“One issue raised by the WCJ in these cases is the misconception that substantial medical evidence is required to determine adequacy of a stipulation. That is not true. Stipulations exist, in part, to obviate the need for evidence.”
(Gaines, supra, at p. 21, citing County of Sacramento v. Workers’ Comp. Appeals Bd. (Weatherall) (2000) 77 Cal.App.4th 1114, 1121.)
“There is no requirement that substantial medical evidence support a stipulation. The only requirement for adequacy review is that sufficient information exists in the formal record to support a WCJ’s decision on adequacy.”
(Gaines, supra, at p. 21.)
“A stipulation is ‘An agreement between opposing counsel . . . ordinarily entered into for the purpose of avoiding delay, trouble, or expense in the conduct of the action,’ (Ballentine, Law Dict. (1930) p. 1235, col. 2) and serves ‘to obviate need for proof or to narrow range of litigable issues’ (Black’s Law Dict. (6th ed. 1990) p. 1415, col. 1) in a legal proceeding.”
(Weatherall, supra, 77 Cal.App.4th at p. 1119, as quoted in Gaines, supra, at p. 21.)
“The parties need only provide relevant information to permit the WCJ to determine adequacy.”
(Gaines, supra, at p. 21.)
“There is no requirement that substantial medical evidence support a stipulation.”
(Gaines, supra, at p. 21.)
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