Opinion

Gibson v. Commissioner Social Security Administration

Court
District Court, D. Oregon
Filed
Jul 12, 2022
Cited by
0 cases
Authority
More cited than 28.7%

The opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

MARGO G.,1 Case No. 3:20-cv-01002-IM

Plaintiff, OPINION AND ORDER

v.

COMMISSIONER, SOCIAL SECURITY

ADMINISTRATION,

Defendant.

Kevin Kerr, Kerr Robichaux & Carroll, P.O. Box 14490, Portland, OR 97293. Attorney for

Plaintiff.

Katherine B. Watson and Sarah Elizabeth Moum, Office of General Counsel Social Security

Administration, 701 Fifth Ave., Ste. 22, Seattle, WA 98104; Renata Gowie, U.S. Attorney's

Office District of Oregon, 1000 SW Third Ave., Ste. 600, Portland, OR 97204. Attorneys for

Defendant.

IMMERGUT, District Judge.

Plaintiff Margo G. seeks review of a final decision of the Commissioner of Social

Security (“Commissioner”) denying her claim for Disability Insurance Benefits (“DIB”) pursuant

1 In the interest of privacy, this opinion uses only the first name and the initial of the last name of

the non-governmental party in this case. Where applicable, this opinion uses the same

designation for a non-governmental party’s immediate family member.

to the Social Security Act. For the following reasons, this Court AFFIRMS the Commissioner’s

decision.

STANDARD OF REVIEW

The district court must affirm the Commissioner’s decision if it is based on the proper

legal standards and the findings are supported by substantial evidence. 42 U.S.C. § 405(g); see

also Hammock v. Bowen, 879 F.2d 498, 501 (9th Cir. 1989). “Substantial evidence” means

“more than a mere scintilla but less than a preponderance.” Bray v. Comm’r of Soc. Sec.

Admin., 554 F.3d 1219, 1222 (9th Cir. 2009) (quoting Andrews v. Shalala, 53 F.3d 1035, 1039

(9th Cir. 1995)). It means “such relevant evidence as a reasonable mind might accept as adequate

to support a conclusion.” Id. (quoting Andrews, 53 F.3d at 1039).

If the evidence is “susceptible to more than one rational interpretation,” the

Commissioner’s conclusion must be upheld. Burch v. Barnhart, 400 F.3d 676, 679 (9th

Cir. 2005). Variable interpretations of the evidence are insignificant if the Commissioner’s

interpretation is a rational reading of the record, and this Court may not substitute its judgment

for that of the Commissioner. See Batson v. Comm’r of Soc. Sec. Admin., 359 F.3d 1190, 1193,

1196 (9th Cir. 2004). “[A] reviewing court must consider the entire record as a whole and may

not affirm simply by isolating a specific quantum of supporting evidence.” Orn v. Astrue, 495

F.3d 625, 630 (9th Cir. 2007) (quoting Robbins v. Soc. Sec. Admin., 466 F.3d 880, 882 (9th

Cir. 2006) (quotation marks omitted)). A reviewing court, however, may not affirm the

Commissioner on a ground upon which the Commissioner did not rely. Id.; see also Bray, 554

F.3d at 1226.

BACKGROUND

A. Plaintiff’s Application

Plaintiff was born on April 9, 1963. AR 104. Her relevant past work included office

manager, beauty shop manager, barber, hair stylist, receptionist, and phlebotomist. AR 34.

Plaintiff alleges disability related to various physical and mental conditions including

osteoarthritis, fibromyalgia, colitis, and depression. AR 28. Her current claim was protectively

filed on February 3, 2017. AR 25. The claim was first denied on March 28, 2017, and, upon

reconsideration, on May 25, 2017. Id. Plaintiff requested review of these denials, and the

Administrative Law Judge (“ALJ”), S. Pines, held an administrative hearing on October 18,

2018. Id. On February 27, 2019, the ALJ issued a decision denying Plaintiff’s application for

benefits, finding that she was not disabled from October 14, 2015 (the alleged onset date)

through June 30, 2016 (the date last insured). AR 27. The Appeals Council declined review on

April 16, 2020. AR 1. Plaintiff then appealed to this Court.

Previously, Plaintiff had protectively filed an application for benefits on December 21,

2012. AR 76. ALJ Cecilia LaCara denied her application for benefits on October 13, 2015. AR

90. On November 23, 2016, the Appeals Council denied Plaintiff’s request for review, making

the ALJ’s decision the final decision of the Commissioner. AR 97.

B. The Sequential Analysis

A claimant is disabled if he or she is unable to “engage in any substantial gainful activity

by reason of any medically determinable physical or mental impairment which . . . has lasted or

can be expected to last for a continuous period of not less than 12 months[.]” 42 U.S.C.

§ 423(d)(1)(A). “Social Security Regulations set out a five-step sequential process for

determining whether an applicant is disabled within the meaning of the Social Security Act.”

Keyser v. Comm’r Soc. Sec. Admin., 648 F.3d 721, 724 (9th Cir. 2011); see also 20 C.F.R.

§§ 404.1520 (DIB), 416.920 (SSI); Bowen v. Yuckert, 482 U.S. 137, 140 (1987). Each step is

potentially dispositive. 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4). The five-step sequential

process asks the following series of questions:

1. Is the claimant performing “substantial gainful activity?” 20 C.F.R.

§§ 404.1520(a)(4)(i), 416.920(a)(4)(i). This activity is work involving

significant mental or physical duties done or intended to be done for pay

or profit. 20 C.F.R. §§ 404.1510, 416.910. If the claimant is performing

such work, she is not disabled within the meaning of the Act. 20 C.F.R.

§§ 404.1520(a)(4)(i), 416.920(a)(4)(i). If the claimant is not performing

substantial gainful activity, the analysis proceeds to step two.

2. Is the claimant’s impairment “severe” under the Commissioner’s

regulations? 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). An

impairment or combination of impairments is “severe” if it significantly

limits the claimant’s physical or mental ability to do basic work activities.

20 C.F.R. §§ 404.1521(a), 416.921(a). Unless expected to result in death,

this impairment must have lasted or be expected to last for a continuous

period of at least 12 months. 20 C.F.R. §§ 404.1509, 416.909. If the

claimant does not have a severe impairment, the analysis ends. 20 C.F.R.

§§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). If the claimant has a severe

impairment, the analysis proceeds to step three.

3. Does the claimant’s severe impairment “meet or equal” one or more of the

impairments listed in 20 C.F.R. Part 404, Subpart P, Appendix 1? If so,

then the claimant is disabled. 20 C.F.R. §§ 404.1520(a)(4)(iii),

416.920(a)(4)(iii). If the impairment does not meet or equal one or more of

the listed impairments, the analysis continues. At that point, the ALJ must

evaluate medical and other relevant evidence to assess and determine the

claimant’s “residual functional capacity” (“RFC”). This is an assessment

of work-related activities that the claimant may still perform on a regular

and continuing basis, despite any limitations imposed by his or her

impairments. 20 C.F.R. §§ 404.1520(e), 404.1545(b)-(c), 416.920(e),

416.945(b)-(c). After the ALJ determines the claimant’s RFC, the analysis

proceeds to step four.

4. Can the claimant perform his or her “past relevant work” with this RFC

assessment? If so, then the claimant is not disabled. 20 C.F.R.

§§ 404.1520(a)(4)(iv), 416.920(a)(4)(iv). If the claimant cannot perform

his or her past relevant work, the analysis proceeds to step five.

5. Considering the claimant’s RFC and age, education, and work experience,

is the claimant able to make an adjustment to other work that exists in

significant numbers in the national economy? If so, then the claimant is

not disabled. 20 C.F.R. §§ 404.1520(a)(4)(v), 416.920(a)(4)(v),

404.1560(c), 416.960(c). If the claimant cannot perform such work, he or

she is disabled. Id.

See also Bustamante v. Massanari, 262 F.3d 949, 954 (9th Cir. 2001).

The claimant bears the burden of proof at steps one through four. Id. at 953; see also

Tackett v. Apfel, 180 F.3d 1094, 1098 (9th Cir. 1999); Yuckert, 482 U.S. at 140–41. The

Commissioner bears the burden of proof at step five. Tackett, 180 F.3d at 1100. At step five, the

Commissioner must show that the claimant can perform other work that exists in significant

numbers in the national economy, “taking into consideration the claimant’s residual functional

capacity, age, education, and work experience.” Id.; see also 20 C.F.R. §§ 404.1566, 416.966

(describing “work which exists in the national economy”). If the Commissioner fails to meet this

burden, the claimant is disabled. 20 C.F.R. §§ 404.1520(a)(4)(v), 416.920(a)(4)(v). If, however,

the Commissioner proves that the claimant is able to perform other work existing in significant

numbers in the national economy, the claimant is not disabled. Bustamante, 262 F.3d at 953–54;

Tackett, 180 F.3d at 1099.

C. The ALJ’s Decision

At step one of the sequential evaluation process, the ALJ found that Plaintiff had not

engaged in substantial gainful activity since the alleged onset date of October 14, 2015. AR 27.

At step two, the ALJ found the following severe impairments: “osteoarthrosis,

fibromyalgia, colitis, and depression.” AR 28.

At step three, the ALJ found that Plaintiff did not have an impairment or combination of

impairments that met or medically equaled the severity of one of the listed impairments in 20

C.F.R. Part 404, Subpart P, Appendix 1 (20 C.F.R. §§ 404.1520(d), 404.1525 and 404.1526).

The ALJ then determined Plaintiff’s RFC. Id. The ALJ found her capable of performing light

work as defined in 20 CFR 404.1567(b), except that:

[She] can stand and walk for a combined total of six hours and can sit for six

hours; can occasionally climb ramps and stairs; can never climb ladders, ropes or

scaffolds; can occasionally balance, stoop, kneel, crouch, and crawl; can

occasionally reach overhead and frequently reach in all other directions; can

frequently handle and finger; should not have concentrated exposure to extreme

temperatures, vibration, or hazards; and is limited to simple, routine work, in a

workplace with no more than occasional workplace changes.

AR 29–30.

At step four, the ALJ found that Plaintiff was unable to perform any past relevant work.

AR 34.

At step five, the ALJ considered the claimant’s age, education, work experience, and

RFC, and concluded that jobs exist in significant numbers in the national economy that Plaintiff

could perform. AR 35. The ALJ relied on vocational expert testimony to find Plaintiff capable of

other work, identifying the representative occupations of pricer, office helper, and production

assembler.2 Id. Finally, the ALJ found that Plaintiff has not been under a disability from October

14, 2015, the alleged onset date, through June 30, 2016, the date last insured. AR 36.

DISCUSSION

Plaintiff raises a single issue for this Court’s review: whether the ALJ erred by rejecting

the opinion of Dr. Aaron A. Brown, D.O., Plaintiff’s treating source physician. ECF 21 at 3. As

2 An ALJ may rely on the Medical-Vocational Guidelines found at 20 C.F.R. Part 404, Subpart

P, Appendix 2, or on the testimony of a vocational expert. Tackett, 180 F.3d at 1101. “[A]

vocational expert or specialist may offer expert opinion testimony in response to a hypothetical

question about whether a person with the physical and mental limitations imposed by the

claimant's medical impairment(s) can meet the demands of the claimant’s previous work, either

as the claimant actually performed it or as generally performed in the national economy.” 20

C.F.R. § 404.1560(b)(2).

explained below, the ALJ reasonably evaluated Dr. Brown’s medical opinion and properly

rejected the opinion based on contradictory evidence contained in the record.

A. Dr. Brown’s Opinion

According to Dr. Brown, Plaintiff could only lift or carry less than ten pounds

occasionally or frequently, and could only stand or walk less than two hours, total, in an eight-

hour day (up to twenty minutes at one time). AR 1793. Dr. Brown also found that Plaintiff could

only sit up to four hours per day (up to two and a half hours at one time). Id. Dr. Brown noted

that during the time Plaintiff was not capable of sitting, standing, or walking, she would need to

be reclining or laying down. Id. Dr. Brown found that Plaintiff could climb, kneel, crouch, crawl,

and reach occasionally, and could balance, stoop, and bend frequently. Id. He indicated Plaintiff

was unable to complete even simple work tasks for 20 percent of the work week due to attention

and concentration deficits. AR 1794. Plaintiff would need to be absent from work at least 16

hours per work month because of her mental health problems and the pain associated with her

colitis and tendonitis. Id.

B. Analysis of the ALJ’s Decision

Plaintiff claims that the ALJ erred when it rejected the August 2018 opinion of Dr. Aaron

A. Brown, D.O., Plaintiff's primary care provider. ECF 21 at 4. While Dr. Brown’s evaluations

noted significant physical and mental limitations, this Court agrees with the ALJ’s decision

finding that Dr. Brown’s opinion was inconsistent with Plaintiff’s daily activities. AR 33.

Plaintiff’s daily activities included caretaking responsibilities and the completion of household

chores. Specifically, Plaintiff testified that her grandson lived with her since his birth in

September 2015, and that she was his primary caregiver.3 AR 30–31, 49. She reported she

received some help with these activities from her husband. AR 261, 268–69. However,

Plaintiff’s husband became ill in 2015 with progressive dementia, requiring her to care for him as

well. AR 30, 498–99, 1401. Although Plaintiff received some help twice per week from a home

health aide to assist in caring for her husband, she was primarily responsible for the caretaking of

her husband. AR 31, 498–99.

An ALJ rejecting the opinion of a treating or examining physician must provide clear and

convincing reasons for the decision. See Lester v. Chater, 81 F.3d 821, 830 (9th Cir. 1995). Even

when a treating or examining physician’s opinion is contradicted by the opinions of other

treating or examining physicians, an ALJ still must provide “specific and legitimate reasons” to

reject that opinion, “supported by substantial evidence in the record.” Id. at 830–31. The ALJ

must consider not only the physician’s clinical findings and interpretation of test results, but also

his subjective judgments. Id. at 833. While the ALJ is not required to discuss each piece of

medical evidence, Howard v. Barnhart, 341 F.3d 1006, 1012 (9th Cir. 2003) (citing Black v.

Apfel, 143 F.3d 383, 386 (8th Cir. 1998)), the ALJ must explain why he or she rejects significant

probative evidence, Vincent v. Heckler, 739 F.2d 1393, 1395 (9th Cir. 1984). “The ALJ must do

more than offer his conclusions. He must set forth his own interpretations and explain why they,

rather than the doctors’, are correct.” Embrey v. Bowen, 849 F.2d 418, 421–22 (9th Cir. 1988).

The Ninth Circuit has recognized a proper basis for discounting a treating physician’s

opinion when the claimed restrictions are inconsistent with the level of activity engaged in by a

claimant. Rollins v. Massanari, 261 F.3d 853, 856 (9th Cir. 2001) (“[T]he restrictions appear to

3 Plaintiff noted her daughter also helps with cleaning and caretaking for her grandson,

but she is still the child’s primary caregiver. See AR 261.

be inconsistent with the level of activity that [the defendant] engaged in by maintaining a

household and raising two young children, with no significant assistance from her ex[-]

husband.”). Like the claimant in Rollins, Plaintiff did not receive significant assistance in

maintaining a household and providing care to family members. Yet the treating doctor assigned

restrictions “so extreme as to be implausible.” Id. Plaintiff’s objection boils down to a claim that

the ALJ erred by rejecting her claim without including specific details about Plaintiff’s

caregiving activities.4 ECF 21 at 5–6.

In support of her argument, Plaintiff cites Trevizo v. Berryhill, in which the Ninth Circuit

found that the ALJ failed to provide “specific and legitimate” reasons for rejecting the

physician’s opinion because the ALJ did not sufficiently detail the extent of the plaintiff’s

childcare activities and how that undermined the claimed limitations. 871 F.3d 664, 676 (9th Cir.

2017). However, Trevizo is distinguishable from the facts here. In that case, the Ninth Circuit

chided the ALJ for failing to provide detail about the plaintiff’s regular childcare activities. This

included the extent and frequency with which the plaintiff did things like pick up, bathe, and play

with the children she was caring for. Id. The only details that the ALJ in Trevizo did account for

were “one-off events” like the plaintiff taking the children to the doctor’s office which did not

speak to the limitations at issue. See id. The court also noted that the ALJ failed to inquire

whether the plaintiff cared for the children alone or with the assistance of others. Id.

Contrary to Plaintiff’s assertion here that the ALJ “did not include any specific details

about Plaintiff’s caregiving activities,” ECF 21 at 6, the ALJ detailed the numerous tasks that

Plaintiff was responsible for. This included doing most of the family’s meal preparation, and

4 This error is supposedly harmful, because the ALJ did not present Dr. Brown’s assessed

limitations to the vocational expert. Id. at 8.

taking care of laundry, pet care, and other household chores like cleaning. See AR 33. The ALJ

also noted that despite the claimed limitations, Plaintiff could ride a bicycle and “knew exercise

was good for her, but [explained that] . . . the primary impediment was a lack of time due to her

caregiving responsibilities.” Id. (emphasis added).

Despite Dr. Brown’s opinion that Plaintiff could not perform simple work tasks 20

percent of the time and would need to miss 16 hours of work per month, the record demonstrates

that Plaintiff was able to meet the significant responsibilities that came with providing care not

only to herself but two other family members. Plaintiff successfully completed primary

caretaking activities for a young child (7 days a week) and an adult suffering from progressive

dementia (5 or more days a week) with little outside help. These caretaking activities were

substantive, and it would be odd for a person with such marked limitations to keep up with such

a rigorous routine. As the record notes, Plaintiff did “everything” for her grandson, including

waking him, brushing his teeth, dressing him, and preparing meals. ECF 22 at 3 (citing AR 261–

62). She was even able to pick up her grandson several times per day even though he weighed 21

pounds—more than twice the lifting limit identified by Dr. Brown. AR 664. Similarly, she notes

that her husband “cannot cook, drive [or] pay bills.” AR 261.

Plaintiff acknowledges that the record contains life activities that would appear to

contradict the claimed limitations. However, she argues that the mere existence of these activities

means little without additional context. For example, she explains that the sole fact that she is

able to ride a bicycle does not contradict Dr. Brown’s opinion because the ALJ did not detail

how often and how long she engaged in this activity. ECF 21 at 7. This line of argument is not

well taken. The ALJ did not reject Plaintiff’s claim based on an analysis of a few isolated life

activities. At its core, Dr. Brown’s opinion involves Plaintiff’s ability to sustain physical activity

over a period of time. And each of the significant caregiving responsibilities that fill Plaintiff’s

daily schedule—when considered in their totality—present a contradiction. It is difficult for this

Court to imagine, and Plaintiff has failed to adequately explain, how it would be possible to keep

up with her current schedule when her ability to sit, stand, and walk are so drastically limited.

Thus, even if the ALJ did not go into granular detail about the specifics of each individual

activity, taken together, these numerous activities provide a legitimate basis for the ALJ to reject

Dr. Brown’s opinion. This Court does not read Trevizo as requiring an ALJ to exhaustively

chronicle a plaintiff’s daily activities minute by minute. As the court in Trevizo noted, one of the

fundamental errors in the ALJ’s decision was not that there was just a mere dearth of

information. Rather, the error was attributable to the fact that the ALJ provided “no details as to

what [the plaintiff]’s regular childcare activities involved.” Trevizo, 871 F.3d at 676 (emphasis

added).

Within this district, courts applying Trevizo have cautioned against such an expansive

reading of the case. For example, in Marcus P. v. Comm’r, Soc. Sec. Admin., No. 6:19-CV-0003-

HZ, 2020 WL 5866323 (D. Or. Sept. 29, 2020), the plaintiff claimed that the ALJ should have

developed the record pertaining to his childcare responsibilities before using these activities as a

basis to deny his claim. The court rejected this argument, finding that “[u]nlike Trevizo, where

there was no evidence of what the claimant’s childcare activities involved that could undermine

the claimant’s physical limitations, Plaintiff creating a routine for the children, taking them to

school, caring for the kids all day and getting them to bed at night, and taking the children to all

their doctor and dentist appointments contradicts Plaintiff’s assertion that he is so limited by his

psychological impairments that he cannot understand and carry out simple instructions.” Id. at *5

(internal quotation marks and citation omitted); see also Starlyn B. v. Comm’r, Soc. Sec. Admin.,

No. 6:17-CV-1897-SU, 2019 WL 4786959, at *7 (D. Or. Mar. 22, 2019), report and

recommendation adopted, No. 6:17-CV-01897-SU, 2019 WL 4786047 (D. Or. Sept. 29, 2019)

(noting that the plaintiff’s reliance on Trevizo was “misplaced” and that “unlike Trevizo, the ALJ

relied on more than plaintiff’s childcare activities to discount plaintiff’s symptom allegations,

and the specific demands of plaintiff's childcare activities were detailed in the record”).5 Trevizo

simply asks that when daily activities are used to reject a disability claim, “specific details” about

those daily activities should be given. Trevizo, 871 F.3d at 676. A lack of specific detail is not at

issue here and Plaintiff’s reliance on Trevizo is misplaced.

Plaintiff also claims that the ALJ should not have placed so much reliance on evidence of

her daily life activities because they were performed in a home environment—rather than a

competitive work environment—and are not equivalent. ECF 21 at 6. Citing Garrison v. Colvin,

759 F.3d 995 (9th Cir. 2014), Plaintiff claims that the ALJ was required to account for the

differences in these two environments. ECF 21 at 6. In Garrison, the Ninth Circuit explained that

“[m]any home activities are not easily transferable to what may be the more grueling

environment of the workplace, where it might be impossible to periodically rest or take

medication.” Id. at 1016 (quoting Fair v. Bowen, 885 F.2d 597, 603 (9th Cir. 1989)). The court

found that the plaintiff’s “ability to talk on the phone, prepare meals once or twice a day,

5 Here, the facts also differ from the cases within this district where Trevizo’s reasoning

was used as a basis for remand. For example, in Alicia D. v. Kijakazi, No. 3:20-CV-01222-SB,

2022 WL 891786 (D. Or. Mar. 3, 2022), report and recommendation adopted, No. 3:20-CV-

1222-SB, 2022 WL 888297 (D. Or. Mar. 25, 2022), the plaintiff suffered from post-traumatic

stress disorder symptoms which notably impaired her interpersonal and emotional abilities. Id. at

*6. The ALJ discounted the plaintiff’s testimony because it was inconsistent with activities like

taking her son to the library or archery range. Id. The Court found that the ALJ should not have

relied on activities that were so solitary in nature—since it is unlikely that the plaintiff would

have interacted with other people in these circumstances. See id. Here, unlike in Alicia D.,

Plaintiff’s daily activities bear a more direct connection to Plaintiff’s claimed limitations.

occasionally clean [her] room, and, with significant assistance, care for [her] daughter, all while

taking frequent hours-long rests, avoiding any heavy lifting, and lying in bed most of the day,”

was not evidence sufficient to reject the plaintiff’s testimony. 759 F.3d at 1016.

But like Trevizo, Plaintiff’s reliance on Garrison is also distinguishable. The court in

Garrison noted that the plaintiff required considerable help from her mother, was often unable to

engage in activities due to pain, and typically required rest after carrying out minimal activities.

Id. at 1015–16. Here, Plaintiff’s activities were far more “robust than the ‘minimal, punctuated

activities’” at issue in Garrison. See Starlyn B., 2019 WL 4786959, at *7. As already explained

above, there is little evidence in the record that Plaintiff’s daily life activities required minimal

effort or that her significant caretaking responsibilities could not have been accomplished

without help.

Accordingly, this Court finds that the ALJ did not err when she identified specific

inconsistencies between Plaintiff’s daily activities, on the one hand, and the extreme limitations

Dr. Brown assessed, on the other. Combined with Plaintiff’s caregiving activities and

housekeeping tasks, her frequent exercise via both walking and bicycling is not consistent with

an inability to stand or walk longer than 20 minutes at a time or less than two hours of a

workday. AR 1793. Further, although Dr. Brown opined that Plaintiff could lift less than ten

pounds, id., the record shows Plaintiff was able to lift her 21-pound grandson several times per

day, AR 664, 1257, 1267. Plaintiff was also able to launder clothes, handle cookware, and shop

for groceries, among other activities. AR 33, 254–55, 261–63. It was reasonable, then, for the

ALJ to reject Dr. Brown’s opinion.

CONCLUSION

The Commissioner’s decision denying Plaintiff’s application for disability benefits is

AFFIRMED.

IT IS SO ORDERED.

DATED this 12th day of July, 2022.

/s/ Karin J. Immergut

Karin J. Immergut

United States District Judge

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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