Smurfit-Stone Container Corp. v. Taylor

Smurfit-Stone Container Corp. and its workers’ compensation insurance carrier, RSKCO (Appellants) appeal an order of the Judge of Compensation Claims (JCC) awarding attorney’s fees. We hold, for purposes of this case, that Appellee’s filing of'his Motion for Emergency Conference, pursuant to section 440.25(4)(h), satisfied any pleading requirements under section 440.192. See Town & Country Farms v. Peck, 611 So.2d 63 (Fla. 1st DCA 1992) (notice and filing requirements may be excused in emergency situations). As Appellants refused to authorize the medically necessary emergency care even after…