The following excerpt is from Magda v. Colvin, No. 2:13-cv-0053 DAD (E.D. Cal. 2014):
4. "The opinions of . . . non-examining physicians may also serve as substantial evidence when the opinions are consistent with independent clinical findings or other evidence in the record." Thomas v. Barnhart, 278 F.3d 947, 957 (9th Cir. 2002).
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