Aten v. Workers' Comp. Appeals Bd

In Aten v. Workers' Comp. Appeals Bd. (1977) 75 Cal.App.3d 113, the parties stipulated as to the apportionment between the injuries. The Aten court applied Wilkinson rather than Fuentes, stating: "This is not a case in which it is impossible to say what proportion of the total disability is attributable to each of the three injuries, because the parties have stipulated to the exact percentages . . . . para. The stipulation does not prevent the application of the Wilkinson v. Workers' Comp. Appeals Bd. (1977) principle in these cases. The elements of the Bauer doctrine, as applied in Wilkinson, will be present if it should appear that the two injuries became permanent at the same time." ( Aten, supra, 75 Cal.App.3d at p. 119.)