Employee Personnel File

Initial Request 11/2/2012

Mike Christian Civil Attorney Appears at WCAB Hearing Incomplete Records on 10/03/14

2 years

Labor Code Section 1198.5

Inspections must be allowed at reasonable times and intervals, but not later than 30 calendar days from the date the employer receives a written request. Upon a written request from a current or former employee, or a representative, the employer shall provide a copy of the personnel records, at a charge not to exceed the actual cost of reproduction, not less than 30 calendar days from the date the employer receives the request.

Employers are required to give an employee or job applicant, upon request, a copy of any instrument that the employee or applicant has signed relating to the obtaining or holding of employment. Labor Code Section 432

Employers are required to permit current and former employees to inspect or copy payroll records pertaining to that current or former employee. Labor Code Section 226(b) An employer who receives a written or oral request from a current or former employee to inspect or copy his or her payroll records shall comply with the request as soon as practicable, but no later than 21 calendar days from the date of the request. Failure by an employer to permit a current or former employee to inspect or copy his or her payroll records within the 21 calendar day period entitles the current or former employee to recover a penalty from the employer in a civil action before a court of competent jurisdiction. Labor Code Section 226, subdivisions (c) and (f)

Employers are required to keep accurate payroll records on each employee, and such records must be made readily available for inspection by the employee upon reasonable request. Additionally, when a piece rate or incentive plan, such as a commission plan, is in operation, piece rates or an explanation of the incentive plan formula shall be provided to employees. The employer must maintain accurate production records. IWC Orders 1 through 15, Section 7, and IWC Order 16, Section 6,

All employers must provide employees or their representative(s) access to accurate records of employee exposure to potentially toxic materials or harmful physical agents. Labor Code Section 6408(d)

Employment records may be subpoenaed from a current or former employer by a third party. If employment records are subpoenaed, the employee must be notified and has the right to object to production of the records. Code of Civil Procedure Section 1985.6(e)

Stockwell Intentional Stalling Mom 2 Year Life Terminal

3/11/2014 Did I scan a blank page? Sorry.

I am perplexed about your email about settlement given the fact that you just asked Dr. Tabaddor for a supplemental report?

I will see where settlement is but it will not be done tomorrow. Please call me in the morning after 9. Thanks

Sent from my Verizon Wireless 4G LTE DROID

Tiffany Anderson <tiffanyanderson@me.com> wrote:

here is kyles response an empty document titled scanned documents status quo don’t get your hopes up

3/10/2014 from Kyle Hansen

Per your request.

From: mail-sac@shww.com [mailto:mail-sac@shww.com]
Sent: Monday, March 10, 2014 3:45 PM
To: Kyle Hansen
Subject: Scanned Document

[ 6 pages, MSDS label for potassium permanganate] 

 3/10/2014 You requested a supplemental report from Dr. Tabaddor.

Their office called seeking authorization to review the records.

Attached is my letter of authorization. I did clarify that the only active case is the 2011 case.

 The source card number for the Stockton Sewer Plant is 10-1N-6E-18-003.

  Kyle Hansen

Stockwell Harris Woolverton & Muehl

1/11/2014 Letter to Kyle Hanson asking for 9 numbered items

1/8/2014 It is not  proper to unilaterally cancel a PQME evaluation.

If more time was needed to gather information due to the delay in getting stuff to you I would have

Been willing to Reschedule the appointment.

I am going to reschedule the evaluation for April at the earliest. Do we need a conference at the Stockton WCAB to

Go over what you propose to send to Dr. Allems? If so let me know and I will file for a Conference.

Kyle Hansen

Stockwell Harris Woolverton & Muehl

—–Original Message—–

From: Tiffany Anderson [mailto:tiffanyanderson@me.com]

Sent: Wednesday, January 08, 2014 2:26 PM

To: Kyle Hansen

Subject: PQME cancellation for upcoming appointment January 23, 2014 with Dr. Allems


I phoned Dr. Allems do reschedule the appointment coming up. I was unable to speak with him directly. I left a message on his answering machine.  I am following up with this email to you.  Please note I am canceling this appointment. This appointment is unnecessary until the evidence to submit is agreed upon.


Tiffany Anderson

12/20/2013 Again requested items listed in the October 16, 2013 letter

12/18/2013 Time Sheets

I finally was able to get someone freed up in the office to copy these records for you.

They will go out either tomorrow or Friday in the mail.

 12/17/2013 Letter to Kyle and copy to UNUM asking for documents in advance of the QME

12/4/2013  Tis the season for colds and flues. I hope all is better. 

Thank you, Kyle. 

On Dec 4, 2013, at 9:17 AM, Kyle Hansen <Kyle_Hansen@shwm.com> wrote:

I was out taking care of a sick kid for a few days before the Thanksgiving Holiday

So things are a bit behind.

All of the materials are being copied so should go out in the mail either Thursday or Friday at the latest.

Hope your Thanksgiving was nice.

 Kyle Hansen

Stockwell Harris Woolverton & Muehl

11/20/2013 Kyle, 

Thank you so much! Much appreciated.

Tiffany Anderson

On Nov 20, 2013, at 9:13 AM, Kyle Hansen <Kyle_Hansen@shwm.com> wrote:

I received a huge box on Monday from Eddie.

I will need a few days to go through it and have someone in my office copy it.

It will go out before Thanksgiving. Call or email if you have any questions.

 Kyle Hansen

Stockwell Harris Woolverton & Muehl

10/24/2013 from Kyle Hansen

You will have them in plenty of time. Hoping by mid-November.

From: Tiffany Anderson [mailto:tiffanyanderson@me.com]
Sent: Thursday, October 24, 2013 10:02 AM
To: Kyle Hansen; pmyers@dir.ca.gov pmyers@dir.ca.gov
Subject: Fwd: kyle qme reschedule

 Tiffany Anderson

2 Avena Avenue

Lodi, California 95240 

October 24, 2014

Receipt of Amended QME Date, Request for Documents  

Stockwell, Harris, Woolverton & Muehl

1545 River Park Drive

Sacramento, California 95815-4616  

Dear Mr. Hansen, 

Thank you for rescheduling, it is imperative I receive the documents at least.

Dear Kyle Hansen,

I am in receipt of your letter dated 10/15/13, in which you reschedule the QME for 1/23/14. Thank you for giving me the time I need to assemble my case. I am still anticipating the documents I requested, and will need  to have them at least a month in advance of the appointment (as it will take that time to assemble them). Thank you for your exhaustive cooperation.


Tiffany Anderson

From: Kyle Hansen <Kyle_Hansen@shwm.com>

10/16/2013 Letter sent to Kyle asking for 7 numbered items including time sheets

10/10/2013 at 1:16:39 PM PDT

To: Tiffany Anderson <tiffanyanderson@me.com>

Subject: Re: Response required

Call me tomorrow. If claims are not denied at this point (not sure) then AIMS is obligated to provide care up to $10,000 or until claim is denied. Regarding knees you are free to treat with a doctor of your choosing.

Sent from my Verizon Wireless 4G LTE DROID

Tiffany Anderson <tiffanyanderson@me.com> wrote:

Thank you very much Kyle for your speedy response.

Here is one major point of concern. I have been using my private insurance provided by my employer. This benefit has been terminated along with my employment and I do not know where or how to get medical treatment now.

Any suggestions I would appreciate.

Thank you

Tiffany Anderson

On Oct 10, 2013, at 10:57 AM, Kyle Hansen <Kyle_Hansen@shwm.com> wrote:

I will reschedule the QME evaluation in the next few days.

I do not know if those injuries have been accepted or denied at this time. The time frame is 90 days from the date of the application.

I will see. However I am recommending the claims be denied pending Dr. Allems’ opinion. If he then finds injury due to chemical exposure then liability most likely would be accepted.

I need to review where we are with documents but will review early next week.

I will provide you with ample time to get everything together for Dr. Allems.

Sorry it has been a very hectic last few weeks.


—–Original Message—–

From: Tiffany Anderson [mailto:tiffanyanderson@me.com]

10/10/2013 10:51 AM

To: Kyle Hansen; pmyers@dir.ca.gov

Subject: Response required

October 10, 2013


The QME with Dr Allems is getting near and I do not have the materials discussed in prior correspondence needed for this appointment. I understand you may be busy. At this time I am requesting that you respond to me where we are at.

1) Are you going to reschedule the QME?

2) Has AIMS accepted both claims

        a. Specific Exposure DOI 6/29/2011

        b. Cumulative Exposure DOI 6/2004

3) Are you going to provide the documents we discussed per phone agreement?

I will be filing next week to request a hearing for documents for medical discovery if I do not hear back from you.


Tiffany Anderson


9/26/2013 at 1:35 PM, Kyle Hansen <Kyle_Hansen@shwm.com> wrote:

Ms. Anderson:

 I enclose a letter and some documents. I will be out of the office the rest of Thursday and Friday.

Let’s talk either on Monday or Tuesday of next week concerning your case and how to proceed.

I want to be on the same page with Dr. Allems regarding what he is going to review and what he is going to comment on.

It is my opinion that he should address all alleged dates of injury concerning exposure. He does not address knees.

Kyle Hansen

Stockwell Harris Woolverton & Muehl

From: mail-sac@shww.com [mailto:mail-sac@shww.com]


Sent: Thursday, September 26, 2013 2:12 PM

To: Kyle Hansen

Subject: Scanned Document

 <SKMBT_75013092613110.pdf>  [64 pages in PDF form]

9/23/2013 from Kyle Hansen

I will email you tomorrow everything that I have. Sorry I have been very busy.

Can you email me your email from Friday as well. Don’t worry we will work everything out.

 From: Tiffany Anderson [mailto:tiffanyanderson@me.com]
Sent: Monday, September 23, 2013 8:55 AM
To: pmyers@dir.ca.gov; pmeyers@dir.ca.gov; Kyle Hansen
Subject: Fwd: Waste Water Information Packet

Kyle here is the most up to date information I could find regarding some of the data I requested to be present for the upcoming QME appointment. I need a response from you the date is almost four weeks away. 


Tiffany Anderson 

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