(9th Cir.2009)). The ALJ also identified affirmative evidence suggesting that Watkins was malingering. See id.; Carmickle v. Comm’r, Soc. Sec. Admin., 533 F.3d 1155, 1160 (9th Cir.2008). 2. The ALJ found lay witness evidence from Watkins’ mother and a friend of limited value because the daily activities the witnesses described were not consistent with someone who was unable to work. This is a germane reason for discounting the lay evidence. See Carmickle, 533 F.3d at 1163-64. The ALJ also discounted the mother’s testimony because it was not based on medical testing, and the friend’s third-party report because it did not discuss treatment or aggravating/precipitating factors. Even assuming that these reasons were not appropriate, see Bruce v. Astrue, 557 F.3d 1113, 1116 (9th Cir.2009) (<HOLDING>) and Tobeler v. Colvin, 749 F.3d 830, 833 (9th
holding that an alj is entitled to rely on vocational experts testimony that is based on assumptions that are supported by evidence in the record holding it is error for an alj to fail to consider factors relevant to the pain analysis which are supported by the record holding that an alj cannot discredit lay testimony solely because it is not supported by medical evidence in the record holding the alj may discredit complaints of claimant where inconsistencies appear in record holding that the alj did not err in discounting a claimants reports of pain where they were not supported by the medical record