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Records: 897 EMPLOYER 1 WORKSAFE 5 LEGAL 8 INTERNAL 852 PERSONAL 31 ⭐ Key: 26 | Last import: 2026-05-11 10:20
← WCB REBUTTAL CLINICAL OPINION PANG … WCB REBUTTAL CLINICAL OPINION PANG … β†’
HOLAND_CLAIM_FILE_p011WCB REBUTTAL CLINICAL OPINION PANG MAR20 07
πŸ“„ HOLAND_CLAIM_FILE_p008 to p015 | p.14
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WORKING TO MAKE A DIFFERENCE

Memo
(continued)

Worker last name First name Middle initial WorkSafeBC claim number
HOLAND MARK 42647461

professional and personal sense. | have worked in genuinely noisy environments β€”
mainline railway track maintenance, tower rigging in Northern Alberta, heavy
equipment operations β€” and have consistently worn appropriate hearing protection
throughout.

| do not have a pre-existing history of pathological sensitivity to low level noises. |
have never been diagnosed with hyperacusis prior to this injury. | have never
avoided normal acoustic environments. | have never reported noise sensitivity to
any physician prior to January 2026.

High fidelity hearing and pathological noise sensitivity are categorically different
conditions. One is an asset | have carefully protected throughout a 30 year career.
The other is a condition | did not have before January 12, 2026.

The clinical opinion converted my statement about protecting a valued sensory
asset into evidence of a pre-existing pathological condition. This misrepresentation
materially affected the clinical conclusions and constitutes a factual error of
significant consequence.

ERROR 14 β€” MARCH 5 EMERGENCY ROOM FOOTAGE REVIEW
MISCHARACTERIZED

The clinical opinion states regarding the March 5, 2026 ER visit β€” the physician
reviewed footage of the worker sleeping that he provided and did not see any
evidence of tonic clonic movements.

This characterization misrepresents both my clinical presentation and what occurred
during that interaction.

| presented sleep footage specifically to demonstrate cyclical nocturnal motor
activity consistent with a physiological feedback loop. The resident's initial response
was that everyone moves in their sleep. | specifically directed the physician to
observe the cyclical and repeating pattern of the movements β€” not random
positional changes characteristic of normal sleep movement but a recurring cycle
consistent with an identifiable physiological source and feedback mechanism.
Tonic clonic movements are the convulsive movements of generalized epileptic
seizure. | never claimed to be having epileptic seizures. | claimed to be
experiencing nocturnal motor spasms consistent with tensor tympani feedback loop
activity during sleep β€” a recognized feature of TTTS.

The clinical opinion characterized this interaction as the physician finding no
evidence of tonic clonic movements β€” implying | claimed seizures and was
clinically disproven. | claimed cyclical nocturnal spasms consistent with TTTS. That
claim was not assessed. It was not addressed. It was reframed as a seizure claim
and dismissed on those grounds.

This is a material misrepresentation of both my clinical presentation and the
physician interaction on March 5, 2026.

FORMAL REQUESTS
| am formally requesting that WorkSafeBC:

1. Withdraw the Clinical Opinion dated March 20, 2026 prepared by Flora Pang
M.Sc. RAUD Aud(C) on the grounds that it contains fourteen identified errors
of fact, methodology, clinical reasoning, and procedural fairness that
collectively invalidate its conclusions.

2. Commission a replacement clinical opinion that correctly identifies the

68B33

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