Web1353 (Fed. Cir. 2024) (citing Bowey v. West, 11 Vet.App. 106, 108-09 (1998)); Bell v. Derwinski, 2 Vet.App. 611, 613 (1992)). The Secretary argues that the Board cannot constructively possess ... appellant further argues that this case is distinguishable from Bowey, because a URL web address is more than a mere reference to a medical article. Id. WebAug 19, 2024 · See Bowey v. West, 11 Vet. App. 106, 108-09 (1998) (holding that mere reference to non-VA documents is insufficient to incorporate them into a record). And records generated by the VA as to one claimant are not normally constructively part of every claimant's record. ... Goodwin v. West, 11 Vet. App. 494, 496 (1998). The Veterans …
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