The following excerpt is from Fried v. Sullivan, 943 F.2d 55 (9th Cir. 1991):
2 Because the final decision in this case was rendered prior to expiration of the statutory pain standard formerly codified at 42 U.S.C. 423(d)(5)(A), the Gamer-Cotton-Varney subjective pain standard applies. See Bates v. Sullivan, 894 F.2d 1059, 1071 (9th Cir.1990).
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