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 findings with respect to that evidence. Petitioners _ assertion
 that the Administrator disregarded the ALJ's credibility findings
 with respect to the witnesses and evidences Pet. 42e incorrectly
 describes both the ALJ_s findings and the respective
 Administrators' reviews of the record° Firsts the ALJ made no
 specific findings regarding credibility. Rather_ he briefly
 summarized the general background or professional qualifications
 of particular witnesses to the extent it was relevant to the
 testimony. Second, the Administrator's review of the evidence
 for sufficiency did not present the kind of credibility question
 that would require deference to the ALJ's observations. To set
 forth substantial evidence in support of his findings_ the
 Administrator first had to determine the basis for the witnesses _
 conclusions about the medicinal value of marijuana and evaluate
 the witnesses' respective qualifications to draw those
 conclusions° Thus_ the Administrator's independent review of the
 facts relevant to these two issues was proper.
 Petitioners also cite the Administrator's assessment of the
 reliability of testimony from patients and their families as
 evidence of improper bias against the lay witnesses. See
 discussion in Final Order If, 57 Fed° Reg. at i0_502.
 Petitioners, however, cannot reasonably dispute the
 Administrator's observation that patient testimony has no
 evidentiary value outside the context ef extensive clinical
 studies controlled for the placebo effect and biased observation.
 In additions the Administrator _s justifiably concerned about the

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