Georgia Law Blog

Attorneys can be very resistant to change. Ebenezer Scrooge, in A Christmas Carol, was visited by the Ghost of Christmas Past. Ebenezer learned from this experience the necessity to change his past ways to ensure a happier and brighter future.

I am constantly amazed by fellow lawyers' reactions when I tell them I strive to have as paperless an office as possible. Some are skeptical. Some say it is not possible. Others tell me they are too old fashioned for that sort of thing. Some call me later for advice and help in implementing their own paperless systems. I am here to tell you that it is possible. You too can implement a paperless system in your office, whether your firm has 500 lawyers or you are a sole practitioner. Even though I am a sole practitioner on the outskirts of a major city with limited resources, my system has worked very well for our office.

A good starting point is to buy a good scanner. Personally, we use a Canon ImageRunner 5000-series all-in-one machine. While this machine is quite large and expensive if purchased new, I purchased one used for substantially less than the new price. Another alternative that many of my friends use is the Scan Snap series from Fujitsu. Whatever hardware you choose, be sure to carefully plan a system for scanning, cataloging, and electronically filing your documents . We use a simple process whereby all scanned documents are "dumped" into a common folder in our database. From there, they are named and electronically filed in their respective folders.

I also use a Canon IP90 portable printer that fits nicely into my briefcase. Of course, I can print documents with a few clicks when I head to court. November and December were busy months for me. I handled several hearings before the State Board of Workers' Compensation. My trial exhibits were created with ease with the Canon machine. I also toted my small portable printer to court where I printed additional documents I needed. Going paperless has increased my capacity to produce work product.

Posted by Jack E. Clay | Permalink | Email This Post

Posted In: Law Firm Technology , Our Law Firm Serving Atlanta & All of Georgia

Bookmark:

I have been using Picasa for several years to view photographs. Lately, I have been reviewing our photographs in past and present case files. For those of you who do not use Picasa, it can be wonderful tool for workers' compensation lawyers, personal injury attorneys, or any other specialty for that matter. For example, it scanned my current and some past client files and found over 3,000 photographs from my years of practice. I was surprised at the number and variation of pictures we have including:

- photos from auto accident scenes;
- wrecked cars and truck;
- pictures of injuries;
- photographs of surgical procedures;
- scars;
- photos of Georgia Panels of Physicians in our workers' compensation cases;
- photographs of x-rays (in addition to original x-ray films);
- pictures of clients' homes after modifications in catastrophic workers' compensation and injury cases;
- clients performing tasks such as sitting, standing, kneeling walking up and down stairs, etc. to show limitations due to injuries;
- pictures of dangerous conditions at construction sites and factories where my clients have been injured;
- photos of parties to case, including defendants;
- and photos of books and other items used in depositions. For example, I deposed a doctor once and saw a medical book authored by him on the coffee table in the lobby. I snapped a quick photo and used it during my direct examination.

Picasa is a great way to view and organize these photographs. We have also started reviewing documents in .tiff format using Picasa. TIF is a file format now owned by Adobe that has not been updated since 1992. One problem I have noticed, however, happens when you view multi-page documents in Picasa. There does not seem to be a way to view multiple pages. Essentially, Picasa shows the first page of the document. Perhaps there is a way to resolve this situation.

While my paperless law office scans and views documents in .pdf format, whenever possible, many courts use .tiff format. Some use several formats. For example, the State Board of Workers' Compensation ICMS seems to use. tiff as a default for scanning incoming "paper documents", but uses .pdf for many documents created by attorneys. Federal courts throughout the country use the .pdf format for documents on its Pacer / ECF systems. In Georgia, we have a group called the Georgia Courts Automation Commission. Sadly, however, we have yet to implement a uniform electronic filing and case system throughout our state court system here in Georgia. I am hopeful that this will happen over the next ten years.

Posted by Jack E. Clay | Permalink | Email This Post

Posted In: Law Firm Technology , Our Law Firm Serving Atlanta & All of Georgia

Bookmark:

Today, Angel Chupin, a 66 year-old construction worker, was killed and 18 others were injured when a tragic construction accident occurred on a construction site at the Atlanta Botanical Gardens. The workers were completing construction on a dramatic walkway through the Gardens when it collapsed, sending workers falling to the ground. Some fell as far as 40 feet. The injured workers were taken to Grady Memorial Hospital with various injuries.

I wrote some time ago about the role of OSHA in workers' compensation cases. I expect that a thorough investigation by OSHA will take place after this tragic accident.

I have also written extensively about how, often, workers are barred from suing their employer and co-employees when their injuries fall-under Georgia's workers' compensation laws. However, there can be third parties who bear responsibility who can be sued in these instances. My observation is that this issue has been the hot topic of Georgia's appellate courts this year. There have been numerous decisions this year about the interplay between the Exclusive Remedy Provision, which limits workers' ability to file a civil suit, and tort law. My discussion of these cases can be found here

Our office handles construction accident cases throughout Georgia. If you or a loved one have been injured working at a construction site, please call us anytime for a free consultation about your rights.

Posted by Jack E. Clay | Permalink | Email This Post

Posted In: Death Cases , Our Law Firm Serving Atlanta & All of Georgia

Bookmark:

On July 10, 2008 the Georgia Court of Appeals decided the case of Keystone Auto v. Hall, 292 Ga. App. 645 (2008). This is a case in which an employee died on the job after having what appears to have been a heart attack. Heart cases are treated especially by Georgia Workers' Compensation laws. O.C.G.A. § 34-9-1 (4) requires an employer in a heart case to prove by a preponderance of the evidence of the conditions were attributable to the performance of usual work of employment before they can be considered an injury.

Perhaps this case is about the heart attack that wasn't. Allow me to explain. In this case, there seems to have been a failure of the doctors to reach a consensus of the exact cause of the claimant's death. Based upon the lack of clarity, the Administrative Law Judge held that the employer failed to overcome a presumption by demonstrating that the claimant's death did not arise out of his employment. Furthermore, the ALJ noted that this claim would not be compensable absent the unexplained death presumption found in Georgia Workers' Compensation Law.

This case is positive for injured workers in Georgia as it upholds the unexplained death presumption as found in Zamora v. Coffee General Hospital, 162 Ga. App. 82 (1982). An employer must rebut a presumption that an employee's death arose out of and in the course of employment if he or she was found dead at the place or he or she could have reasonably been expected to be in the performance of his or her job duties and the death was unexplained. Although in Keystone Auto v. Hall the doctors believed that the claimant had a heart attack, the medical evidence was not definitive as to the cause of death.

This is a good legal decision in that it reinforces the notion that the burden is in the employer to disprove that an employee's on-the-job death is compensable when such death is due to unexplained reasons. In workers' compensation law and other areas of law, either side of a dispute may bear the burden of proof in a case. This presumption can be powerful in close cases where the evidence is not clear as in this case. It is also important to note that in workers' compensation cases, the claimant bears the burden of proof most of the time.

If a friend or loved one has died in an on-the-job accident and there are lingering questions, please call our office for a free consultation. We will do our best to answer your questions in a professional and dignified manner and discuss death benefits under the workers' compensation system.

Posted by Jack E. Clay | Permalink | Email This Post

Posted In: Georgia Workers' Compensation Case Update

Bookmark:

On October 17, 2008 the Georgia Court of Appeals decided the case of DeKalb Board of Education v. Singleton, 2008 Ga. App. Lexis 1116. This case involved a psychological injury under O.C.G.A. § 34-9-105(c)(5). The facts of this case are fairly straightforward. A school bus driver arrived for work and found that there was some white powder in her bus. She proceeded to clean the white powder with paper towels and hand sanitizers provided by the employer. After driving her bus for 30 to 45 minutes, she suffered an asthma attack. The employee had previously been diagnosed with asthma and this attack was an aggravation of a pre-existing condition.

The difficulty in this case concerned the employee's claims for a psychological injury. Under Georgia workers' compensation law, in order for a psychological injury to be compensable, it must satisfy two conditions:
(1) It must arise out of an accident at which the compensable physical injury was sustained; and
(2) While the physical injury need not be the precipitating cause of the psychological condition or problems, at a minimum the physical injury must contribute to the continuation of the psychological trauma.

In this case, the Administrative Law Judge found the employee's psychological claim compensable. The State Board of Workers' Compensation affirmed this decision as did the Superior Court. On appeal, the Georgia Court of Appeals found that the Superior Court acted properly.

This is a good case for claimants. Many claimants suffer a psychological fallout from severe on the job injuries. While in this case the claimant suffered psychological distress and anxiety after suffering an asthma attack while driving a school bus, there are more serious injuries that clearly justify psychological care under workers' compensation. It is easy to see why employees who suffer severe injuries may also suffer psychological problems. Whether these psychological injuries while diagnosed as such using such terms as anxiety and depression, the damage can be real and long-lasting. It is also interesting that Georgia requires a physical injury in order to have a compensable psychological claim. This precludes, for example, workers who are under stress from filing workers' compensation cases, at least in Georgia.

Posted by Jack E. Clay | Permalink | Email This Post

Posted In: Georgia Workers' Compensation Case Update

Bookmark:

On July 10, 2008 the Georgia Court of Appeals decided the case of McLendon v. Advertising That Works, 2008 Ga. App. Lexis 833. This case involved several dates of accidents and several and numerous WC-14 notices of claims. The attorney for the claimant dismissed with prejudice several WC-14 claims at the hearing. The appeal only concerns one date of accident of June 8, 2004. In this case, the WC-14 that is the subject of this appeal referenced the wrong date of accident. While ordinarily this is not fatal to a claim, the claimant did not show on the record that his claim arose out of a single occurrence or that he had simply been mistaken as to the date of injury.

The claimant also raised the argument that an amended WC-14 was filed which should relate back to the original WC-14 and correct the date of accident issue. However, due to the fact that there are numerous dates of injury in this case and lack of a clear record on appeal, the court of appeals upheld the decision from the State Board of Workers’ Compensation under the any evidence standard.

An issue in this case that I encounter very often concerns the applicability of the Civil Practice Act to Georgia’s workers’ compensation laws. It is my opinion that Georgia’s Civil Practice Act only applies to discovery issues in workers’ compensation cases under O.C.G.A. § 34 9 102(d)(1). I believe the Court of Appeals’ analysis regarding the effect of the Civil Practice Act is correct. Many attorneys attempt to relate provisions of the Civil Practice Act that have nothing to do with discovery to workers' compensation cases.

I believe that this case has potentially negative ramifications for injured workers in Georgia if it is carried too far. First, claimants and their counsel should be certain to explain on the record if there is a discrepancy between the date of injury referenced in a WC-14 and the date of injury referenced at a hearing. I believe in the McLendon case, a simple explanation would have made things a lot clearer. Furthermore, there seems to be more ambiguity in this case as there were numerous dates of injury which were dismissed with prejudice at the hearing by the attorney for the claimant. This considerably muddied the waters.

The crux of the problem in this case is as follows. The worker was injured on June 8, 2004. When he hired his attorney, a WC-14 was filed on March 14, 2005 which is clearly within the one year statute of limitations applicable to the facts of this case under O.C.G.A. § 34-9-82. The problem lies in the fact that this WC-14 listed an accident date of July 16, 2004 and not the June 8, 2004 date of accident. Later, on July 12, 2005, the attorney filed a claim to correct the date of accident from July 16, 2004 to June 8, 2004. I believe the court of appeals in this case felt bound to rule against the claimant for the reasons discussed previously as well as the fact that the Claimant referred to medical records and a transcript which were not part of the appellate record. The Court of Appeals commented on this and stated that it is the responsibility of the parties to ensure that the documents relative to the disposition of an appeal be duly filed with the clerk of the Court of Appeals. In this case, I believe the result may have been different if the judges on the Court of Appeals had the hearing transcript and medical records in their possession.

This is fact-intensive decision based on very convoluted facts. I had to re-read the opinion several times to get a clear understanding of what happened. The weight this case should carry as binding case law should be minimal, if any. This is primarily due to the fact that the Court of Appeals did not have a complete record before it in deciding this appeal.

Posted by Jack E. Clay | Permalink | Email This Post

Posted In: Georgia Workers' Compensation Case Update

Bookmark:

On November 14, 2008, the Georgia Court of Appeals decided the case of Holder v. City of Atlanta, 2008 Ga. App. Lexis 1236. This case involved enforcement of a settlement agreement at the Superior Court level. This case emphasized the point that, under O.C.G.A. § 34-9-105(b), if a Superior Court does not hear (or continue hearing on) an appeal from a decision by the Board within 60 days from the date of docketing, the Board’s decision “shall be considered affirmed by operational law.” Accordingly, the decision of the State Board of Workers’ Compensation approving the settlement agreement was affirmed by operation of law as the Superior Court lost jurisdiction to enter any order at a later date.

This case emphasizes the importance for both attorneys for claimants and attorneys for employer/insurers to carefully study and follow the rules for appealing cases in Georgia. It has been my opinion for some time that the workers’ compensation appeals process in Georgia should be streamlined by eliminating the Superior Court’s role in the appellate process. Workers’ compensation cases are heard by Administrative Law Judges throughout the state. After an Award is issued, the aggrieved party may file an appeal to the full Board, a three judge panel, which constitutes the State Board of Workers’ Compensation. Thereafter, an appeal may be made to the Superior Court of the Judicial District covering the county in which the original accident occurred. Next, there is the opportunity for a discretionary appeal to the Georgia Court of Appeals. Finally, there is a possibility of a discretionary appeal to the Georgia Supreme Court.

While the law would have to be changed, it would greatly streamline the system in workers’ compensation cases if cases were directly appealable from the State Board of Workers’ Compensation to the Georgia Court of Appeals. I have found in my experience that many superior court judges do not deal regularly with workers’ compensation cases. Moreover, many have to do extensive research regarding workers’ compensation law and may not understand or appreciate the nuances of this narrow area of practice.

If you or a loved one has been injured in Douglasville, Douglas County, GA, or throughout Georgia, please feel free to call our office for a free and confidential phone consultation.

Posted by Jack E. Clay | Permalink | Email This Post

Posted In: Georgia Workers' Compensation Case Update

Bookmark:

On August 15, 2008 the Georgia Court of Appeals decided the case of Taylor v. Peachbelt Properties, Inc., 2008 Ga. App. Lexis 932. This case involved the enforcement of a judgment in the Superior Court after a workers’ compensation case was decided. In this case, the claimant filed a workers’ compensation case against an uninsured employer. While many employers in Georgia are uninsured, the law is clear that employers who meet certain requirements must carry workers’ compensation insurance. The remedy is a personal responsibility of the “owners” of the corporation, despite the fact that the business entity may be a corporation or limited liability company.

In this case, the original workers’ compensation Award was established in 1995. This case involved the renewal of this original judgment in the Superior Court many years later. I am including an article on this case as many workers’ compensation claimants’ attorneys handle cases involving uninsured employers. This case emphasized the importance of following all procedural protocol after a judgment is obtained in the Superior Court, especially for claimants’ attorneys who have judgments against employers. In this case, a motion to amend was filed after the proper time (i.e. not in the same term of court as defined by Code in each Judicial District throughout Georgia) in the Superior Court. Thus, the Superior Court had no authority to amend its prior judgment.

Workers’ compensation attorneys are cautioned to carefully review the legal requirements concerning judgments if they pursue such judgments against uninsured employers. Another reasonable suggestion would be for the claimant’s counsel to consult with or associate with an attorney who specializes in post-judgment collections.

Posted by Jack E. Clay | Permalink | Email This Post

Posted In: Georgia Workers' Compensation Case Update

Bookmark:

On June 18, 2008 the Georgia Court of Appeals decided the case of Parham v. Swift Transportation Company, Inc., 292 Ga. App. 53 (2008). This case involved two primary issues important to injured workers in Georgia. First, this case emphasized the fact that the testimony of an injured worker is very important, perhaps as important as or more important than the testimony of a medical expert. This case re emphasized that, while medical questions are to be established by physicians as expert witnesses and not by a layman, a physician may testify as to his or her opinion as to the cause of the injury. However, the ultimate decision as to whether or not an injury is related to a work accident is a legal decision. Thus, the claimant’s credibility and testimony is very important.

The second issue in this case is medical bills that were unpaid by the employer/insurer. The Court of Appeals affirmed the State Board of Workers’ Compensation decision that medical bills of $7,195.00 that the injured worker suffered after having a heat stroke should be paid.

This case is important to the injured worker. In many cases, the doctor’s opinions may vary greatly as to the cause of a particular medical condition. In most workers’ compensation cases, medical evidence is critical. Many doctors are known to be friendlier to the side of the employer/insurer while other doctors are known to be friendlier to injured claimants. I am certain that the Administrative Law Judges are keenly aware of this situation. One detail in this case that I do not want to overlook is the credibility of the claimant. The Georgia Court of Appeals noted that the ALJ found that, “after personally observing the employee’s demeanor and testimony, I (Administrative Law Judge) find the employee very credible.”

As a claimant’s attorney handling workers’ compensation cases throughout Georgia, I believe that claimant’s credibility is extremely important to the success of any case. In Parham, it appears to have made all the difference in the world as the medical evidence did not appear to be 100% clear as to whether or not the injured worker’s heat stroke was a result of the on-the-job injury.

If you are an attorney reviewing this article and would like to discuss a potential workers' compensation referral with our office, please contact Jack Clay anytime. While our office is located in Douglasville, which is just outside Atlanta, Mr. Clay handles cases state-wide and has tried workers' compensation cases throughout Georgia.

Posted by Jack E. Clay | Permalink | Email This Post

Posted In: Georgia Workers' Compensation Case Update

Bookmark:

On October 17, 2008, the Georgia Court of Appeals decided the case of Clarke v. Country Home Bakers, 2008 Ga. App. Lexis 1109. This case involved a simple issue of whether an inmate who suffered serious injuries while working at bakery should recover workers’ compensation benefits. In this case, the inmate was not allowed to recover workers’ compensation benefits in the form of medical care and income benefits due to the fact that he was working for a private employer through the Department of Corrections work release program. Thus, he was not an employee under the Workers' Compensation Act.

There is a law in Georgia that excludes, from workers' compensation coverage, inmates or persons participating in a work release program, community service program, or similar program as part of the punishment for violation of a state’s law

O.C.G.A. 34 9 1(2) states, in pertinent part, that, "Inmates or persons participating in a work release program, community service program, or similar program as part of the punishment for violation of a municipal ordinance pursuant to Code Section 36-32-5 or a county ordinance or a state law shall not be deemed to be an employee while participating in work or training or while going to and from the work site or training site, unless such inmate or person is employed for private gain in violation of Code Section 42-1-5 or Code Section 42-8-70 or unless the municipality or county had voluntarily established a policy, on or before January 1, 1993, to provide workers' compensation benefits to such individuals."

In this case, the inmate’s work was voluntary. The Claimant's argument was that because his work was voluntary, it was not "part of the punishment" as stated in the statute in question. The Court of Appeals affirmed the decision that because the work release program was “part of his punishment”, the claimant was not an employee under the law for workers’ compensation purposes.

While this case presents potentially negative implications for injured workers, this case would only affect the rather rare instance in which inmates in work release programs are injured. I am not sure whether this decision or the law upon which it is based make a whole lot of sense in all cases. For example, many private companies benefit from prison labor or work release programs. This case and the statute discussed above seem to insulate such employers from workers' compensation claims when people get hurt on-the-job. While, perhaps, this "protection" is an incentive to hire, train, and help people in the justice system, this could adversely affect a worker who is severely injured in a work accident.

Posted by Jack E. Clay | Permalink | Email This Post

Posted In: Georgia Workers' Compensation Case Update

Bookmark:

On June 27, 2008 the Georgia Court of Appeals decided the case of United Grocery Outlet et al v. Bennett, 2008 Ga. App. Lexis 772. In this case, a claimant was paid workers’ compensation benefits in the form of temporary total disability benefits. The employer stopped paying the benefits and failed to file a Form WC 2. More than two years lapsed from the last date the claimant was paid temporary total disability benefits until the time she sought additional income benefits. As I have previously discussed in other articles, the statutes of limitations under Georgia workers’ compensation law can be confusing and need to be carefully analyzed.

O.C.G.A. § 34-9-104(b) states that a claimant must file a claim for additional weekly income benefits within two years from the last payment of such income benefits if the worker is seeking additional weekly benefits. The Court of Appeals was very clear in this case in holding that, despite the fact that a Form WC 2 was not filed telling the employee that her income benefits were suspended, she was barred by the statute of limitations.

This decision is bad for claimants. This case represents a philosophy on behalf of the Georgia Court of Appeals to strictly adhere to statutes of limitation in the workers’ compensation arena. It is also interesting to note that the law requires that an employer file a Form WC¬ 2 when commencing or suspending weekly income benefits. However, the Court of Appeals rationalized that this is not a reason to extend the statute of limitations. In sum, the Court of Appeals found that, “…we find no grounds for delaying or extending the statute of limitations based upon such non compliance.” I believe that the filing of a Form WC-2 and notice to the employee is essential in workers’ compensation cases. Injured workers should be informed that their weekly workers’ compensation checks are being suspended and the reason behind the suspension. This case is also bad for the injured worker as a person hurt on workers’ compensation can get his or her weekly benefits cut off, continue to receive medical care paid by the Employer/Insurer, and be time-barred if they later seek weekly benefits due to a worsening in their medical condition or an economic condition. Next, this case sub-verses what is commonly referred to as the notice requirement, depriving an employee of notice of suspension of income benefits so they may make a decision as to what rights they need to pursue.

Injured workers, untrained in the nuisances of the law, may not understand the significance of certain types of benefits. For example, many mix-up temporary total disability benefits (TTD) with permanent partial disability benefits (PPD). The Georgia Supreme Court also denied cert in this case recently.

If you or a friend has been injured at work and face confusion about what rights to which you are entitled, please call my office for a free no-obligation consultation.

Posted by Jack E. Clay | Permalink | Email This Post

Posted In: Georgia Workers' Compensation Case Update

Bookmark:

On June 26, 2008, the Georgia Court of Appeals decided the case of Freeman v. Brandau et. al, 2008 Ga. App. Lexis 760. This case stemmed from the tragic events that took place at the Fulton County Courthouse in which several people were murdered. Specifically, Julie Ann Brandau was Judge Barnes' court reporter in Fulton County Superior Court. Her estate sued the Fulton County Sheriff Myron Freeman and eight employees of the Sheriff's Department for negligence. Freeman and Fulton County argued that Ms. Brandau, at the time of her death, was a co employee of Fulton County Sheriff Myron Freeman. Thus, a motion to dismiss was filed citing the exclusive remedy provision of Georgia's Worker's Compensation Act.

The primary reason that many attorneys and plaintiffs want to forego the workers' compensation system and, instead, file a civil lawsuit is that the damages in a personal injury or wrongful death claim tend to be substantially higher than settlements in workers' compensation cases. In this appeal, the Court of Appeals held that the Sheriff of Fulton County was not immune from suit as a co-employee of the decedent. Thus, the case was allowed to go forward. This case broadens the rights of plaintiffs suing co-employees in the narrow situation where the co-employee may be an elected official. However, the law cited in this case allows elected officials to be exempt, and therefor immune from lawsuits, if the municipality takes certain action. In this case, key evidence focused on the lack of action by Fulton County that may have likely precluded this lawsuit.

If you or a loved one has been injured while working in Atlanta, Fulton County, or anywhere throughout Georgia, please feel free to contact our office for a free consultation.

Posted by Jack E. Clay | Permalink | Email This Post

Posted In: Georgia Workers' Compensation Case Update

Bookmark:

On July 8, 2008, the Georgia Court of Appeals decided the case of Rheem Manufacturing Company v. Butts, 2008 Ga. App. Lexis 814. In this case, an injured employee filed a medical malpractice lawsuit against a physician employed by his employer. The claimant had a knee injury and sought treatment from a physician who was employed by an on-site medical clinic at Rheem Manufacturing Company. The medical malpractice lawsuit was based upon the failure to diagnose cancer.

The Georgia Court of Appeals held that the employee could not maintain the personal injury lawsuit under the exclusive remedy doctrine found in Georgia workers’ compensation law. The Court reasoned that the physician was a co-employee of the claimant, Mr. Butts. Also, the Court of Appeals noted that O.C.G.A. § 34-9-203(b) precludes damages for malpractice by a physician or surgeon furnished by an employer at an on-site clinic.

This has been a popular theme in recent workers’ compensation case law: that claimants have tried to sue employers, co-employees and third-parties for personal injury, medical malpractice and wrongful death. Recently, we have seen expansion in some areas and limiting and contraction in others. This case again reemphasizes the fact that an injured worker cannot generally sue a co-employee for torts committed by the co-employee under Georgia workers’ compensation law.

If you have been injured at work and have questions about whether you can file a lawsuit for personal injury or have questions about a workers' compensation benefits such as weekly benefits and medical care, please contact our office for a free telephone consultation.

Posted by Jack E. Clay | Permalink | Email This Post

Posted In: Georgia Workers' Compensation Case Update

Bookmark: