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Zenith Ins. v. WCAB
The Workers Compensation Appeals Board (Board) awarded permanent disability benefits to applicant Catherine Watts using the 1997 permanent disability rating schedule that was in effect at the time of her work-related injury in 2004. Zenith Insurance Company (Zenith), the workers compensation carrier for Wattss employer, petitioned for a writ of review, arguing that the Board should have applied the new permanent disability rating schedule that went into effect on January 1, 2005. (Labor Code, 4660, subdivision (d).) Court agree and annul that portion of the award.

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