thank you your honor night krishi a courtesy relative to the pandemic my name is john seidlitz honored to be before the court representing my client die on on applied for social security disability benefits and was denied those benefits and this appeal as follows i would request two  fifteen she went through the normal process ultimately having an administrative hearing at up to the administrative hearing that found the only severe d major depression anxiety none of those were incorporated they were not reviewed in step three the list of impairment and they were  not submitted to the vocational consultant as part of the residual functional capacity under step four this is the critical air i believe it is a fatal error to the about this is well but there seemed to be confusion in this case about dr newman because it seems that the government thinks he didn't start treating your client until i think july th team but actually there are notes from  depression including i am not certain the defendant ignored the initial examination by dr newman and focused only on the july one reference a most identical findings throughout the whole treatment and so in terms of justifying why we ignore dr newman and then later discount dr newman's findings by suggesting something something that might be new i don't know but a defendant argues that it was properly ignoring the doctor when when he found it made on had  normal attention focus and recall she presented the healthcare providers as pleasant cooperative alert and no apparent distrust that is the whole basis discount all of the mental health care providers that she was doesn't cooperate to alert normal attention and focus and there is no one in the medical reviews including the physicians that social security hires to do records reviews that indicate those findings allow position to rule out severe anxiety severe depression  mental issues in terms of objective findings but here the doctor found a severe level of anxiety that was the beck anxiety inventory of twenty seven by dr mahoney who did a disability exam for social security twenty seven indicating gear level of things so this is not a case where we do not have  you know she put on a cheery things to see the doctor so therefore she must not be having severe anxiety even though the doctor does not mind that i think i think what we have is a situation where the the vocational consultant and as the court is is well aware that you have to include all of the their impairment into the punctual capacity if the vocational consultant testimony can be relied upon so mean that she would be on able to work at least three days a month right that's exactly right that's exactly right and one of the other positions over the  some clinical social worker oh also said there was an inability to sustain this and neither of those were submitted or incorporated into the l g s opinion relied upon and in fact is no  dr newman statement that did give more details that she would miss work at least three times a week but as i understand it the appeals council rejected that opinion on the basis that it did not relate to the period at issue we've been talking here but that's a different issue i mean and you can come up with it with a new argument about why they should have rejected it all they said that was if the rug takes which is wrong because he says it goes back into the period  i think that your argument not anything they ever said if i'm understanding  chores and other tasks are judged goo highlighted in that that quote the ala j it more and other evidence showing the difficult face in every gay life close quote  of diagnoses and they look and it's listed what's there or has been there but we have no way to correlate r t l jay has no way to correlate it to this time period this air period being reviewed because we don't know where have a minute left here and i should be more time than i need in terms of the reference about objective medical evidence when we're dealing with the mental issues that's seldom available we do have a disability exam by dr mahoney who did a back anxiety inventory found a scale of twenty seven this is a disability exam not a treating finding racing heart trembling and shaking in the justin and so in terms of findings the doctors findings newmans were consistent both with me as well as the clinical social worker who had twenty three sessions with this woman so this is not a function of the doctor just having to visit there there is plenty of evidence in front of the  sixteen when she talks about what she does if she goes to the grocery store she has to sit in her car and do breathing exercises so she can go in if she goes to walmart i feel like i'm being judged nervous it's better if i have somebody with me otherwise it's really hard for me to do anything by myself so this is not a function of a woman who has just a modest impact on her activities  daily living she's she needs someone to escort her to the grocery store that should have been included it should have been analyzed by the l g a so that we don't have two layers of the court having to do deal with these arguments if it properly reviewed this if that would have been done it would have saved a ton of time and a ton of paper i certainly appreciate the court listening thank you very much thank you counsel once again thing folks