In this case, a police officer was driving a squad car in response to a call for emergency assistance. He suffered an injury in a vehicle collision. The officer filed a workers’ compensation claim for that injury. Our office represented the officer’s employer, a suburban municipality. A settlement of the workers’ compensation case was reached with the employer reserving its lien rights to reimbursement if a recovery was made in any third party claim.
Although the police officer declined to sue the other driver, we believed that the collision was caused by the other driver’s negligence. Under Section 5(b) of the Illinois Workers’ Compensation Act, an employer may file suit against a third party who is liable for a work-related injury within the last three months before the statutory period for such filing would otherwise expire.
Robert Newman of our firm did file a suit on behalf of the employer against the other driver and established his negligence during the course of the litigation. A settlement was obtained which reimbursed the employer all monies expended in the Workers’ Compensation case including medical bills, lost time costs and the permanent disability settlement.
For questions about Section 5(b) and recovery pursuant to a Workers’ Compensation lien or subrogation interest, you may contact Robert T. Newman of the firm at 312/627-0631 or rnewman@msulaw.com.
Our firm has recently received three favorable arbitration decisions which highlight the importance of documenting accident reports in a claimant’s own words and obtaining contemporaneous medical histories attributed to the claimant. Documentation of pre-existing problems including obtaining family physician and prior treating records is also helpful.
In the first case, the claimant alleged an aggravation of prior low back problems. He gave several different histories regarding how his low back was reinjured which included grinding components, pushing a large object at work, pushing a box at work, opening a door at work and returning from a break with his legs not holding him. Initial examination findings indicated an unremarkable MRI and very few findings. Several months after the accident, an employee health nurse contacted a company physician and advised that the claimant was concerned about not knowing why he had low back pain, noting that while he had pushed an object at work, it required minimal effort and involved his arms and not the lower back muscles. Thereafter, the claimant saw a surgeon who repeated the MRI and diagnosed discogenic low back pain from a disc protrusion and an annular tear. Attorney Gary Gale obtained a denial of the claim with the Arbitrator finding that the claimant’s testimony regarding the alleged accident and histories to various healthcare providers were inconsistent.
Attorney Robert Ulrich represented the employer in the second case. It involved an issue of causal connection between an accident and low back complaints. The accident itself was not disputed – the dispute focused on which parts of the claimant’s body were affected. On the accident report, handwritten and signed by the claimant, she reported a right upper back injury extending down her arm to her hand while pulling overhead a stuck part out of a baking oven. This was contrasted by her Arbitration testimony where she alleged that while pulling the part out, she twisted like a pretzel and her whole body jerked. Similar versions involving twisting and jerking were reported to treating providers many years after the accident.
However, immediately following the accident, the claimant had no low back complaints or treatment, though she did receive treatment for her right upper back, shoulder, arm and hand. Histories to these contemporaneous medical providers indicated only an injury to her shoulder down to the hand. There was no mention of low back problems in follow-up office notes. When the claimant switched to a different treating chiropractor, she still had no low back pain complaints. The employer sought opinions from two different doctors who reviewed these treatment records and concluded that the contemporaneous notes documented only a right shoulder injury and that it was inconceivable that the shoulder condition would mask low back pain.
In quite detailed findings and conclusions, the Arbitrator denied benefits for the low back condition and noted that the claimant had a chronic, pre-existing low back problem which was more significant and permanent than she had indicated in her testimony. Yet, he noted that the claimant’s specialist had no grasp of her earlier history. The Arbitrator completely questioned the claimant’s credibility, finding that her “clinical picture,” taken from family doctor’s records, indicated she had engaged in doctor-shopping, sought aggressive treatment contrary to her family doctor’s advice and displayed significant emotional instability. He inferred that she had attempted to stage evidence for purposes of the litigation and manipulate the legal system. The Arbitrator noted that when the claimant pressed her doctors for either back surgery or imposition of work restrictions, several physicians found she was not a surgical candidate and had too few findings and too much overlay!
In the most recent decision, Attorney Gale again received another favorable ruling issued only a few weeks ago. The evidence presented similar inconsistencies in testimony and histories of a knee injury given to various medical providers. The claimant testified that the accident occurred after kneeling down for several hours one day while repairing a furnace and then later on the same day, throwing some furniture in a dumpster. Medical histories included kneeling down while repairing the furnace as well as going up and down ladders. Other doctors reported no known injury with generalized complaints of knee pain. The accident report, again handwritten and signed by the claimant, did not reference kneeling while repairing a furnace and also indicated an earlier date of accident. During his testimony, the claimant stated that he had signed the accident report when he was confused, but he later independently remembered the correct date of accident. He also admitted to a history of memory problems for which he had taken medication.
Given these circumstances, the Arbitrator did not need to find the claimant lacked credibility to deny benefits. He found that the claimant had either alleged differing accounts of how the injury occurred or provided no account at all. Due to the number of inconsistencies, the Arbitrator stated that to find an accident, he would have to speculate as to which events caused his knee problem and as liability may not rest of speculation, the claimant had failed to prove he sustained an accident on the date alleged. The claimant has already filed a review to the full Commission.
It is clear from these three decisions that the thoughtful gathering of prior and contemporaneous medical records is invaluable in proving inconsistencies that an arbitrator can cite to deny claims. Equally important are accident reporting forms – best completed by the claimant with a signature. If such evidence indicates inconsistencies, a claimant may then be discredited during testimony before an arbitrator.
After a quiet year where the Workers’ Compensation Commission panel of the Illinois Appellate Court had rendered only three published decisions, the five justices issued a flurry of opinions in December. These cases addressed diverse matters, some of first impression in Illinois, involving undocumented aliens, fraudulent claims, and procedural constraints in litigating before the Commission. Below is an analysis of these cases and recommendations for handling claims in the wake of the decisions.
Economy Packing Company v. IWCC (December 9, 2008) - Undocumented Alien Entitled to Permanent Total Disability Benefits under “Odd-Lot” Category
The Appellate Court has now held that an undocumented alien can establish that she is permanently and totally disabled under the “odd-lot” doctrine because she proved that she cannot sustain regular employment in a well-known branch of the labor market without regard to her undocumented status. The Court indicated the burden of proof would then shift to the employer to prove that, but for the undocumented alien’s legal inability to obtain employment, suitable work would be regularly and continuously available.
In this case, the Commission had affirmed the arbitrator’s award to a woman who had suffered multiple injuries when she slipped, hit a wall and fell onto the floor while working on an assembly line manually deboning chickens. The claimant had been born in Mexico and admitted that she lacked paperwork to obtain legal employment in the United States. She had presented false documents when she applied for her position with the employer. After her injury and treatment, she had permanent 10-lb. and no overhead lifting restrictions which could not be accommodated by the employer. At that time, she was 60 years old and had been in the United States for more than two decades. She had attended only three years of school in Mexico before working on a farm. She spoke only Spanish and could not speak, read or write English. She did not drive.
Significantly, neither the vocational expert consulted by the claimant of the employer based their opinion on her undocumented alien status. The employee’s expert stated she was limited to less than sedentary work for which no stable labor market existed, concluding that even if she were a citizen, she would not be employable. The employer’s expert reported that while she was not a candidate for vocational rehabilitation, she would be able to perform a wide range of unskilled sedentary occupations but for her inability to legally obtain employment.
Referencing the standards for proving entitlement to permanent and total disability under the “odd-lot” doctrine, the arbitrator concluded that the claimant was not obviously unemployable and the medical evidence indicated she was limited to less than sedentary work. The Arbitrator concluded that her age, lack of education, lack of transferable skills, inability to speak English and physical restrictions rendered her unfit to perform any but the most menial tasks for which no stable labor market exists. She was awarded permanent total disability benefits. The Commission affirmed and adopted the arbitrator’s decision. On the employer’s appeal, the Circuit Court, in turn, affirmed the Commission’s decision.
The employer filed a further appeal to the Appellate Court and raised two issues. The first issue was based on federal law (the “Immigration Reform and Control Act of l986”) barring employers in the United States from hiring undocumented aliens. The employer argued that under this law, an undocumented alien is always unemployable and thus she could not prove she is unemployable as required for entitlement to permanent total disability benefits.
The Court rejected this argument, finding that the federal law does not automatically preempt an award of permanent total disability. The Court concluded that the award does not conflict with federal immigration policy, reiterating that the claimant would be able to work elsewhere but for the work-related injury. It further noted that, in contravention of the purpose of the federal law, excluding undocumented aliens from receiving workers’ compensation benefits would actually provide a financial incentive for employers to hire undocumented workers.
The second issue before the Appellate Court was whether an undocumented alien can prove permanent total disability pursuant to the traditional test for employees who fall within the “odd-lot” category. The Court stated that the employer was correct that the traditional test cannot be applied to undocumented aliens, but nevertheless, believed she could establish she is permanently and totally disabled under the “odd-lot” doctrine so long as her unemployability is not based upon her immigration status.
The Appellate Court noted that this issue was one of first impression in Illinois and looked to a 2002 North Carolina case where their state court of appeals observed that although federal immigration law prevented an undocumented alien from returning to the same pre-injury job or any other job in the United States, federal law did not prohibit conducting a labor market survey to determine what suitable jobs are available bur for the immigration status. The Illinois Appellate Court found that reasoning sound, noting that neither of the vocational experts had considered the claimant’s immigration status when proffering their opinions. The Court then, in affirming the Commission’s decision, cited to the Commission’s function to weigh the evidence and its greater reliance on the opinions of the claimant’s expert. It rather routinely concluded that the Commission’s decision was not against the manifest weight of the evidence.
The Economy Packing decision resolves a question that has been seen in more and more cases before various arbitrators. Many arbitrators were receptive to the arguments that undocumented aliens were not entitled as a matter of law to permanent total disability benefits. It is now clear that they may be entitled to these benefits if a sufficient factual showing is made.
Weyer v. IWCC (December 16, 2008) – Successive 19(b) Hearing Present Separate Causation Questions that are not precluded by the Law of the Case Doctrine
Sometimes cases drag on over a period of years and there are successive hearings for payment of interim lost time and/or medical benefits. These hearings are held pursuant to sections 19(b) and 8(a) of the Workers’ Compensation Act. Each award of lost time benefits may not extend beyond the date of the most recent hearing. However, the award or, for that matter, the denial of such benefits does not bar future hearings for additional lost time, medical expenses and, when appropriate, for permanency. A procedural issue arises when a previous hearing has addressed the threshold compensability issue of causation between the work accident and the injury that allegedly resulted therefrom.
In Weyer, the claimant alleged a shoulder injury that an arbitrator initially determined was causally related to the work accident. The claimant had an MRI of the shoulder which was negative for tears and had returned to work within the first six months following the accident. However, his complaints continued and he was subsequently restricted from overhead lifting. When that restriction was not accommodated, temporary total disability benefits were awarded.
A second hearing resulted in an award for continuing lost time benefits due to ongoing shoulder complaints which prompted his doctor to question whether he had torn the rotator cuff or glenoid labrum. An MR-arthrogram revealed a SLAP lesion that the treating physician opined had caused his persistent left shoulder problems since the work accident and recommended surgical repair. The employer’s examining physician who had twice previously examined the claimant saw him again and reviewed the test results. He opined that the labral tear (SLAP lesion) could have occurred any time during the past three years and because an MRI taken a few days after the work accident demonstrated that the glenoid labrum was intact, it did not relate back to the accident.
After the second 19(b) hearing, the arbitrator found that while the claimant had suffered an aggravation of his shoulder condition at the time of the accident, it had resolved prior to the tear diagnosis. The arbitrator cited the claimant’s ability to perform work and complete a functional capacity evaluation within the first six months after the accident which was inconsistent with his having sustained a labral tear. The arbitrator denied further benefits and his second decision finding that the claimant failed to meet his burden of proving a causal relationship between the SLAP lesion and the work accident was affirmed by the Commission and subsequently, by the Circuit Court.
On further appeal to the Appellate Court, the claimant argued that the first Arbitration decision, which neither party had reviewed to the Commission, was final and had resolved the causation issue. The claimant cited the law of the case doctrine which provides that a final decision of a question of law or fact reached during the course of litigation settles that question for all subsequent stages of the case. This doctrine has been held to apply to proceedings before the Commission.
However, the Appellate Court held that the two Arbitration hearings had involved different legal and factual issues and since the labral tear was not diagnosed until later, the first hearing obviously did not involve the question of whether the tear had been caused by the work accident. Thus, the law of the case doctrine did not prohibit the litigation of new issue presented by the recent labral tear diagnosis.
This decision mandates a departure from common practice at the Commission where many arbitrators have refused to entertain causation issues to long-delayed diagnoses and newly arisen conditions. Employers not have a solid basis to dispute causation to conditions that often do not arise until several years after work accidents.
Smalley Steel Ring Company v. IWCC (December 12, 2008) – Employer Remedy for Fraudulent Claim is in Circuit Court not Commission Proceeding
In this case, it is helpful to start with a recitation of the relevant facts. The claimant alleged a work injury resulting in left arm injuries and sought an Arbitration hearing. At the hearing, the employer requested a 30-day continuance, in part to obtain verification of claimant’s identity asserting that his stated social security number belonged to a deceased person. The arbitrator denied the continuance and proceeded to hold an evidentiary hearing on the merits. Thereafter, he issued a decision finding a compensable accident and awarding lost time benefits and medical expenses. Neither party sought review by the Commission; however, within the period for such appeal expired, the employer filed an emergency motion to recall the arbitrator’s decision and reopen proofs.
In its motion, the employer provided evidence of the claimant’s having filed the claim using a false name and social security number. It also set forth the claimant’s true identity and his having sustained a prior left arm injury while working for a different employer which had resulted in a settlement that the current employer could claim credit for. Neither the claimant nor his attorney appeared on the motion and the arbitrator conducted a hearing on the motion. At the conclusion of the hearing, the arbitrator granted the motion, recall his decision and reopened proofs.
Thereafter, the arbitrator conducted another hearing and heard additional evidence. Again, neither claimant nor his attorney appeared at the hearing. The arbitrator then issued a second decision, determining that the claimant had lied at both the initial hearing and to his treating physicians. He stated the claimant completely lacked credibility and had thus failed to prove he sustained a compensable accident. His claim was denied in its entirety.
The claimant appealed this second decision to the Commission. The Commission held that the arbitrator had lacked jurisdiction recall his first decision, reopen proofs or reissue his decision. It reinstated the arbitrator’s first decision as the Commission’s final decision and rendered the second arbitration decision null and void.
The Commission decision was confirmed by the Circuit Court and subsequently in this recent decision, by the Appellate Court. The Court stated that while the facts presented “an unfortunate scenario” and the employer possessed “strong evidence of fraud,” the arbitrator lacked the statutory authority to act. It noted that the only statutory basis allowing an arbitrator, or the Commission for that matter, to recall a decision is to correct a clerical or computational error. Despite the arbitrator’s failure to grant the continuance which had notified the claimant about the fraudulent conduct, his actions after issuing his first decision lacked statutory authority and were nullified.
The Appellate Court cited an old Illinois Supreme Court case from 1941 that lacking express authority of the Commission, the claimant was relegated to bringing a civil fraud action. The Court also stated that the deficiency in the Commission’s authority should be addressed by the legislature.
City of Chicago v. IWCC (December 23, 2008) – Employer’s IME Report Wrongly Excluded - Taking of Evidence Deposition does not constitute the Commencement of Hearing
At issue was whether the Commission erred in excluding an employer’s Independent Medical Examination (IME) report because it was not disclosed to the claimant prior to the taking of his treating physician’s deposition. Employers routinely request that claimants be examined by a physician of their choice as provided for in section 12 of the Workers’ Compensation Act. This provision requires that reports written by the examining physicians must be furnished to the employee or his representative “as soon as practicable but not later than 48 hours before the time the case is set for hearing.”
A problem arises because often, arbitrators will request that the parties complete any doctor depositions before a claimant and any other witnesses testify. Thus, all the evidence can be taken at one setting. However, several Commission cases have equated “the time the case is set for hearing” with the taking of doctors’ depositions and excluded from evidence IME reports that have not been given to the opposing party more than 48 hours earlier.
In this case, the Commission had excluded the report of the employer’s IME doctor because it had not been disclosed before the treating doctor’s deposition was taken. In fact, it had not even been generated. Both parties had taken the deposition of the treating physician by agreement. At the time of the deposition, a hearing before an arbitrator was anticipated though no date had yet been set. After the deposition, the matter remained pending for several months with no set hearing date. During that time, the employer scheduled an IME as provided for in section 12 and a report was issued a few weeks later. This report was given to the claimant’s attorney within another few weeks. In a letter accompanying the report, the employer’s counsel inquired as to whether the claimant’s attorney would agree to admit the IME report or require a deposition of the doctor. The claimant’s attorney never responded to the inquiry.
Another five months later, when the case was heard by an arbitrator, the claimant’s attorney objected to the report. The Arbitrator sustained the objection and issued his decision finding the claimant permanently and totally disabled based on the unrebutted opinions found in the treating physician’s deposition. Once again, the Commission affirmed and adopted the arbitrator’s decision. The employer appealed and the Circuit Court confirmed the Commission.
However, the Appellate Court vacated the award, finding that as a matter of law, the arbitrator erred in excluding the employer’s IME report. The court reasoned that the 48-hour provision of section 12 sought to prevent surprise medical evidence at an arbitration hearing but that no such surprise had occurred here. It cited the fact that the claimant had attended the IME without objection and the resulting report was tendered soon after the examination and well before the arbitration hearing. However, the Court cautioned that had the IME and report been completed before, but withheld until after, the treating doctor’s deposition, the outcome may have been different.
In this case, the Appellate Court has reached a logical and fair conclusion to the knee-jerk objections to properly obtained medical examinations and reports. The Commission may not longer routinely reject these reports in the absence of any surprise or unfairness. The right to a section 12 IME remains a vital tool in the defense of workers’ compensation claims.
Entitlement to TTD After Termination for Cause of Light-Duty Employee
What happens when an injured employee who is working light duty on restrictions is terminated for cause? Is he entitled to temporary total disability benefits? The Appellate Court recently faced this issue and held that an employee who voluntarily removes himself from the work force for reasons unrelated to his injury is not entitled to collect temporary total disability (TTD).
The Recent Interstate Scaffolding Case
In Interstate Scaffolding, Inc. v. I.W.C.C., (October 20, 2008), the Illinois Workers’ Compensation Commission Division of the Illinois Appellate Court focused on whether the departure from work was voluntary and then stated that a termination for cause involved a voluntary act. The relevant facts in the case are an employee who sustained work-related head and neck injuries, was off work for an extended period of time and was eventually released to work with specific lifting restrictions. The employer accommodated the restrictions and the employee returned to light duty. A few months later, he was fired for defacing company property.
The Court first discussed the general rule entitling a claimant whose condition has not stabilized or, as often referred to, not yet at maximum medical improvement (MMI). A claimant in that situation would generally be entitled to TTD benefits. However, the Court noted that while there was evidence that this claimant’s condition had not stabilized and he was technically considered temporarily totally disabled, he was not entitled to TTD benefits following his discharge.
The Court went on to review prior case law and how other jurisdictions had addressed the issue, noting that TTD had previously been denied based on other voluntary actions by a claimant including failure to cooperate with rehabilitation efforts or refusal to perform light-duty work. The Court also analogized the case to a light-duty employee voluntarily retiring from the work force to collect a pension, especially if the employee presented no evidence that the retirement decision was related to the work injury or disabililty. (City of Granite City v. I.C., 279 Ill. App. 3d 1087 (1996). The Court thus joined other states that deny compensation to employees who are terminated for misconduct where the disability played no part in the discharge.
Lastly, the Court in Interstate Scaffolding stated that denying benefits to employees terminated for cause would not advance the stated goal of the Illinois Workers’ Compensation Act to compensate an employee for a work-related injury. Rather, the Court sought to prevent a windfall to terminated employees.
The Dissent in Interstate Scaffolding
Of course, there is always another side in the law and there is a caveat to the Interstate Scaffolding decision. Can the denial or suspension of TTD benefits be lifted if an employee demonstrates that the work-related disability is the cause of an inability to find or hold new employment? Two of the five appellate judges who sit on the Commission Division of the Appellate Court dissented from the three-member majority opinion. The dissenting judges stated that the majority announced a new principle providing that TTD may be discontinued where an employee who, upon returning to light duty or to a rehabilitation assignment, is terminated from the work force as a result of voluntary conduct unrelated to his disabling condition, but did not provide standards for practical application of the new principle. The dissenting opinion expressed concern that if an employee subsequently establishes that the medical restrictions resulting from the work-related injury prevent him from securing employment at pre-injury work levels, then TTD benefits should be payable for any loss of earning capacity.
Therefore, the dissent indicated that simply showing voluntary conduct resulting in termination should be insufficient to discontinue benefits and suggested the employer should justify the reasons for discharging the employee before denying benefits. The dissent reasoned that doing so would prevent an employer from citing misconduct, which might not otherwise result in termination, as a pretext for terminating an injured employee and would protect against harassment leading to voluntary termination. Employers would also benefit by being insulated against unacceptable behavior that ordinarily would result in the termination of an employee.
According to the dissent, there was no evidence in Interstate Scaffolding of whether the employee would be able to find and hold other employment due to any work-related disability or medical restrictions. Nor was there evidence of whether an able-bodied employee had ever been terminated for such conduct. It claimed however that there was evidence of his having trouble sleeping and increased irritability and temper which may have caused cognitive changes leading to his misconduct. The dissent opined that whether the employee’s conduct was related to his post-concussion symptoms presented a fact question that neither party had addressed. A remand with an opportunity for both sides to present additional evidence was recommended. Such evidence might include the employee documenting an unsuccessful job search due to his ongoing restrictions.
The dissenting judges also raised concern that the Commission is not the proper forum for determining whether just cause existed for terminations, noting that employers might subsequently argue in retaliatory discharge actions that the Commission finding an employee’s TTD benefits were properly denied following termination should bar relitigating that issue in a civil case.
Misconduct as a Motive to Expand Entitlement to TTD
Almost one year previous, the Appellate Court hinted at a position on the issue of entitlement to TTD after a “just cause” termination. In an unpublished order in the case of Menard, Inc. v. I.W.C.C., (Docket No. 4-06-0771WC - filed November 9, 2007), the Court reversed the Commission who awarded TTD because the claimant’s condition had not yet stabilized at the time of his termination. At least one of the claimant’s doctors had recommended he participate in a pain management program and based on that recommendation, the Commission found the Petitioner was not at MMI. The Appellate Court disagreed, stating the claimant’s condition had resolved as much as expected and pain management was solely to alleviate his subjective, fluctuating complaints of pain and to provide coping strategies. This reasoning differed from that of the lower court which had also reversed the Commission, but cited its concern that the claimant should not be “free to terminate his employment of his own volition for non-medical reasons, or for deliberate misconduct in the workplace, and thereby compel the payment of TTD because his injuries had not stabilized.” In citing the lower court’s language, the Appellate Court noted that the claimant had not argued his termination was unjustified, but again based its denial of TTD on the evidence supporting a finding of MMI.
Prior Commission Decisions Have Awarded TTD After Just Cause Terminations
The Interstate Scaffolding holding represents a definite departure from positions often taken by the Commission. In past decisions, the Commission has awarded TTD after claimants were fired for store theft (Kuzara v. Petrie Stores, 00 IIC 0322), unspecified business reasons involving “improprieties” (Burns v. Interparking, I04 IIC 0227), safety rule violations (Alicea v. Sysco, 06 IWCC 0596), walking off a light duty job (Saczek v. Rosewood Care Center, 08 IWCC 0169) and termination for being “unsafe” (Casper v. TCR System Co., 08 IWCC 215). However, it is not unprecedented for the Commission to deny benefits after a termination for cause. See, Cookson v. Lowes, 03 IIC 0495 (terminated after making threats and evidence that the employer would have continued accommodating work restrictions) and Kirk v. City International, 06 IWCC 0382 (termination under no call/no show policy).
Looking Forward After Interstate Scaffolding
There is a lot of controversy over the Interstate Scaffolding case. As one might expect, there is no general consensus among attorneys practicing in the workers’ compensation arena over the Court’s reasoning. The decision is from a narrow three-judge majority with a dissent that raised several concerns over application of the majority’s holding. The employee has filed a Petition for Rehearing to the Supreme Court of Illinois arguing that this is an important question of law and one of first impression in this state.
For the time being, the issue of whether an injured employee working light duty and/or with restrictions is entitled to TTD after termination remains a question of fact for the Commission to decide. The focus will be on why the employee was removed from the work force. Any employee misconduct or other voluntary removal from the work force should be well-documented. Company policies and their enforcement should be well-established and communicated. It is in an employer’s interest to show that the reason for an individual’s termination was unrelated to the work injury or any resulting restrictions.
Finally, it must be remembered that the workers’ compensation claim of an employee terminated under these circumstances is not extinguished by the termination. It becomes more difficult to oversee and manage the claim of a worker who is no longer working for you.
Multi State Workers’ Compensation Seminar – Illinois, Indiana, Michigan & Wisconsin – January 9, 2009
With attorneys from neighboring states, Robert Maciorowski is one of the planners and a featured speaker at this upcoming seminar being held Friday, January 9, 2009 from 9:00 a.m. to 3:30 p.m. at the Double Tree Guest Suites - 2111 Butterfield Road, Downers Grove, Illinois. The participating firms are all part of the National Workers’ Compensation Defense Network.
Topics include Current Developments and Trends in each State, Factors for Trial versus Settlement, Medicare Reimbursement and Reporting Requirements. Dr. Michael Vender will be the lunch speaker on Getting the Most from an IME.
To register, contact James Reiter at James.reiter@crpjdh.com. If you need hotel reservations, the Double Tree Guest Suites may be reached at 630/971-2000.
Questions may be directed to Bob Maciorowski at 312/627-1522.