[00:00:04] Speaker 02:
Okay, last we have McCulloch versus Bisognano.

[00:00:20] Speaker 01:
Good morning.

[00:00:21] Speaker 03:
Good morning.

[00:00:22] Speaker 01:
May it please the court. My name is Eitan Kanceljianic and I'm representing Beverly McCulloch in this appeal.

[00:00:29] Speaker 01:
McCulloch has been unable to work since December 2002 due to the combined functional effects of many severe impairments, including spinal impairments, right shoulder impairments, pain disorders, depressive disorders, anxiety disorders, including PTSD, and personality disorders.

[00:00:47] Speaker 01:
Prior to the period at issue here, McCulloch had three surgeries on her lumbar spine, the last of which was in June 2001.

[00:00:55] Speaker 01:
McCulloch first applied for disability benefits in 2003 and 2004, did not appeal the July 2005 denials on those applications. And the ALJ here refused to reopen the final determinations on those applications.

[00:01:11] Speaker 01:
McCulloch's current applications were filed in April 2007 when she was 40 years of age.

[00:01:18] Speaker 05:
Hold on one second. Wait, we just have a... I'm having trouble with the audio on your...

[00:01:24] Speaker 05:
There seems to be something of an echo.

[00:01:27] Speaker 02:
Is it possibly too loud?

[00:01:31] Speaker 04:
Kelly, can you bring his audio down a little bit?

[00:01:39] Speaker 02:
You want to try again?

[00:01:41] Speaker 01:
How is it now?

[00:01:42] Speaker 02:
It's better, I think. Better. Thank you.

[00:01:44] Speaker 01:
Okay.

[00:01:46] Speaker 01:
McCulloch's current applications were filed in April 2007 when she was 40 years of age.

[00:01:53] Speaker 01:
She's now 59 years old.

[00:01:56] Speaker 01:
Since that time, she's had seven ALJ hearings, received six ALJ decisions.

[00:02:00] Speaker 02:
Just because your time is limited and we are familiar with the lengthy procedural, can you maybe focus on what you think is your strongest issue to start?

[00:02:13] Speaker 01:
Thank you.

[00:02:16] Speaker 01:
So the main issue here, I think, involves the best way of summing it up is by looking at Ortiz, which was issued just a couple of weeks ago. The analysis in that decision is directly applicable to this case. The ALJ aired here. by improperly rejecting the findings and opinions of essentially all the McCullochs treating and examining physicians.

[00:02:38] Speaker 03:
Counsel, we're dealing here, are we not, with a closed period from 2002 to 2015.

[00:02:45] Speaker 03:
Am I right about that?

[00:02:47] Speaker 01:
That is correct.

[00:02:48] Speaker 03:
So she was found disabled approximately this time of year in 2015. That is correct. Yeah. So I guess...

[00:03:01] Speaker 03:
I would ask you specifically why it isn't reasonable and permissible to have discounted those opinions given things like claimant's daily activities during that period and the fact that she had stated that she was leaving her job in 2002 to take care of her kids.

[00:03:28] Speaker 03:
There were...

[00:03:30] Speaker 03:
other reasons given also, but why are those insufficient reasons in your view?

[00:03:36] Speaker 01:
Well, for one thing, in early 2003, she was in a rollover motor vehicle accident that further exacerbated her conditions. Our starting point here is that she'd already had three spinal surgeries.

[00:03:51] Speaker 01:
And looking back, pointing once again at the medical evidence and the medical opinion evidence, there are nine different medical providers who basically said that she had limitations that were very significant. And if taken, if accepted.

[00:04:11] Speaker 05:
What exact limitations are at issue here? My understanding is that the RFC recognized that she was quite limited, but the dispute, as far as I can tell, seems to revolve around whether she needed to changed positions so frequently that she really wasn't going to be able to work in a workplace. Is that the biggest focus of where the differences are?

[00:04:44] Speaker 01:
Yes, that's one of the two. The other one, I believe, is her need to lie down. I'm sorry, I'm having trouble.

[00:04:51] Speaker 03:
Need to lie down is what he said.

[00:04:53] Speaker 05:
You have to lie down, is that what you're saying? Well, that's part of the same thing, whether she had to lie down, whether she had to walk around, whether she had, and so on.

[00:05:03] Speaker 01:
Right. She, she could not make it through a full day without having to lie down to relieve the back pain that she had from these numerous, uh, And you don't in your brief spend much or maybe any time, um, talking about the medical opinions that the ALJ did rely on.

[00:05:24] Speaker 05:
Um, But they matter, right, because he was saying there was a conflict between the ones he discounted and the ones that he relied on. And we're back in the world in which the treating physicians are the ones that matter.

[00:05:43] Speaker 05:
So if we thought that the ones he did rely on didn't really stand up, would that matter?

[00:05:52] Speaker 01:
Yes, it should matter. They do that analysis very much.

[00:05:58] Speaker 05:
The treating physicians were Dr. Blair and Dr. Lindahl and who else?

[00:06:03] Speaker 01:
Gosh, those are, see, there was a Dr. Coren, that was an early on doctor. Sarah was a radiologist and he had some findings that were very significant. Blair and Lindahl were, Lindahl was a treating physician. Blair was a surgeon.

[00:06:21] Speaker 01:
who she did not do surgery, but he had checked her out for the issues.

[00:06:27] Speaker 01:
And then there's other than Dr. Christ, who was the consultative examiner. He wasn't a treater, but he is the one who said that she could only sit for five hours in an eight hour day and had changed positions. So it provides the basis of that need to change positions.

[00:06:48] Speaker 01:
And when you get to the meta, the how this dovetails with her testimony about her limitations, her need to change positions more often than the ALJ accepted is consistent with these opinions of all of her treating and examining positions.

[00:07:08] Speaker 01:
The ALJ, the non-examining physicians evaluated her so long ago that it has very little weight under the law that applies here because they didn't ever review everything and they didn't review the file and they never examined her. So it has less weight. One of the things I should mention, regard to Judge Braver's question about the activities.

[00:07:42] Speaker 01:
There were some very vague and incorrect statements in the ALJ's decision about the type of activity she supposedly did. I mean, there was one in particular where the ALJ cited to her testimony from 2019 hearings. I reread that testimony, and it simply doesn't support his analysis.

[00:08:05] Speaker 01:
She never had the ability to do, to be active all day. I mean, there's nothing that contradicts that. Oh, and he relied quite heavily on work activity she did before the relevant time period, which doesn't really make any sense. He relies on evidence from 1998 and questions, well, then she went back to work after the surgery. Yes, she did. She kept working as long as she could. but that's not relevant to the issues in this case because it was from an earlier time period.

[00:08:39] Speaker 05:
Was the vocational expert asked whether if she had to move, Dr. Chris said, for example, she would probably have to alter position and change position during that four to five hour period due to chronic low back pain and rigged leg pain.

[00:08:56] Speaker 05:
Was the vocational expert asked whether if that were the case, she couldn't do these sedentary jobs?

[00:09:04] Speaker 01:
Yes, he was. And what did he say? He said, no, she couldn't. It's all about how often.

[00:09:12] Speaker 05:
It seems a little weird to me that some employer would say, you can't stand up and walk around for three minutes and come back.

[00:09:22] Speaker 01:
Well, it was the frequency that became the issue. So if she was doing it every 10 to 20 minutes, having to get up and change positions.

[00:09:29] Speaker 05:
Dr. Christian said that. He said you would probably have to alter position and change position. during that four to five hour period. He didn't say you have to do every five minutes.

[00:09:39] Speaker 01:
He did not. But how do you determine whether or not, what is that?

[00:09:43] Speaker 01:
One of the things that they have to take into account is the claimant's testimony about how often they're actually having to do it.

[00:09:49] Speaker 05:
But the ALJ just discounted that opinion the way he articulated it.

[00:09:56] Speaker 05:
He didn't buy that much, even that much.

[00:10:00] Speaker 01:
That's correct. He discounted Dr. Chris's opinion. just as because, but Dr. Christopoulos I think does support, it's consistent with her testimony about her actual limitations. He's got findings in his evaluation that show that at that time she was still having, you know, very uncomfortable changing positions even in her evaluation by him.

[00:10:26] Speaker 01:
With regard to the activity level, there really isn't evidence that contradicts her testimony about the limitations she was having and her need to change positions and her need to lie down. And it's commonly accepted that a person who's had three back surgeries and then a motor vehicle accident with a rollover, it's not unreasonable to expect that they might have to change positions to cope with their pain.

[00:10:56] Speaker 01:
There was also criticism of the fact that she had stopped taking medication. I'm sorry, go ahead.

[00:11:02] Speaker 05:
I'm sorry.

[00:11:04] Speaker 05:
It's really difficult dealing with you appearing virtually. I'm almost sorry we allowed you to do it. But anyway.

[00:11:09] Speaker 01:
I'm sorry, too. But it's a long drive.

[00:11:13] Speaker 05:
I know, but that's not much of a reason to tell you the truth.

[00:11:17] Speaker 05:
The... I forgot what I was going to say, so go ahead.

[00:11:24] Speaker 01:
So the...

[00:11:26] Speaker 01:
Actually, what I would like to do is reserve my time for rebuttal.

[00:11:30] Speaker 01:
And that way, if you come up that. Thank you.

[00:11:33] Speaker 00:
Good morning. May it please the court. Jeff Staples here for the commissioner who asks that you affirm the district court's judgment because substantial evidence supports the ALJ's findings of fact.

[00:11:57] Speaker 00:
McCulloch claimed that she was unable to work beginning in 2002, and the period under the ALJ's consideration here ended in 2015.

[00:12:08] Speaker 00:
During most of that time, McCulloch consistently reported that she didn't need any pain medication, routinely refused treatment, didn't follow up with treatment that was suggested, and said that she was doing a lot better than what she reported to the agency.

[00:12:27] Speaker 05:
So the ALJ- But she had actually four back surgeries, is that right?

[00:12:35] Speaker 00:
I believe so. I think several occurred before she stopped working. And so the ALJ considered that and said, well, you continued working after that. And although she said that she stopped working because of her impairments, other evidence suggested that she quit that job because she needed to spend more time with her kids-

[00:12:57] Speaker 05:
She had, as I understand it, a fusion back operation later on. I don't know exactly when. She had several different cortisone and steroid shots for pain at different times.

[00:13:12] Speaker 00:
Yes.

[00:13:12] Speaker 05:
Right.

[00:13:15] Speaker 05:
And, I mean, it seems irrefutable that she had a serious back problem, really serious. I mean, enough to have four back surgeries, which is an awful lot.

[00:13:28] Speaker 05:
almost unprecedented, and that she had other treatments for her back. I mean, sometimes she didn't follow through, and sometimes she did follow through, basically.

[00:13:42] Speaker 03:
Yes.

[00:13:43] Speaker 05:
So what is the medical evidence that the ALJ did rely on that demonstrated that she could sit for you know, five hours without getting up is what an amount. And that's what I understand the core of the dispute could be. Could she sit for five hours without moving around?

[00:14:02] Speaker 00:
Yeah, so.

[00:14:02] Speaker 05:
Or anybody can sit for five hours without moving around, but.

[00:14:07] Speaker 00:
Right.

[00:14:08] Speaker 00:
So I think that's a good question. And, you know, the ALJ took a look at Dr. Christ's opinion, which was the subject of the prior court remand.

[00:14:21] Speaker 05:
took another look at Dr. Christ, who I think that's where that kind of... But the part of Dr. Christ that he disapproved was the part when she said that without giving time or anything, she would probably have to alter position and change position during that four- to five-hour period. And he said he discounted that because he was relying on subjective pain complaints and because Dr. Weiss said otherwise. Dr. Weiss examined her once, as I understand it, and said, that she did not appear to be in much distress, and she smiled and laughed.

[00:14:54] Speaker 05:
And I don't know whether it makes any sense to think that people who are in pain don't smile and laugh.

[00:15:01] Speaker 05:
So that seemed to be the reason. He was relying on Dr. Weiss, largely. Is that accurate? Yeah, I think... Who was not a treating physician.

[00:15:10] Speaker 00:
That's correct, and neither was Dr. Christ.

[00:15:14] Speaker 05:
Okay, but the other two, but Lindahl and Blair were.

[00:15:18] Speaker 00:
Yes, so...

[00:15:20] Speaker 00:
Dr. Lindahl had an opinion that was similar to Dr. Christ. And so the ALJ kind of referred back to what the ALJ had said about Dr. Christ in reviewing Dr. Lindahl's opinion as well.

[00:15:33] Speaker 05:
Well, he said something at one point about he discounted it because it wasn't consistent with the RFC, but that's backwards, of course.

[00:15:41] Speaker 00:
Right. So I think the ALJ did, though, you know, explain why the medical records, you know, the treatment records, did not show that she was in the kind of condition that Doctors Christ and Lindahl opined.

[00:15:58] Speaker 05:
And Blair.

[00:15:59] Speaker 00:
And, yeah, so Dr. Blair was a treatment provider, but he thought that she would only be off work for three months following a surgery. So I think the ALJ did agree, yes, you could expect someone to, you know, need a three-month recovery period.

[00:16:15] Speaker 00:
And I think as you pointed out, it's worth noting, you know, the ALJ took seriously the fact that she's had these surgeries, that she has these conditions. The ALJ didn't take that lightly and found that she was limited to sedentary work, which is the lowest exertional level, with several additional limitations. So the ALJ did take that seriously.

[00:16:38] Speaker 00:
given so much of the other evidence showing that she wasn't taking, you know, even any pain medication for this allegedly disabling pain, and that's throughout the period under the ALJ's consideration, that those opinions didn't line up with that evidence.

[00:16:56] Speaker 02:
Counsel, I have two questions, but I'll start with one. So I'm reading here the...

[00:17:06] Speaker 02:
the determination about the number of jobs and the VE testimony. And the ALJ says, furthermore, with regard to the document, prepare and surveillance systems, monitor jobs, Mr. Harrington opined that they would accommodate someone who is standing two to three hours and seated for four to five hours would need to alternate position on occasion. And if you can refresh my memory, would those two positions have been enough to establish there were enough jobs in the economy?

[00:17:42] Speaker 00:
Yes.

[00:17:44] Speaker 00:
One of them had over 15,000 jobs nationwide, and one had over 7,000 jobs nationwide.

[00:17:52] Speaker 02:
And then the record, was there any more drilling down in the questioning of the VE, what he meant, what was meant by shifting position on occasion? Is there... Was that consistent with Dr. Christ's recommendation?

[00:18:09] Speaker 00:
My understanding is what the LJ was trying to do was take Dr. Christ's opinion and present it to the vocational expert, essentially, to see, you know, like you were asking about Judge Berzon, is this limitation actually, would the case turn on whether she needed to alternate positions? And the answer turned out to be no.

[00:18:30] Speaker 00:
You know, the ALJ did give, and I think, good reasons for discounting Dr. Chris' opinion about the need to alternate positions. But even if you accepted it, it wouldn't lead to a finding of disability. It wouldn't change the outcome of this case.

[00:18:43] Speaker 05:
So what do you understand the dispute to be about? That's where I've had trouble in this case. Where is the core of the... If there's not... Your opponent said, yes, the core question is whether the fact that she had to shift positions... and maybe lie down.

[00:19:04] Speaker 05:
He represented that there was an answer that said that she couldn't have jobs in the economy, and you say that's not what happened.

[00:19:12] Speaker 00:
So I think what this turns on is, do you believe her statements about how much pain she was in and how much she needed to lie down? Her allegation is she, you know... It's just about lying down.

[00:19:24] Speaker 05:
It's not about shifting positions.

[00:19:25] Speaker 00:
That's right. I mean, that's my understanding, you know, Councils, of course, can parse it different ways, but I understand it to be you have to believe her about what she says about her limitations.

[00:19:39] Speaker 05:
Did any doctor say that she would have to lie down?

[00:19:42] Speaker 00:
That she would have to lie down? I think, I mean, you've got Mr. Myers said that she could only do part-time work.

[00:19:56] Speaker 00:
Dr. Ghazi said less than sedentary. So I think she's not, you know, completely devoid of opinion support for her allegations. Though on the other hand, you know, going in favor of what the ALJ found, there was Drs. Gaffield, Hoskins, Anderson, Parker, Chalstrom, Postavoid, and Ether.

[00:20:18] Speaker 00:
So, you know, there are some opinions on both sides of this. So I think it does come down to, you know, When you're looking at what did the medical record show, what is the significance of her repeated failure to take almost any treatment for these allegedly disabled conditions?

[00:20:37] Speaker 05:
But that's not true. She had repeated surgery. She had cortisone shots.

[00:20:43] Speaker 05:
She may have not done some of the things they told her to do, but she did an awful lot.

[00:20:47] Speaker 00:
She did some things, that's right.

[00:20:49] Speaker 05:
I mean, major things.

[00:20:51] Speaker 00:
Right.

[00:20:51] Speaker 05:
Fusion back surgery.

[00:20:52] Speaker 00:
Yes, yes.

[00:20:54] Speaker 00:
And the ALJ took that seriously, found a very limited RFC, but there are also repeated mentions throughout the record, throughout the entire period, from 2002 all the way to 2015, where she's saying, I'm not having any of these problems. I'm not taking any medication at all for these conditions. And we go through those in our brief. These are not isolated instances.

[00:21:19] Speaker 00:
And so I think the question then becomes, any reasonable person look at this record and draw the same conclusions that the ALJ did?

[00:21:27] Speaker 02:
Council, I want to address one thing. So the ALJ did, in part, rely on the fact that Clement was working up until 2002, and that work didn't seem consistent with her subjective symptom testimony.

[00:21:48] Speaker 02:
Is that really relevant? And if not, does it matter?

[00:21:52] Speaker 00:
So she claimed that these back conditions were, you know, her main problem.

[00:21:59] Speaker 00:
And so I think it is relevant that she's had these going back several years prior to her alleged onset of disability.

[00:22:07] Speaker 05:
But she then had two more serious car accidents and she got pushed off the porch and she had another surgery and several other partisan shots and so on. I mean...

[00:22:20] Speaker 05:
It seems that what her condition was in 2002 is not really 2001, I guess, is not really the question.

[00:22:28] Speaker 00:
So I think one other thing that the ALJ did point out about the work activity in 2002 that makes it relevant is that she came to the agency and said, I had to stop working in 2002 because of my conditions. Then on another occasion, she revealed that she actually quit her job to spend more time with her kids.

[00:22:47] Speaker 02:
It seems to me. Right. There's some dispute about her condition between 2002 and 2003 when there was another accident. And I think part of the questioning here is because in a testimony related to the accident and whether the accident was cause of further problems, she was, I think the ALJ is representing, she indicated she was, the accident was a significant cause of further pain symptoms.

[00:23:17] Speaker 02:
But my question really is more to pre-2002, before the claimed period, right? There's some mention of her capabilities before then, which seemed to me irrelevant because it's certainly, she was not claiming disability for that period. And it certainly seems possible that if you have serious back problems, that they get progressively worse to the point at which at some point, at the start of the claim period, they have come to the point where she cannot work anymore.

[00:23:51] Speaker 02:
So the fact that she could work before the claim period seems to me to be legally irrelevant. And it just seems to me it's not a point that you're willing to concede, but I'm not sure why.

[00:24:04] Speaker 00:
I'm perfectly willing to concede that her work activity prior to the alleged onset of disability is of limited relevance. Okay.

[00:24:14] Speaker 00:
I do think it is important, though, you know, when you've got someone coming to the agency saying, I had to stop work in 2002 because of my conditions. You know, like you were saying, she's saying this is that point at which.

[00:24:30] Speaker 02:
It's a different question. I mean, I think that ALJ also points to the fact that she inconsistently testified as to the reason why she stopped working in 2002. I'm not trying to suggest that.

[00:24:42] Speaker 00:
Okay.

[00:24:42] Speaker 02:
And consistency is irrelevant. I'm just trying to question why the ALJ is relying on her, some evidence that she was able to keep working up until 2002.

[00:24:54] Speaker 00:
I think, you know, I think it's worth noting, you know, it's the ALJ is, this is a very comprehensive decision. The ALJ went through a lot of evidence and that was part of it. I think to the, you know, that maybe doesn't say much about her allegations of disability.

[00:25:13] Speaker 02:
And is there enough, are there enough clear and convincing reasons without that?

[00:25:18] Speaker 00:
100%, Your Honor. You know, starting with why did she stop working? And then when you do take the period under the ALJ's consideration, I think there are numerous inconsistent statements that she made, you know, back and forth about her activities, about the effect of the treatment that she had, how effective was it.

[00:25:40] Speaker 00:
You know, did treatment do anything to help you? You know, she repeatedly says no. The record repeatedly says yes.

[00:25:47] Speaker 00:
And so I think that the balance of the ALJ's findings definitely stand, you know, if you omit that consideration of the pre-alleged onset work activity.

[00:26:04] Speaker 00:
I see I'm just about out of time, but, you know, I think the ALJ – did a really nice job here of going through all the evidence and explaining why it didn't fully corroborate. You know, to Judge Berzon's point, it certainly did support a lot of limitations and they just didn't get over the line to disability because the vocational expert explained, you know, that a person with sedentary work and these other limitations could still do jobs. Even if you factor in Dr. Christ's opinion and Dr. Lindahl's opinion about the need to alternate positions, She's still not disabled.

[00:26:38] Speaker 00:
I think it's certainly the case that a reasonable person could look at these records and draw the same conclusions that the ALJ did. And that being the case, we would ask that the court affirm.

[00:26:51] Speaker 00:
Thank you.

[00:26:55] Speaker 02:
Thank you, counsel.

[00:27:01] Speaker 01:
I'd like to first address the issue of the vocational expert's testimony. They did testify that if the individual had to change positions every 10 minutes, that would eliminate all competitive work.

[00:27:13] Speaker 05:
Did any doctor say that you had to shift positions every 10 minutes?

[00:27:19] Speaker 01:
No, because that's actually not something that you can exactly predict exactly. Um, I, I, you know, the thing about pain is it's an individualized phenomenon. Dr. Ghazi actually agreed with that, that he could not get, he could not predict with any kind of precision, precision, what her shoulder limitations were or back limitations because you can't know every individual has a different tolerance of pain. Some people are going to be changing positions all day long and some people are going to be able to, okay.

[00:27:52] Speaker 01:
Um,

[00:27:53] Speaker 02:
So the finding that she would need to change position every 10 minutes comes down to the claimant's testimony. Is that correct?

[00:28:02] Speaker 01:
Yes, it does. And in addition, the finding or the issue regarding her need to lie down or need to take. I mean, the vocational expert said she had to take one extra 15 minute break per day. That would eliminate all the jobs he had described. And with the level of back pain she had, it's not.

[00:28:23] Speaker 01:
It's completely reasonable to expect that she would have had to do that. Now, with regard to pain medication, everyone is well aware that the medical profession is not like people being addicted to narcotic pain medications. And she chose not to be addicted to them anymore and figured she would just tough it out because she was unhappy being having to rely on the narcotic pain medications and which, you know, eventually they don't work.

[00:28:59] Speaker 01:
With regard to the, one of the challenges here is that there aren't any doctors who know whether, who actually said, who actually disagreed with her description of her pain or her description of her limitations. Even Dr. Weiss, who they rely on, for one thing, Dr. Weiss's opinion was in 2005, and she did not, she didn't have a really clear opinion that contradicted McCulloch's testimony.

[00:29:36] Speaker 01:
Dr. Blair, he actually did discography, which was, he did test, a procedure to determine whether or not there was her pain was, there was something he could do to fix her pain and determine that he couldn't. And that's why he did not do an additional surgery at that point.

[00:29:59] Speaker 01:
I don't really know what else to say here. The colic's been suffering in pain for a long time. For someone who had been through these surgeries and these accidents and to have The doctors who test her say that she's limited to sedentary work and then some, once Dr. Christ had her below sedentary, the ALJ's decision, oddly enough, doesn't even include a sit-stand option in his residual functional capacity assessment. Now, he added that in question to the vocational expert.

[00:30:30] Speaker 01:
Why it's not in the RFC assessment? Well, you'd have to ask the ALJ. Basically, he was repeating his RFC from his previous decision. And that's another issue I didn't really address here, but that's what he did here is he repeated, he was supposed to reevaluate all the evidence. He didn't do it. And as a result, it's the same decision again. And this person with all this pain is being disbelieved.

[00:30:55] Speaker 05:
Apparently.

[00:30:56] Speaker 01:
Or he supports her on that.

[00:30:57] Speaker 05:
I'm reading that Dr. Lindahl did say that she had to get up every 10 minutes.

[00:31:01] Speaker 01:
Is that not true? Thank you so much for finding what I'm not finding.

[00:31:11] Speaker 01:
Yes. And he was her treating physician. He had an experience with treating her multiple times. I mean, he didn't just see her once.

[00:31:24] Speaker 01:
If the court doesn't have any other questions, I ask you to reverse this decision. I think that this case has gone on much too long. I've I have a lot of cases that go on a long time. This is longer than any of them.

[00:31:37] Speaker 01:
And I don't think there's any doubt that at least since her application date here, or actually since 2003, she was completely unable to sustain full-time competitive employment. Thank you.

[00:31:52] Speaker 02:
Thank you.

[00:31:56] Speaker 02:
This matter is submitted. I believe we are adjourned for the day.

[00:32:01] Speaker 02:
All rise.

[00:32:15] Speaker 04:
The court stands adjourned until tomorrow morning at 9.30 a.m. Thank you.