you been getting bills from the Silverlake Hills Health Center for “diagnostic” services?  You might want to put that checkbook down for a moment and read this blog post.

A jury recently convicted Lisa Maria Henschel, of the Silverlake Hills Health Center, of 32 felony counts of insurance fraud, finding that she altered bills for services including Pilates, chiropractic care, and acupuncture, to reflect expensive diagnostic codes.  There was apparently some forging of a doctor’s signature involved as well.

Not everyone has an MPN, and some MPNs might potentially have or had Silverlake included, so it might make sense to check the billings on this one.

The business is now apparently closed, and Ms. Henschel might spend some time in jail for her fraudulent actions.  Rest assured, dear readers, there’s plenty more frauds out there!

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A UR Denial and 12 Months of Peace

November 14th, 2014 No comments

So, there you are – triumphantly stroking the recent IMR decision which upheld the UR determination that the injured worker is not entitled to fresh shipments of caviar to help with his industrial paper cut.  What a wonderful feeling – justice is done, the system worked, and now the price on caviar will not sky-rocket out of your price range, such as this scene captured at Occupy Wall Street so many years ago…

caviar at occupy wall street

Well, the injured worker decided to appeal the IMR decision… to his treating physician.  “But Dr. Beluga, I need the caviar to make the boo boo go away, it’s the only thing that works!”  Well, seeing as how Dr. Beluga is a strong believer in the medicinal properties of caviar, he submits another request for authorization, thinking this one will fall through the cracks.

Are you required to process this request again… and again… and again… until between UR and IMR, it would have been cheaper to authorize the treatment?

Well, probably not.

Labor Code section 4610(g)(6) provides that “[a UR] decision to modify, delay, or deny a treatment recommendation shall remain effective for 12 months from the date of the decision without further action by the employer with regard to any further recommendation by the same physician for the same treatment unless the further recommendation is supported by a documented change in the facts material to the basis of the [UR] decision.”

So, Dr. Beluga can only request caviar injections but once a year, unless his second request for authorization is “supported by a documented change in the facts material to the basis of the [UR] decision.”

Now, here’s an interesting question for all y’all: Form 9785.5, the Request for Authorization form, offers options at the top of the form: “New Request” or “Resubmission – Change in Material Fact.”  What happens when the doctor submits a report with his or her RFA discussing the change in material fact, but fails to check the “resubmission” box?  Can the defense ignore the same requested treatment by the same physician?  Your humble blogger doesn’t know, but if faced with this situation will likely argue for the “Resubmission”

In fact, a recent panel opinion (Martha Reyes v. Target) held just that: a defendant is free to ignore the RFA for the same treatment by the same physician which UR recommended be denied less than 12 months before.  And, when in conjunction with Dubon, carriers can effectively budget one UR and one IMR per treatment request per year.

Have a good weekend, dear readers!

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Defying “No Videotaping” and “No Trespassing” Signs Insufficient to Exclude Sub Rosa Video

November 12th, 2014 No comments

Who doesn’t love to pop some popcorn, pop in a DVD, and enjoy an evening of watching allegedly injured workers act like allegedly un-injured workers?  Well, your humble blogger can’t think of a single thing he enjoys more (actually, that’s not true… not even a little bit)

Sub Rosa is always an issue in comp cases where fraud is suspected.  Applicants will sometimes say one thing to a doctor and another to the employers at the jobs they aren’t supposed to have while collecting temporary disability, or engaging in the various other pursuits which one can throw oneself into while collecting the salary of full time job and simultaneously having the obligations of one completely unemployed.  (Joe Applicant: Waiting for this temporary disability check IS a full time job!)

Of course, it is within every applicant’s and applicant’s attorney’s best interest to keep the QME and PTP from viewing any version of the applicant other than the one presented at the relevant evaluation or appointments.  So, when there is some damning sub rosa video available, some applicant attorneys will go to great lengths to get the videos kicked to the curb.

Ponder, if you will, the case of Duong v. Automobile Club of Southern California.  Therein, defendant obtained sub rosa video of applicant while on the street, from the driveway of a mobile park home, and then from the property itself, although all filming was done from the private investigator’s car.  Applicant was also videotaped in an Albertson’s grocery store.

Applicant sought to have the sub rosa video excluded because of the posted “no trespassing” signs.  It appears that Civil Code section 1708.8 was considered (liability for invasion of privacy for entering the land of another person to videotape or photograph a person “engaging in a personal or familial activity”), but upon defendant’s petition for reconsideration of the WCJ’s exclusion of the sub rosa video, the WCAB held that 1708.8 governs civil liability for tort, and not admissibility before the WCAB.

The WCAB also disagreed with the WCJ’s policy considerations of protecting an applicant’s privacy in this case, as there is no right to privacy in a grocery store or in the publicly visible areas of a mobile home park.

So, for the time being at least, it appears that third parties cannot create an investigator-free zone by posting “no trespassing” or “no videotaping” signs.  As you can imagine, your humble blogger is very pleased with the result in this case, because anything that keeps the parties honest is a good thing.

Now, if only we could have use of sub rosa as rebuttal evidence without first disclosing it on a 5-pager, everyone would be very honest indeed.  Sadly, as some of my readers will recall, that’s not the case.  But, for the time being, your humble blogger will take what he can get.

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Happy Veterans Day!

November 11th, 2014 1 comment

Hello, my dear readers!  Although I’m sure this e-mail will find some lucky few of you on Wednesday rather than today, I still wanted to submit what the kids are calling “a shout out” to honor our veterans on this Veterans Day, 2014.

Thank a vet, buy or her a beer or a coffee, or, if you’re feeling particularly patriotic, check out the good folks at Fisher House, which helps provide housing for veterans’ families while they are visiting them in recovery.

See you back here, bright and early, tomorrow, dear readers!

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MPN Medical Discharge Contestable Through Panel Process; Not 2nd MPN Opinion

November 10th, 2014 No comments

Hello, dear readers!   So, show of hands: who is blowing off Monday and taking a four-day weekend through the end of Veteran’s day?  Ok, now, show of hands: who actually raised their hands in response to a blog post that can’t see them or acknowledge the hand-raising?

For those, like your overworked and underfed humble blogger, who are powering through Monday and, in all likelihood, Tuesday, I have the following story to relate to you.

A dear and beloved friend of mine obtained one of those rare gems in workers’ compensation – one of those diamonds that are rarely found and always appreciated: the full discharge.  The injured worker can avoid being maimed by surgery or having his life destroyed by doctor-provided narcotics, and can  return to full duty.  Meanwhile, the employer can go back to the work at hand (the business of business is business, after all).

Well, what if the injured worker, or his attorney, isn’t too satisfied with a total discharge?  After all, how much does an applicant’s attorney get from an attorney fee of 15% off of a 0% PD and no need for future medical care?  (Hint: even 100% of 0 is still 0).

So, what’s to be done in this case?  What devious treachery can the employer and/or its insurer expect from the less reputable applicants’ attorneys looking to turn a healthy worker into an unhealthy one?

California Code of Regulations section 9785(b)(3) provides that [i]f the employee disputes a medical determination made by the primary treating physician, including a determination that the employee should be released from care, the dispute shall be resolved under the applicable procedures set forth at Labor Code section 4060, 4061, 4062, 4600.5, 4616.3, or 4616.4.”

Now, what do you think, dear readers, would the applicant’s attorney prefer to have his client on temporary total disability and receiving some sort of “treatment” while awaiting a panel, or would the attorney rather his client go back to work and put this whole injury behind him, possibly decided to abandon any claim?

If you’ve got an MPN set up, the applicant’s attorney is going to turn to Labor Code section 4616.3, and demand an MPN second opinion and possibly a third opinion, until some doctor says that further treatment actually is necessary.  The specific language is in subsection (c): “[i]f an injured employee disputes either the diagnosis or the treatment prescribed by the treating physician, the employee may seek the opinion of another physician in the medical provider network.”

Furthermore, the applicant’s attorney will tell you, Labor Code section 4061 specifically excludes “the employees dispute of the medical provider network treating physician’s diagnosis or treatment recommendations under Sections 4616.3 and 4616.4.”

So, then, dear reader, are you stuck?  Is there nothing you can say to respond to these demand for a second, or possibly third, opinion as to whether further treatment is necessary?  Maybe there is.

Websters defines “diagnosis” as “the process of determining by examination the nature and circumstances of a diseased condition and the decision reached from such an examination.”

Websters also defines “treatment” as “to deal with (a disease, patient, etc.) in order to relieve or cure.”

Do either of those definitions fit with “discharge from care”?   As such, does 4616.3 really apply, given that it provides a second and third opinion as to “the diagnosis or the treatment prescribed.”

In the panel case of Acosta v. Balance Staffing Services, where the same issue arose and the WCAB, concurring with the WCJ, found that a discharge from care without need for further medical care was subject to the panel process, and not the MPN second-opinion process.

Now, here’s another tidbit – you probably like the specialty of the physician that gave you a discharge.  If that’s the case, and if you’re timely with your panel request, the treating physician can’t be changed under regulation 9785(b)(2), so odds are your panel will be in the same specialty as the one that found your injured worker dischargeable.  All good stuff, no?

What do you think, dear readers, is a discharge from care a diagnosis or treatment as contemplated by Labor Code section 4616.3?  Let your wisdom grace the comments below, or send an e-mail to your humble blogger.

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Ivan [and] the Terrible [Paper Cut], or is this Psyche Injury “Catastrophic”? [Part 3 of 3]

November 7th, 2014 No comments

Here were are again, dear readers.  Some have come willingly; some don’t know how to make the “unsubscribe” button work on their e-mails (it’s just there for show, dear readers – you’re stuck with me for good!).  Whichever way you made it here, it’s time to wrap up the story of Ivan and his totally permanently disabling paper cut injury.

Labor Code section 3208.3(d) provides that, for a psyche claim to be compensable, an injured worker must have been employed at least 6 months, unless the injury was caused by a “sudden and extraordinary employment condition.  Leaving aside the 3208.3 defenses involved in this case, and boring poor Ivan with the particulars of what is considered sudden and what is considered extraordinary, do these rules still apply?

Is it enough to show that there is a catastrophic event, under Labor Code section 4660.1, regardless of the applicant’s tenure?  Can an injury be catastrophic under section 4660.1, and yet not sudden and extraordinary in the meaning of 3208.3(d)?  And what effect do these moving parts have on the benefits to which an injured worker may be entitled?

The language of 4660.1 suggests that the measurement of the operative words, “catastrophic” refers to the injury, or rather the physical effects of the injury – paralysis, loss of a limb, severe burns, severe head injury.  By contrast, section 3208.3(d) discusses a “sudden an extraordinary employment condition.”  Furthermore, while the failure to establish at least 6 months of employment or a sudden and extraordinary employment condition precludes the recovery of any “compensation,” the failure to establish a catastrophic event merely precludes any increase in impairment due to the psychiatric injury.

Section 4660.1(c)(1) specifically provides that “[n]othing in this section shall limit the ability of an injured employee to obtain treatment for … psychiatric disorder, if any, that [is] a consequence of an industrial injury.”

So, in other words, if all that you’re missing is proof of a catastrophic event, Ivan may be able to secure the right to treatment, but if Ivan’s employment was less than six months in length and the injury wasn’t caused by a sudden and extraordinary employment condition, Ivan may be out of luck completely.

But… where does that leave temporary disability benefits?  TTD isn’t medical treatment, as specifically protected by section 4660.1(c)(1), yet it’s not really an increase in impairment, as excluded by section (c)(2).  A good defense attorney would argue that if the legislature wanted to protect temporary disability benefits, the legislature could have done so as did for medical treatment.  But, at the same time, any applicant’ attorney would likely argue that if the legislature wanted to exclude temporary disability benefits, it could have done so as well, like it excluded any increase for impairment.

At this point, with little to no authority on the subject, it looks like an injured worker could make it past the hurdles of 3208.3 but fail to make it past the test of 4660.1, and thereby become entitled to temporary disability and medical treatment, but not permanent disability.

In Ivan’s case?  It may be a hard sell.  His three-month tenure with the paper factor probably precludes any psyche claim, as being barred by Labor Code section 3208.3.  But, let’s say his attorney manages to persuade a WCJ that 4660.1 renders 3208.3 inoperative, or perhaps that the slip-and-fall and the fluttering piece of paper were sudden and extraordinary, then perhaps he might be able to get medical treatment and temporary disability benefits.

However, aside from applicants’ attorneys’ fantasies, there’s no basis to conclude that 3208.3 is somehow made inoperative by 4660.1.  So make sure there’s another bullet point on your checklist, because, even if a doctor or a medical evaluator finds Ivan permanent and stationary and assigns any level of permanent disability, unless the adjuster on his case thinks that the injury was “catastrophic,” he’s probably going to see a denial notice issued.

What do you think, dear readers?  Should Ivan let the matter go, or just get over his paper cut and get back to work?

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Ivan [and] the Terrible [Paper Cut], or is this Psyche Injury “Catastrophic”? [Part 2 of 3]

November 5th, 2014 No comments

Welcome back, folks!  As you may recall from the last post, my beloved cousin Ivan suffered a horribly debilitating injury when a fluttering piece of paper gave him a paper cut, causing a near-paralyzing fear of all paper products, and thereby precluding him from resuming his brilliant career at the paper factory.  Ivan had come to me for some “family discount” legal advice about whether the resulting psyche injury was compensable.

By way of background, dear readers, Senate Bill 863, signed into law by Governor Jerry Brown on September 18, 2012, took effect immediately, except for those sections which set a different activation date.  The newly minted Labor Code section 4660.1 took effect for all injuries sustained on or after January 1, 2013, and subsection (c) provided that there would be no increase in impairment for such psyche injuries unless they were the result of (A) a violent act; or (B) a catastrophic injury.

Labor Code section 4660.1 provides some examples of what might constitute a “catastrophic” event, but doesn’t provide very much by way of a specific test.  So, how are we, poor humble workers’ compensation G[r]eeks supposed to interpret these decrees from up high on Mount Olympus Sacramento?  (If you’ve never been to Sacramento, there’s not much there by way of mountains in the city itself, but I’m hoping you’ll go with me for the analogy).

Well, let’s start with the basics – the code section itself:

Labor Code section 4660.1(c)(B) holds: “[a] catastrophic injury, including, but not limited to, loss of a limb, paralysis, severe burn, or severe head injury.”  Does it have to be as bad as all that?  Well, probably.  After all, doesn’t the list provided by the legislature give us some indication of the significance of the injury necessary to provide a compensable psychiatric injury?

“Catastrophic” is defined by Webster’s Dictionary as “a momentous tragic event ranging from extreme misfortune to utter overthrow or ruin.”  Nor did the term “catastrophic” come into creation with SB-863.

The Workers’ Compensation Appeals Board has used “catastrophic” to describe injuries rendering an applicant a quadriplegic (Brock v. KS Industries, LP (ADJ8407884)), brain injury resulting in a several-month stay in the hospital, with residual left side weakness, decreased memory, fatigue, and seizures (Mulford v. El Toro RV, Inc. (ADJ7763946)), and lack of use of an applicant’s arms and leg and the need of round-the-clock care (Barragan v. American Bridge/Fluor Enterprises (ADJ7714923)).  So, a paper cut might not make the cut (see what I did there?)…

Now, when I explained all this to my dear cousin Ivan, he seemed, oddly enough, to be encouraged.  To him, the case of the vicious paper cut was actually clear-cut (see what I did there again?): it was catastrophic in that he could no longer return to work at the paper factory, and is now so scared of paper that he shivers every time I jot down a note on my legal pad, and jumps every time my printer spits out a fax.

So, naturally, as a matter of cousinly concern, I asked him just how long of a career in the paper industry was struck down by this sad event.

“When all this happened, I had just got done with my 3-month probation period.  Just think of it, such an excellent career cut short in its prime!”

Poor, poor, Ivan.  Come back on Friday for the exciting conclusion of Ivan [and] the Terrible [Paper Cut]…

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