The following excerpt is from Valero v. Colvin, Case No. 1:13-cv-01815-SKO (E.D. Cal. 2015):
her past relevant work requires constant handling, although it is not clear there is a need for bilateral handling. In other words, testimony that a claimant who is limited to occasional overhead reaching on the left and only frequently handling on the right can nonetheless perform constant reaching and handling generally is the type of deviation that requires explanation and testimony from an expert. Prochaska v. Barnhart, 454 F.3d 731, 736 (7th Cir. 2006).
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