Sydney Institute of Technology v Cawthorne
[2006] NSWWCCPD 129
•23 June 2006
WORKERS COMPENSATION COMMISSION
DETERMINATION OF APPEAL AGAINST A DECISION OF THE COMMISSION CONSTITUTED BY AN ARBITRATOR
CITATION:Sydney Institute of Technology v Cawthorne NSWWCCPD 129
APPELLANT: Sydney Institute of Technology
RESPONDENT: Donald Selwyn Cawthorne
INSURER:TMF Workers Compensation (NSW) Limited
FILE NUMBER: WCC7291-05
DATE OF ARBITRATOR’S DECISION: 23 August 2005
DATE OF APPEAL DECISION: 23 June 2006
SUBJECT MATTER OF DECISION: Estoppel; ‘Total Incapacity’ and section 36 of the Workers Compensation Act 1987.
PRESIDENTIAL MEMBER: Acting Deputy President Deborah Moore
HEARING:On the papers
REPRESENTATION: Appellant: Rankin & Nathan
Respondent: Rishworth Dodd & Co
ORDERS MADE ON APPEAL: 1. The decision of the Arbitrator dated 23 August 2005 is revoked and the following decision made in its place:
(a) Award in favour of the Sydney Institute of Technology.
(b) No order as to costs.
2. No order as to costs of the appeal.
BACKGROUND TO THE APPEAL
Donald Selwyn Cawthorne (‘Mr Cawthorne’) was employed by the Sydney Institute of Technology (‘the Institute’) as a TAFE Automotive Teacher. On two occasions, 27 January 1997 and 23 October 2000, Mr Cawthorne injured his left shoulder whilst at work. On 11 August 1997, he also injured his right arm, again at work.
In proceedings before the Commission No. 9746-03, he sought payments of weekly compensation following the incident in October 2000. Those proceedings were determined on 23 September 2003. The Arbitrator’s ‘Statement of Reasons’ noted that Mr Cawthorne’s Application:
“Identified the period in dispute as 12 October 2000 to 12 April 2001. Leave was subsequently granted … to amend the Application, nominating the period in dispute as 11 March to 11 August 2001. By consent at a conciliation/arbitration conference held on 21 August 2003, the period in dispute was narrowed to 16 March 2001 to 11 May 2001 (‘the relevant period’)”.
The principal issue in those proceedings was whether or not the ‘incident’ in October 2000 constituted a ‘fresh’ injury such that Mr Cawthorne would be entitled to benefits pursuant to section 36 of the Workers Compensation Act 1987 (‘the 1987 Act’) rather than pursuant to section 37 of that Act.
The Arbitrator determined that the incident on 23 October 2000 did in fact constitute a fresh injury, and issued a determination as follows:
“1. That the Respondent pay the Applicant weekly compensation at the rate of $1011.25 per week for the period 16 March 2001 to 11 May 2001 under section 36 of the Workers Compensation Act 1987.
2. That the Respondent have a credit for any payments made under section 37 of the Workers Compensation Act 1987 during the period 16 March 2001 to 11 May 2001.”
On 18 May 2005, Mr Cawthorne filed a fresh Application in the Commission, the subject of this appeal, seeking weekly benefits compensation from 12 May 2001 to 16 September 2001 as a consequence of the injury on 23 October 2000. The basis of that claim is not entirely clear from the Application, but it appears that Mr Cawthorne took the view that the Arbitrator’s determination in Matter No. 9746-03 was for a period of approximately eight weeks, and that he wished “… to be paid for the balance of the 26 weeks owing to him.”
In its Reply filed on 11 July 2005, the Institute maintained firstly, that it had in fact paid Mr Cawthorne for the period 12 May 2001 to 16 September 2001 (pursuant to section 37 of the 1987 Act) and secondly, that Mr Cawthorne was “… estopped from claiming compensation pursuant to section 36 in respect of the period from 12 May 2001 to 16 September 2001.”
The parties attended a conciliation/arbitration hearing on 17 August 2005. On 23 August 2005, a ‘Certificate of Determination’ with an accompanying ‘Statement of Reasons’ was issued. The determination of the Arbitrator was as follows:
“1. That the Respondent pay the Applicant weekly benefits compensation from 12 May 2001 to 16 September 2001 under section 36 of the Workers Compensation Act 1987 … at the rate of $1,011.25 per week with credit for weekly compensation payments already made.
2. That the Respondent pay the Applicant’s costs as agreed or assessed.”
On 26 September 2005, the Institute filed an ‘Application to Appeal Against Decision of Arbitrator’. Briefly, the Institute submits that the Arbitrator failed to adequately address the estoppel issue and erred in his interpretation of sections 34 and 36 of the 1987 Act such that his decision should be revoked.
In a ‘Notice of Opposition to the Appeal’ filed on 25 October 2005, Mr Cawthorne submits that the Arbitrator’s decision should be confirmed.
LEAVE TO APPEAL
The amount at issue on appeal satisfies the criteria set out in section 352(2) of the Workplace Injury Management and Workers Compensation Act 1998 (‘the 1998 Act’). However, the appeal was out of time as it was not lodged within 28 days of the Arbitrator’s decision as required by section 352(4) of the 1998 Act and Rule 77(1) of the Workers Compensation Commission Rules 2003 (‘the Rules’).
In its submissions seeking an extension of time, the Institute claims that it first received a copy of the ‘Certificate of Determination’ dated 23 August 2005 by facsimile on 9 September 2005 such that time should be extended until 28 days after 9 September 2005.
Rule 77(2) provides that: “For the purposes of sub-rule (1), a decision is made, in respect of a dispute, when the Commission issues a certificate as to the determination of the dispute as required by s294(1) of the 1998 Act.” The Commission file records that a copy of a ‘Certificate of Determination’ was sent to the Institute and its solicitors under cover of a letter dated 23 August 2005. The file also records that a facsimile of that letter was indeed sent to the Institute’s solicitors on 9 September 2005.
However, as I said in Blurlato Pty Limited v Austin [2006] NSWWCCPD 68, “… time must run from the date the Commission issues the decision.” The decision is dated 23 August 2005 such that the appeal is out of time.
Nevertheless, I accept the submission by the Institute that it did not receive the decision until 9 September 2005, confirmed by the Commission file, and in accordance with Rule 77(8), I am satisfied that, in this particular case, a demonstrable and substantial injustice would result to the Institute if leave were not granted. I also note that Mr Cawthorne does not object to the extension of time in his submissions contained in his ‘Notice of Opposition’.
Accordingly, leave to appeal is granted.
ON THE PAPERS REVIEW
The Institute submits that the matter cannot be properly determined ‘on the papers’ principally because, due to technical problems, there is no sound recording of the proceedings before the Arbitrator. It is also submitted that the Arbitrator has taken into account evidence “from the Bar table” given by Mr Cawthorne’s solicitor at the hearing, but the significance of this submission, other than the fact that there is no recording of the proceedings, is not clear.
Mr Cawthorne submits that the matter is suitable for a determination ‘on the papers’.
I have before me all the documents that were before the Arbitrator, including the Arbitrator’s determination in the earlier proceedings, the reasons for decision and the written submissions by both parties on appeal. The parties do not seek to rely upon fresh evidence.
The absence of a transcript, as Deputy President Fleming said in Humphreys v Plaspack Closures Pty Limited [2006] NSWWCCPD 98, (‘Humphreys’ case’) is a “serious shortcoming” but in the circumstances of this particular case, given that the principal issue is that of estoppel, I do not regard that as fatal to my determination of the appeal.
Having regard to the provisions of section 354(6) of the 1998 Act and Practice Direction No. 1, I am satisfied that I have sufficient information to proceed ‘on the papers’ and that this is the appropriate course in the circumstances.
THE ISSUES IN DISPUTE
The principal issue in dispute relates to the Institute’s defence of estoppel, either ‘cause of action’ or ‘issue’ estoppel. The Arbitrator appears to have determined that Mr Cawthorne was not estopped from bringing this claim since he was “mislead” in the previous proceedings in circumstances that amounted to “special circumstances” in accordance with the principles enunciated in Port of Melbourne Authority v Anshun Pty Limited [1981] 147CLR 58 (‘Anshun’s case’) to which I will refer later.
The Institute also submits that the Arbitrator misinterpreted section 34 and 36 of the 1997 Act in that he failed to take into account periods of incapacity between 23 October 2000 and 16 March 2001, but rather identified 16 March 2001 as the “starting date” of the first 26 weeks of incapacity.
SUBMISSIONS, EVIDENCE AND FINDINGS
The Estoppel Issue
Although I do not have the file in the earlier proceedings, it is clear from the Arbitrator’s determination that the claim in matter No. 9746-03 was for weekly benefits pursuant to section 36 for incapacity resulting from an injury on 23 October 2000.
The period claimed, the Arbitrator noted, was “by consent” narrowed to 16 March 2001 to 11 May 2001. The Arbitrator stated: “The Applicant contends that throughout the relevant period [16 March 2001 to 11 May 2001] he was entitled to payment under section 36 of the Workers Compensation Act 1987 … when in fact he was paid at the lesser rate prescribed by section 37.”
The present claim is for weekly benefits for incapacity resulting from the injury on 23 October 2000. Although not specified, the amount claimed, i.e. $1,011.25 is the same as that awarded by the Arbitrator in the earlier proceedings pursuant to section 36 of the 1987 Act, such that the claim can be identified as one for section 36 benefits.
The period claimed commences on 12 May 2001 (the expiration of the period claimed in the earlier proceedings) and ceases on 16 September 2001, being 26 weeks from 16 March 2001, the date the earlier award commenced.
It is clear from a list of payments by the Institute’s insurer attached to the appeal that Mr Cawthorne has been in receipt of weekly benefits for the whole of the period from 12 May 2001 to 16 September 2001 at a rate consistent with section 37 of the 1987 Act, such that it is clear that the issue in dispute, i.e., the rate of weekly benefits, is identical with that in the earlier proceedings.
The question then is whether Mr Cawthorne is estopped from claiming the period 12 May 2001 to 16 September 2001 by virtue of the determination and award in the earlier proceedings.
In paragraph 36 of his ‘Statement of Reasons’, after summarising the evidence of both parties as to what payments had in fact been made to Mr Cawthorne, the Arbitrator stated:
“Therefore the Tribunal finds that the only reliable evidence before it is the oral evidence of the Applicant and that the Award of the previous Arbitrator is the only indication of actual weekly compensation payments by the Respondent at the Applicant’s average weekly earnings of $1011.25 per week. Therefore, the Tribunal finds the Applicant has only received eight weeks weekly compensation payments under s.36 and that he accordingly is entitled to the balance of the first 26 weeks of 18 weeks at that rate.”
In the following paragraph, number 37, the Arbitrator stated as follows:
“Notwithstanding this finding, the Commission now has to consider whether the Applicant is estopped from making the claim at all on the basis of the decision of the High Court of Australia in [Anshun’s case] … and the decision of the Workers Compensation Commission in Quarmby v Motor Traders’ Association of NSW [2005] NSWWCCPD 43 (‘Quarmby’s case’). As stated in Anshun at paragraph 22, ‘where a given matter becomes the subject of litigation in, and of adjudication by, a Court of competent jurisdiction, the Court requires the parties to the litigation to bring forward their whole case, and will not (except under special circumstances) permit the same parties to open the same subject of litigation in respect of matters which might have been brought forward as part of the subject in contest, but which was not brought forward, only because they have, from negligence, inadvertence, or even accident, omitted part of their case. The plea of res judicata applies, except in special cases, not only to points upon which the Court was actually required by the parties to form an opinion and pronounce judgment, but to every point which properly belonged to the subject of the litigation and which the parties, exercising reasonable diligence, might have brought forward at the time.’”
At paragraph 38, the Arbitrator stated:
“The Respondent submits that the Applicant is, based on Anshun, which the Commission accepts it is bound to follow, estopped from bringing a claim again and extending the period to 16 September 2001. The Applicant’s representative submits the Respondent produced a very large bundle of documents at the proceedings before [the previous Arbitrator], and the Applicant could not discern from inspection of the documents what weekly compensation payments had been made by the Respondent … but he was persuaded to consent to amend the period of weekly compensation claimed in the Application in those proceedings, and in respect of which the Arbitrator made her determination. In effect the Applicant claims he was mislead and deceived as a result of misrepresentations by the Respondent’s staff in the previous proceedings and that the Respondent has still not produced any intelligible documentation in these proceedings for a reasonable person to ascertain what weekly compensation payments under s.36 have been made by the Respondent … whilst the Respondent’s submission is superficially compelling, it would clearly render an injustice, and allow the Respondent to profit from its misrepresentation in respect of the payments it claims to have made but of which it has not been able to prove in the current proceedings on any reasonable basis. It is apparent the Respondent has not been able to adduce any sound evidence of having made the first 26 weeks s.36 payments at the Applicant’s average weekly earnings. I do not find the Applicant did not [sic] make the current claim due to negligence, inadvertent [sic] or accident in the previous proceedings under the Anshun principles but rather because of reliance on the Respondent in the last proceedings but this is not determinative. On balance, I find there are special circumstances as set out above which brings this case within the Anshun exception. Therefore, I find the Applicant is not estopped from the current claim.”
Whilst there is no transcript of the evidence, the Arbitrator summarised the evidence of Mr Cawthorne at paragraph 17 of the ‘Statement of Reasons’ as follows:
“The Applicant stated that on 8 May 2001 he had surgery to remove the anchor pin from his left shoulder joint. He has not returned to work at all. He was retired for ill health … on 14 December 2001. He is only being paid weekly compensation at the rate applicable under s.37 and seeks payment under s.36 … he had sought such payment for the period 11 March 2001 to 11 August 2001 in the previous proceedings before [the previous Arbitrator] but was persuaded by officers for the Respondent Employer at the start of the proceedings that the Respondent had paid the Applicant his full 26 weeks entitlement … except for the period 16 March 2001 to 11 May 2001. Accordingly, the Applicant was persuaded to consent to exclude from his claim weekly compensation for the period 12 May 2001 to 11 August 2001.”
This summation suggests that it was the Applicant who gave evidence as to having been “persuaded to consent” to the period 16 March 2001 to 11 May 2001. However, the Institute takes issue with this. It submits that:
“The Arbitrator’s decision … appears to have been significantly influenced by evidence presented ‘from the Bar table’ by [the] solicitor for [Mr Cawthorne]. [The solicitor] gave evidence as to the conduct of the Conciliation Conference in related proceedings before [the previous Arbitrator] on 23 September 2003. The Respondent Worker did not serve a Statement of [the solicitors] intended evidence nor was the Appellant given an opportunity to obtain evidence in response to that of [the solicitor] … the Appellant Employer was entitled to assume in the circumstances that the Arbitrator would not rely upon [the solicitors’] evidence given ‘from the Bar table’ … the Appellant Employer’s alleged conduct in the previous proceedings to which the Worker’s representative discussed from the ‘Bar table’ should not have formed part of the evidence relied upon by the Arbitrator in making his decision or, in the alternative, and at the very least, the Appellant Employer should have been given an opportunity to formally respond in the way of serving statements, calling witnesses etc.”
The Institute then submits that:
“The ‘evidence’ to which the Arbitrator refers in paragraph 38 of the ‘Statement of Reasons’ was in the form of statements made ‘from the Bar table’ during the conciliation phase of the conference on 17 August 2005. The Arbitrator gave no indication that he intended to rely upon [the solicitor’s] statements as evidence. The Appellant submits that the rules of procedural fairness require a party to be given reasonable notice of any application pursuant to Rule 66(4) and given a reasonable opportunity to respond to such application. The Appellant was not given any such notice or afforded any such opportunity in this case.”
Consequently, the Institute submits, “if this evidence is excluded, then it follows … that there was no evidence to support the Arbitrator’s conclusion that special circumstances existed such as to exclude the principle in [Anshun’s case].”
In his ‘Notice of Opposition’, Mr Cawthorne submits that “submissions were made from the Bar table by [Mr Cawthorne’s solicitor] … for the Respondent Worker. Submissions were made from the Bar table and discussions were made during the mediation phase before the Arbitrator”, and that “the Arbitrator has properly and fully considered the issue of estoppel and has found against the Appellant.”
It is Mr Cawthorne’s further submission that even if the Institute’s conduct in the earlier hearing is ignored, its conduct in the present hearing “… is clearly unconscionable in that it did not obey the direction of the Arbitrator to produce documentation required … prior to the hearing …”
Did the Arbitrator in fact “properly and fully” consider the issue of estoppel? There is no question that he made reference to the Anshun estoppel (and Quarmby’s case) in paragraph 37. The real question is whether the evidence supported his conclusion.
Estoppel has been considered by the Commission in a number of recent decisions including Humphrey’s case, Davies v Bisaxa Pty Limited [2006] NSWWCCPD 103 and Coles Supermarkets Pty Limited v Czipo [2006] NSWWCCPD 112.
Res Judicata and its relevance to workers compensation cases was the subject of detailed analysis by Deputy President Lansdowne in Quarmby’s case referred to earlier. At paragraph 34, she stated:
“The authorities established that there are three types of incidences in which a party may be estopped from raising an issue, claim, or defence in subsequent proceedings because, in broad terms, of the principle of res judicata. These are as follows:
(1) Cause of action estoppel (res judicata in the narrow sense)
(2) Issue estoppel.
(3) Anshun estoppel.”
The Institute submits that Mr Cawthorne’s claim falls into the category of issue estoppel defined by Dixon J in Blair v Curran [1939] 62 CLR 462 (as quoted by Priestley JA in Lambidis v Commissioner of Police [1995] 12 NSWCCR 225 at 240) as follows: “… for the purpose of some other claim or cause of action, a state of fact or law is alleged or denied, the existence of which is a matter necessarily decided by the prior judgment, decree or order”.
In other words, the Institute submits that the claim for weekly benefits beyond 11 May 2001, was an issue or fact decided in the earlier proceedings. Mr Cawthorne had an opportunity to pursue his claim for a period beyond which he consented to have determined by the Arbitrator. As is pointed out by Mr Cawthorne in his submissions:
“It is clear evidence before the Arbitrator that the injured worker underwent major shoulder surgery on 8 March 2001 [sic] and was severely incapacitated thereafter and indeed never returned to work and was medically retired in December 2001.”
In those circumstances, one is left to wonder why Mr Cawthorne elected to confine his claim to the period 16 March 2001 to 11 May 2001.
As Deputy President Fleming said in Humphrey’s case:
“It is clear law that, in certain circumstances, an award of the Compensation Court will create an issue estoppel in subsequent proceedings, i.e. where the same question has been decided, the decision was final and the parties are the same …”
There is no question in this matter that proceedings before the Arbitrator in matter No. 9746-03 were determined by an award of the Commission, not simply an agreement between the parties or ‘consent award’. Those proceedings were between the same parties and the Arbitrator’s decision was final and binding.
The thrust of Mr Cawthorne’s submissions is that he was “mislead” by the Institute which constitutes an exception or “special circumstances”, within the principles set out in Anshun’s case.
Briefly put, the Anshun estoppel differs from res judicata and issue estoppel in that it relates not to what was determined by the previous proceedings but what could have been. As Deputy President Lansdowne said in Quarmby’s case: “It arises where a party seeks in subsequent proceedings to raise a defence (and possibly a claim) that could have been raised in earlier proceedings between the same parties, but was not. In certain circumstances, the party may be estopped from raising that defence or claim in later proceedings.”
The Arbitrator quoted the principle in Anshun’s case in paragraph 37 of his ‘Statement of Reasons’, to which I have referred earlier.
Even if Mr Cawthorne’s evidence was to the effect that he was “mislead” in the earlier proceedings, there is no evidence before the Arbitrator, as he put it, of “misrepresentations by the Respondent’s staff in the previous proceedings.” It is this alleged ‘misrepresentation’ that the Arbitrator appears to have regarded as a ‘special circumstance’ on the Anshun principles which would “… render an injustice and allow the Respondent to profit from its misrepresentation in respect of the payments it claims to have made.”
Mr Cawthorne’s submission that the Institute’s conduct in failing to produce certain documentation in the current proceedings was “clearly unconscionable” is irrelevant to the determination of the issue of estoppel which must of course examine the conduct in the earlier proceedings.
It is this aspect of the Arbitrator’s determination which in my view is flawed. His reasons all reflect what he understood to be the “evidence” in the earlier proceedings. But that is not the principal issue to be determined. He was required to consider whether the claim in the current proceedings was the same subject of litigation in the earlier proceedings, the extent of which may have been brought forward but was not.
It seems to me, as the Institute points out in its submissions, that if Mr Cawthorne was dissatisfied with the Arbitrator’s determination in the earlier proceedings, “… the proper course was to lodge an Appeal pursuant to s.352 rather than waiting approximately 18 months before commencing fresh proceedings in the Workers Compensation Commission.”
Moreover, as Burke J as he then was said in Almario v Carrington Constructions Pty Limited [1996] NSWCCR 37:
“A worker can be, and almost invariably is, bound by the acts of his lawyers acting within their ostensible authority … similarly, a worker can be, and almost invariably is, bound by his own acts, particularly those done on the advice of his lawyers.”
Similarly, as the Institute points out in its submissions:
“If the Arbitrator has applied, in effect, an estoppel based on unconscionability to prevent the Appellant from relying upon the Anshun principle, the Appellant submits that there was no logically probative evidence before the Arbitrator to suggest that the Appellant acted in any way improperly or unconscionably. Even if [Mr Cawthorne’s solicitor’s] statements are accepted the Appellant’s alleged conduct, namely overwhelming the Worker with a very large volume of documents at the arbitration hearing on 23 September 2003, does not amount to unconscionable conduct. As the High Court determined in Commercial Bank of Australia v Armardio [1983] 151 CLR 447, the essential ingredient in an estoppel based on unconscionability is an inequality in the bargaining position between the two parties to a transaction. At the arbitration hearing on 23 September 2003, both parties were represented by legal practitioners. Both parties were in the same bargaining position …”.
This is certainly a compelling submission. The issue for the Arbitrator to determine was whether or not Mr Cawthorne was estopped from bringing the current claim by reference to the nature of the earlier proceedings. Those proceedings, as I have said, are clearly between the same parties and canvass identical issues.
The Arbitrator’s reasoning that Mr Cawthorne was not estopped from bringing a claim essentially because of “misrepresentations” by the Institute in the earlier proceedings, was unsupported by probative evidence and failed to have regard to the binding nature of the earlier award in circumstances where Mr Cawthorne, ably represented by an experienced practitioner consented, before the Arbitrator’s ultimate determination, to limit the period of his claim.
Regardless of whether the Institute in these proceedings had failed to produce “any intelligible documentation” relating to the claim for section 36 benefits, Mr Cawthorne was estopped from bringing these proceedings. If the documentary evidence in the earlier proceedings was similarly unintelligible or unsatisfactory for the purpose of determining the appropriate award, that was an issue which ought properly to have been brought forward in those proceedings.
The ‘Section 36 Issue’
As to the Institute’s submission that the Arbitrator erred in his interpretation of section 34 and 36 of the 1987 Act, since he failed to take into account periods of incapacity following the injury on 22 October 2000 prior to 16 March 2001, the Arbitrator’s award should be revoked for the reasons set out in the preceding paragraphs such that I do not consider it necessary to determine that issue.
Nevertheless, it should be pointed out that there was no evidence before the Arbitrator to disturb the previous Arbitrator’s Award which effectively concluded that any period of total incapacity pursuant to the provisions of section 36 of the 1987 Act concluded on 11 May 2001. There was merely Mr Cawthorne’s assertion that he was in theory “entitled” to payments pursuant to section 36 for a period of 26 weeks.
CONCLUSION
The Arbitrator erred in finding that Mr Cawthorne was not estopped from bringing these proceedings. The decision of the Commission in Matter No. 9746-03 constituted a binding award on the parties.
DECISION
The decision of the Arbitrator dated 23 August 2005 is revoked and the following decision made in its place:
(a) Award in favour of the Sydney Institute of Technology.
COSTS
The Institute submits that Mr Cawthorne should pay its costs both of the proceedings before the Arbitrator and of the appeal, principally on the ground that the proceedings, even at first instance, lacked proper justification.
Section 341(2) of the 1998 Act provides that: “The Commission has full power to determine by whom, to whom and to what extent costs are to be paid.”
Section 341(4) provides that: “The Commission may not order the payment of costs by a claimant unless the Commission is satisfied that the claim was frivolous or vexatious, fraudulent or made without proper justification”.
Whilst I agree to an extent with the Institute’s submission on this issue, I am not satisfied that I have sufficient information to conclude that the proceedings entirely lacked “proper” justification. In the circumstances, I make no order as to costs of either the proceedings before the Arbitrator or of the appeal.
Deborah Moore
Acting Deputy President
23 June 2006
I CERTIFY THAT THIS IS A TRUE AND ACCURATE RECORD OF THE REASONS FOR DECISION OF DEBORAH MOORE, ACTING DEPUTY PRESIDENT OF THE WORKERS COMPENSATION COMMISSION.
ASSOCIATE
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