Permanent Disability; Apportionment. WCAB, affirming WCJ's finding in a split opinion and approving decision in Kaiser Foundation Hospitals, PSI v. W.C.A.B. (Dragomir-Tremoureaux)), held that applicant's industrial injuries to knees, spine and in form of stroke during cumulative period, and to right knee and in form of stroke, combined to cause 100 percent permanent disability pursuant to conclusive presumption for brain injury in Labor Code 4662(d), and that application of conclusive presumption precluded  apportionment as between applicant's cumulative and specific injuries under LC 4663, 4664 and Benson v. Permanente Medical Group; while finding that defendant did not prove apportionment as required under LC 4663 and 4664, concurring Commissioner indicated that he would allow apportionment, if properly proven, under LC 4663 and 4664(b) for LC 4662 total disability cases, but not apportionment under LC 4664(c). See Sanchez panel decision.

WCAB Procedure; Sealed Documents. WCAB affirmed WCJ's order denying applicant's petition to seal her entire workers' comp record and, alternatively, her request to be granted "Jane Doe" status and to have a line-by-line redaction of her name, address, and other private data from records regarding her injuries, when WCAB found that (1) on balance, public's constitutional right and interest in having access to documents regarding judicial proceedings outweighed applicant's privacy concerns with respect to her medical records, residence address, and social security number, (2) applicant failed to establish specific overriding reasons why her medical records should be sealed, (3) there is no reasonable expectation of privacy regarding injury-related medical reports submitted to WCAB, (4) applicant was not entitled to have her medical records sealed based on her stated concern that she might be assaulted, (5) applicant was not entitled to have medical record sealed based  upon California Public Records Act (PRA),  and (6) applicant was not entitled to have her record sealed to protect her home address or social security number because such information is already protected under LC 138.7 and PRA. See Stathoulis panel decision.

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