California, United States of America
The following excerpt is from Zarate v. Workers' Comp. Appeals Bd., 160 Cal.Rptr. 408, 99 Cal.App.3d 598 (Cal. App. 1979):
The WCAB lead opinion also noted that in Adams v. Workers' Comp. Appeals Bd. (1977) 18 Cal.3d 226, 133 Cal.Rptr. 517, 555 P.2d 303, the court held that medical-legal expense is "compensation" as defined in the workers' compensation laws and thus to award medical-legal expenses here would be to pay compensation to someone not an "employee."
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