Vaughan v. Broward General Medical Center

In this workers’ compensation appeal, Claimant argues that the Judge of Compensation Claims (JCC) erred by admitting into evidence, and relying upon, unauthenticated correspondence to support her denial of physical therapy, costs, and attorney’s fees where Claimant objected on authentication and hearsay grounds. She asserts that the correspondence was not a “medical report” under section 440.29(4), Florida Statutes (2011), and the Employer/Carrier (E/C) did not set forth an intent to rely on such a report as required by statute. For the reasons set forth below, we agree and we reverse.

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