As established in Section 2, above, both mechanisms tested are ones the worker excluded himself, in writing,
before the claim existed. Testing only those two mechanisms, and never the tensor tympani / TMJ /
Sensory-processing pathway the worker's \reating specialists have since identified, is the central deficiency
running through both submissions. Sections 4-8, below, set out what the specialist record actually shows.

4. Mischaracterization of the Pre-Existing Migraine Condition

The Opinion treats the worker's migraine history as an undifferentiated Pre-existing condition, without
reference to its management status immediately before the exposure or to how it changed afterward. The
worker's specialist record — and his own January 22, 2026 report — fills that gap.

A managed baseline

Before the January 2026 exposure, the worker had implemented a structured migraine reduction program: triple
progressive glasses (obtained after a vision assessment revealed both farsightedness and nearsightedness),
Coenzyme Q10, and cessation of both smoking and alcohol. This program produced a documented 33%
reduction in sumatriptan use — an objective, medication-based measure of improving control.

Oveupational disruption of that baseline

The worker's January 2026 training placement seated him directly in front of two industrial-sized servers.
Within the first week of exposure, sleep became disrupted and the migraine reduction program began losing
cflectiveness. Small and nocturnal headaches increased, Approximately two weeks in, sharp stabbing pain
developed in both ears, worse on the left.

‘The clinical turning point

This exposure pushed the worker's migraines to “a severity never previously experienced,” resulting in his
first-ever emergency room visit for a migraine, on January 30, 2026 — after seventeen months of a stable,
well-controlled baseline, and eight days after the January 22, 2026 report in which he had already flagged the
exposure as a problem. This is not the profile of a pre-existing condition running its own independent course; it
is the profile of a managed condition destabilized by a new exposure, exactly as the worker predicted in real
time,

Source: Dr. Navjot Chaudhary, Neurology:Pain, Surrey iScope Concussion & Pain Clinics, clinical report, June 29, 2026.

“... Workers’ compensation claim was denied 5) an audiologist who attributed the claim to migraines without

reviewing the migraine reduction program or the timeline of the first emergency room visit an 01/30/2026,"
Dr. N. Chaudhary, June 29, 2026

Dr, Chaudhary, a specialist neurology and pain physician, examined the worker directly and reviewed the same
medical file available to Ms. Pang. Her report identifies the specific gap in the Opinion: it labels the condition
“pre-existing” without ever engaging with the fact that the condition was actively and successfully managed
until the exposure began.

The clinical course sinee has already answered (he Opinion’s causal question

The Opinion's conclusion depends on migraines being “the main driving factor” of the worker's ongoing
complaints. That theary is now testable against the clinical course, and it has failed the test, As of the July 16,
2026 consultation with Dr. Abdalkhani, ENT, the workers migraines had resolved through self-management —-
self-massage, heat application, and daily sauna use — while the left ear pain that prompted this claim had not.

Source: Dr. Arman Abdalkhani, MD, FRCSC, Van City Ear, Nose & Throat, consitltation report, July 16, 2026.

“Migraines have resolved with self-management strategies."

“Audiologist from WCB attempted to attribute Svaiploms fo migraines; however, migraines have cleared while
ear pain persists,”

~~ Dr A, Abdalkhani, July 16, 2026

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