; Malherek v. Comm'r of Soc. Sec. Admin., No. CV-18-00409-TUC-CKJ (DTF), 2019 WL 5078223, at *6-8 (D. Ariz. June 5, 2019), adopted by No. CV-18-00409-TUC-CKJ, 2019 WL 4686631 (D. Ariz. Sept. 26, 2019); Jones v. Berryhill, No. ED-CV-17-1138-AS, 2018 WL 3956479, at *3 (C.D. Cal. Aug. 15, 2018).