With no explanation, chose the best option from "A", "B", "C" or "D". (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

A: holding the alj may discredit complaints of claimant where inconsistencies appear in record
B: holding that an alj cannot discredit lay testimony solely because it is not supported by medical evidence in the record
C: 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
D: holding it is error for an alj to fail to consider factors relevant to the pain analysis which are supported by the record
B.