The trial court dismissed the plaintiff's first amended complaint against Washington County with prejudice. The plaintiff appealed, arguing the trial court erred in two ways: 1) in ruling the defendant did not have a duty to prevent the filing and maintenance of a false mental health report, and 2) in ruling the defendant did not have a duty to prevent foreseeable harm to deaf taxpayers caused by the lack of a deaf communication policy. The plaintiff asserts sufficient facts were presented to state claims and that the dismissal should be reversed to allow amendment of the complaint.

1. IN THE COURT OF APPEALS OF THE STATE OF ORGEON
ABBY JO OVITSKY,
Plaintiff-Appellant,
v.
JIM RYAN and CLAUDIA LOPEZ,
Defendants,
and
COMMONWEALTH REAL ESTATE SERVICES and WASHINGTON COUNTY SHERIFF'S
DEPARTMENT,
Defendants-Respondents.
Washington County Circuit Court
C153663CV
A161503
APPELLANTS' REPLY BRIEF AND EXCERPT OF RECORD
Appeal from the Judgment of Dismissal of
the Circuit Court for Washington County
dated January 27, 2016
The Honorable Andrew R. Erwin
Abby Jo Ovitsky
6900 SW 195th Avenue #133
Aloha, Oregon 97007
abby@parentadvocate.org
There is no telephone
6/2016

2. i
INDEX
STATEMENT OF THE CASE ..............................................................................................1
Restatement of the action and relief sought ............................................................1
Questions Presented on Appeal...................................................................4
a. Did the trial court err in ruling that as a matter of law defendant did
not have a duty to prevent the filing and maintenance for 10 (ten)
years of a completely false MHRT report?
b. Did the trial court err in ruling that as a matter of law defendant did
not have a duty to prevent foreseeable future damages to deaf
taxpayers in Washington County caused by Sheriff's deputies on
account of the absence of any official deaf communication policy?
Request for Judicial Notice......................................................................................4
Summary of Argument.............................................................................................5
Sufficient Factual Evidence Was Submitted to the Trial Court and Ignored............6
Preservation of Error................................................................................................6
Standard of Review..................................................................................................6
ARGUMENT........................................................................................................................7
CONCLUSION.............................................................................................................12

3. ii
TABLE OF AUTHORITIES
Cases:
Ashcroft v. Iqbal,129 S. Ct. 1937 (2009)...............................................Declaration, p. 14
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) ................................Declaration, p. 14
Buchler v. Oregon Corrections Div., 316 Or 499 (1993).....................................................7
Donaca v. Curry Co., 77 Or App 677 (1986)................................................................9, 10
Fazzolari v. Portland School Dist. 1J, 303 Or 1 (1987)........7, 10, 11, Declaration, p. 18,19
Finch v. Miller, 271 Or 271 (1975) ............................................................Declaration, p. 17
Flast v. Cohen, 392 U.S. 83 (1968)...........................................................Declaration, p. 21
Green v. Cox, 44 Or App 183, (1980). …..................................................Declaration, p. 17
Hansen v. Anderson, 113 Or App 216 (1992).......................................6, Declaration, p. 18
Hornbuckle v. Harris, 69 Or App 272, (1984) …........................................Declaration, p. 17
Johnson v. Lee, 15-789 S. Ct. (2016)..................................................................................3
Kerschner v. Smith, 121 Or 469 (1925).............................................Declaration, p. 17
Lawrence v. Arapahoe Sheriff MOU...........................................................................5
Masood v. Safeco, 275 Or App 315 (2015) …...................................................................3
Moss v. U.S. Secret Serv., 572F.3d 962 (9th Cir. 2009)...........................Declaration, p. 14
Martin v. Ziherl , 607 S.E.2d 367 (Va. 2005).............................................Declaration, p. 21
Neitzke v. Wìlliams, 490 U.S. 319 (1989)...........................................Declaration, p. 14
Ovitsky v. Beaverton School District et allia, USDC, 9th Cir. 14-35422.......................5
Ross v. Blake, 15-339 S. Ct. (2016)....................................................................................3
Shawn Patrick Lynch v. Arizona, S. Ct., No. 15-8366 (2016)..............................................3
Slogowski v. Lyness, 324 Or 436 (1996)...........................................................................11
Solberg v. Johnson, 306 Or 484 (1988)............................................................................11
Stewart v. Jefferson Plywood Co., 255 Or 605 (1970)......................................................11
Stringer v. Car Data Systems, Inc., 314 Or 576 (1992)........................6, Declaration, p. 18
State Statutes:
ORS section 19.010(1) ......................................................................Declaration, p. 12
ORS 19.205(1)...................................................................................Declaration, p. 12,
ORS §162.375..............................................................................................................1
ORS 30.265(1).................................................................................. Declaration, p. 19
ORS 659A...................................................................................................................7
ORS §90.322.....................................................................................Declaration, p. 24
ORCP 16C …..............................................................................Declaration, p. 16, 17

4. ORCP 21............................................................................................Declaration, p. 17
ORCP §21A(8) ...........................................................................................................1
Federal Statutes:
42 USC §12182(b) (2) (A) (iii)....................................................Declaration p. 6, 9, 25
Fed. R. Civ. P. 12(b)(6) ....................................................................Declaration, p. 14
Other Authorities
Oregon Constitution (2015), Article I, §20...........................................Declaration, p. 9
U.S. Constitution, Art. I, § 8, 478, 102, 88 S.Ct., 1954.......................Declaration, p. 21

5. 1
APPELLANTS' REPLY BRIEF AND EXCERPT OF RECORD
____________________________________
STATEMENT OF THE CASE
Restatement of the action and relief sought
[Sheriff Deputy] [Mateski] called MHRT [mental health response team] and initiated a
[false] report in violation of ORS §162.375 that will remain on file for 10 years (Exhibit 3 to
Plaintiff's First Amended Complaint “FAC”) when they knew it to be false as evidenced by
previous emails delivered to and read by defendants showing proof of a severe hearing
impairment, along with [social security and] OMMP records that do the same. Landlord then
quoted that MHRT report [in its "warning letter" which says it is "notice" dated July 27, 2015
[Exhibit 4][to FAC] to try to evict me [senior citizen, female, disabled] from a home I own
free and clear which is on their land. [ER-1 FAC], page 4. This report is discussed also in
the FAC on pages: 3, 4, 11 (footnote), 14, 16, 17, 18, 20, 32, 37 and on page 38. All of
these augments are completely ignored by opposing counsel.
This is an action against Washington County, erroneously sued herein as Sheriff's
Department, for initiating and maintaining a false MHRT report at taxpayer expense for ten
(10) years. The trial court granted defendant's motion to dismiss plaintiffs' FAC under
ORCP 21 A(8) for failure to state ultimate facts sufficient to constitute a claim. The trial court
states, on p. 4 of its January 27, 2016 dismissal with prejudice, "plaintiff has failed to either
state a legally cognizable claim, or to articulate facts sufficient to state the elements prima
facie case support [sic.] her enumerated claims." Appellant argues this is the court's

6. 2
personal opinion, not based on any fact, not founded on any legal basis and that it violates
her right to due process, including discovery and a jury trial. Justice requires that the case
be reversed and remanded as to Washington County, erroneously sued herein as Sheriff's
Department, because the dismissal WITH PREJUDICE is only based on a typo, not on any
legal basis.
Appellant again notes that no form was ever provided by the trial court, which then
pointed to wrong formatting to justify its summary dismissal. Plaintiff has in fact articulated
more than enough facts, with photos taken of the violations in question, sufficient to state
the elements of a prima facie case case to support her enumerated claims. The same court
tolerated multiple formatting errors from counsel, including the fact that Ms. McCormick is
not counsel of record and no substitution of attorney replacing Mr. Bennett, who is counsel
of record was ever filed or served. It is true that the sewer is fixed, it was not fixed until fall
2015, several months after appellant sued her landlord regarding the sewer and false
MHRT report. It is also true that appellant did not obtain the MHRT report until after the first
complaint was filed because Washington County “County” withheld it and only produced it
upon her FOIA request after long delays and excuses were exhausted.
Evidently Washington County is the correct party, fine, a new lawsuit can be filed,
however dismissal on the basis of what amounts to a typographical error when evidence of
wrongdoing by County was submitted is grounds for the requested reversal. “Sheriff's
Department” is the wrong party. The court erred in not allowing plaintiff to amend her
complaint to correct the name of the legally responsible party, when the County itself
pointed out what amounts to a typographical error, easily corrected, but for the trial court's

7. 3
error in not allowing it. There is plentiful new legal precedent for reversal under these
conditions, when administrative procedures (dismissal with prejudice for a typo) are the only
reason for the request. Ross v. Blake, 15-339 S. Ct. (2016) (case remanded). Johnson v.
Lee, 15-789 S. Ct. (2016) (case remanded). Shawn Patrick Lynch v. Arizona, S. Ct., No. 15-
8366 (2016) (case remanded, also discusses “future dangerousness” and “due process.”
Masood v. Safeco, 275 Or App 315 (2015) (reversed and remanded with directed verdict for
plaintiff, cross claims dismissed on appeal).
Plaintiff seeks reversal of the judgment dismissing the FAC with prejudice based on
what amounts to administrative convenience, apathy toward deaf taxpayers, County
misconduct and a typo naming “Sheriff's Department” instead of “County,” which
nonetheless replied, answered and lied in both pleadings to both courts, misrepresenting
material facts in the assertion that any proper procedure was ever followed.
Moreover, plaintiff has made County aware of clear proof that Deputy Mateski's
report is not a police report (the report itself so states, see ER8 to Appellant's Opening Brief
(OB), it is not a medical report (there is no licensed medical professional signature on the
report, no health exam was conducted, Deputy Mateski is not a licensed medical
professional), and it is factually incorrect as evidenced by the unedited Sprint call transcript
with the Sheriff's Department1
, dated June 30, 2016 (ER10 to OB). The County has no
authority to maintain the MHRT report for ten (10) years at taxpayer expense and to
1 Sheriff's Deputy Tim Mateski references this as a “telephone” call, but plaintiff had no
telephone, and he failed to verify that at the time. Sheriff's deputy omitted the nature of
the call (a sex harassment complaint about him while he was still outside) from of his
report dated the same day. County suppressed this evidence submitted as Exhibit E to
oral argument filed 10.26.15. Does sheriff deny this?

8. 4
continue to discredit a deaf plaintiff as somehow “mentally ill” because and only
because County prefers to yell at deaf instead of coming up with a policy for
meaningful communication with its deaf citizens. The first written complaint to County in
the form of an email dated July 2, 2015 (ER6-3-4 to OB). There was no element of surprise,
including a federal lawsuit regarding same issue, filed in 2013.
Questions presented on appeal
a. Did the trial court err in ruling that as a matter of law defendant did not have a duty to
prevent the filing and maintenance for 10 (ten) years of a completely false MHRT report?
b. Did the trial court err in ruling that as a matter of law defendant did not have a duty to
prevent foreseeable future damages to deaf taxpayers in Washington County caused
by Sheriff's deputies on account of the absence of any official deaf communication
policy? An acceptable example of a deaf communication policy for Sheriff is the
Arapahoe Sheriff's MOU previously submitted to County Counsel2
in 2014 and is a
public document, located on the Department of Justice website at
(http://www.justice.gov/iso/opa/resources/834201332117453273491.pdf.
Request for judicial notice
Since 2013, in now three different venues, this Appellant has repeatedly pointed County
to the Lawrence v. Arapahoe Sheriff MOU, also attached as ER11(5-6) to OB, and
asks the parties for local adoption of this as reasonable policy of
2 Ovitsky v. Beaverton School District et allia, USDC, 9th cir. 14-35422, D.C. No. 3:12-
cv-02250-AA, U.S. District Court for Portland Oregon.

9. 5
equally meaningful communication between deaf and sheriff, school district and other
locals having official business with deaf. As these are relevant public records, plaintiff
humbly requests this court take judicial notice of this previous filing now. Destruction of
the false MHRT filed June 2016 and adoption of this policy are the relief requested, in
addition to Appellant's costs of suit. Less than two years ago, USDC Portland District
declined to rule on substance. Plaintiff interprets this to mean the matter is not settled in
local courts. A new fact situation arose less than one year later, and she refiled in state
court. This appellant will pursue this issue for as long as it takes to obtain justice for
herself and for all hearing impaired persons similarly situated.
Summary of argument
Neither the parties nor the trial court invoked a status, a relationship, or a particular
standard of conduct that creates, defines or limits defendant's duty in this case. The
allegations in plaintiffs' pleading do not place this case in a category of claimants or claims
that require denial of plaintiffs' claim as a matter of law. A rational fact finder could find
defendant's conduct unreasonably posed a foreseeable risk to plaintiff, and that it poses a
reasonable risk of future harm. “Anyone who looks at the sheriff's computer records
and sees any “mental” report will not look at evidence if the report is still listed.”
(ER2-4 to OB). The allegations in plaintiffs' pleading are sufficient to state a common law
negligence claim. Appellant as plaintiff requested leave to amend the FAC for minor errors

10. 6
and the trial court erred in not allowing it. This argument is completely supported by this
courts own recent rulings as well as by recent United States Supreme Court rulings.
Sufficient Factual Evidence Was Submitted to the Trial Court and Ignored
Please refer to Appellant's Declaration in Support of this Brief submitted
contemporaneously.
Preservation of Error
Plaintiff assigns as error the trial court's granting of defendant's Motion to Dismiss.
Defendants-Respondents each moved to dismiss the FAC”. Plaintiff therefore preserved her
claim of error by opposing the motions, she filed two oppositions, one for each of the
Motions to Dismiss that was filed. The trial court granted Defendants' motions, as reflected
in the judgment of dismissal. (ER1).
Standard of Review
"Whether the complaint states a claim is a question of law." Hansen v. Anderson,
113 Or App 216, 218, 831 P2d 717 (1992). "In considering the sufficiency of plaintiffs'
complaint, we accept all well-pleaded allegations of the complaint as true and give
plaintiffs the benefit of all favorable inferences that may be drawn from the facts
alleged." Stringer v. Car Data Systems, Inc., 314 Or 576, 584, 841 P2d 1183 (1992).
(emphasis added).

11. 7
ARGUMENT
In Fazzolari v. Portland School Dist. 1J, 303 Or 1, 17, 734 P2d 1326 (1987), the
Oregon Supreme Court said that,
"unless the parties invoke a status, a relationship, or a particular standard of
conduct that creates, defines, or limits the defendant's duty, the issue of
liability for harm actually resulting from defendant's conduct properly
depends on whether that conduct unreasonably created a foreseeable
risk to a protected interest of the kind of harm that befell the plaintiff.
The role of the court is what it ordinarily is in cases involving the
evaluation of particular situations under broad and imprecise
standards: to determine whether upon the facts alleged * * * no
reasonable fact finder could decide one or more elements of liability for
one or the other party." (emphasis added).
In Buchler v. Oregon Corrections Div., 316 Or 499, 504, 853 P2d 798 (1993), the
Oregon Supreme Court further said:
"The general allegations of the complaint require this court first
to analyze whether a special relationship between the plaintiff and the
defendant is alleged to exist due to 'a status, a relationship, or a
particular conduct which creates, defines or limits the defendant's
duty.' Fazzolari v. Portland School Dist. No. 1J, supra, 303 Or at 19. 5
It is only when there is no such special relationship, status, or conduct
that Fazzolari's general foreseeability principle * * * comes into play.
Ibid."
Public bodies are ordinarily liable for the torts of employees acting within the scope
of employment under ORS 30.265(1). Plaintiff certainly named deputy Mateski as
employee of County (ER2-1 to OB). Defendant County erroneously sued herein as
Sheriff's Department in responding to this complaint never invoked any special

12. 8
relationship, status, or conduct which creates, defines, or limits defendant County's
duty to plaintiff as taxpayer to defendant County. Plaintiff asks for no special treatment,
only enforcement of existing federal ADA law for hearing impaired and deaf. The trial court
in this case did not invoke a special relationship, status, or conduct which creates, defines,
or limits defendant's duty. Plaintiff is not aware of special rules defining how a public body
must go about attempting to tell the truth when they file MHRT reports. Plaintiff in fact
could not hear Deputy Mateski and repeatedly told him she cannot hear and pointed
to signs on her door that explain her hearing impairment. He misreported in the
MHRT report that she did not want to listen (ER8 to OB). This is his personal opinion,
not fact. The property is posted with “video surveillance” “no trespassing” and
“private property” signs at the gate and on plaintiff's private doors (ER9 to OB).
Where is the video to backup his “report?”
Sheriff deputies are neither licensed audiologists nor medical experts. Tim Mateski
has had no special training in audiology qualifying him as an expert. Nobody else
examined plaintiff the day the report was written, June 30, 2015. There is no
supporting evidence for anything in the report, it is 100% gossip collected by
Mateski. The names of the alleged witnesses are also omitted. There are no photos, videos
or sound recordings. The MHRT report is therefore neither a law enforcement report
nor a health report and should not be protected and maintained at taxpayer expense

13. 9
for ten (10) years, when there is a credible fear of future harm from this false report
being on file as plaintiff continues to reside in the same residence. Plaintiff called a
non emergency number to have a meter maid enforce traffic. She did not call for “mental”
health “services.” Mateski yelled at plaintiff, he aggressively forced himself on her in her
own privately owned home and was not disciplined despite an immediate report to his
supervisor and at least two follow up reports. In Donaca v. Curry Co., 77 Or App 677, 714
P2d 265 (1986), the Court of Appeals held that a county did not have a common law duty to
maintain the grass height along a county road so as not to obstruct the vision of drivers at
an intersection with a private road. That decision was reversed in Donaca v. Curry Co., 303
Or 30, 734 P2d 1339 (1987). The complaint in Donaca had been dismissed by the trial court
for failure to state ultimate facts sufficient to constitute a claim for relief. The Supreme Court
said:
"[U]nless the plaintiff invokes such a specific legal source, 'no duty' is only a
defendant's way of denying legal liability for conduct that might be
found in fact to have unreasonably caused a foreseeable risk of harm
to an interest of the kind for which the plaintiff claims damages. "'No
duty' defenses are argued broadly or narrowly, as the occasion demands.
Sometimes 'no duty' excludes whole categories of claimants or of claims, for
instance economic or psychic loss caused by physical injury to another per-
son. At other times 'no duty' refers narrowly to an aspect of the particular
circumstances before the court. This often amounts to a claim that no rational
fact finder could find defendant's conduct unreasonably to prose a foresee-
able risk to the plaintiff but does not really assert any categorical rule." 303 Or
at 32-33 (citations and footnotes omitted).
Appellant argued in the FAC that defendants' actions pose a foreseeable risk

14. 10
because the report is likely to be taken at face value i.e., that she is “mental,” not severely
hearing impaired, despite being on Social Security Disability since 2009 for a severe
hearing impairment diagnosed by a licensed audiologist whose report was accepted by
federal judge Weir in 2009 and which defendant-respondents have all seen long ago, still
pretending they don't know the truth and continuing to misrepresent factual evidence to this
court. According to the Supreme Court in Donaca, the Court of Appeals was apparently
persuaded at least in part by policy considerations of the cost of controlling vegetation at
intersections. This resulted in the Court of Appeals adopting the categorical "no duty"
defense. The Supreme Court said, however, that these were ordinary issues of
negligence liability. That is, they were empirical questions to be decided by the fact
finder. To summarize the Supreme Court's guidance from Donaca, if the pleadings do not
constitute a basis for invoking the "special relationship" rule under Fazzolari, "no duty"
defenses are either broad, seeking exclusion of categories of claimants or claims; or
narrow, amounting to a claim in a particular case that no rational fact finder could find a
defendant's conduct unreasonably to pose a foreseeable risk to the plaintiff. It
is possible that the trial court in this case felt there were "cost" or "necessity" factors,
implicitly reasoning along the lines articulated by the Court of Appeals in the Donaca case.
If so, although such factors may be considered by the fact finder, they seem to have been
rejected by the Supreme Court in Donaca in the context of whether a claim has been

15. 11
stated. Appellant preserved her right to a jury as fact finder and still wants a jury trial
because this is an ongoing issue, she is still being stalked by one neighbor, the fictitious
MHRT report is still on file. Tim Mateski was never disciplined by County for his sexual
harassment of appellant. As a result of this horrible experience, for her own safety, she will
not open her door to any unidentified unscheduled person. There is still no policy in her
county where she pays a property tax for equal access to law enforcement that she
still does not get. If the basis for the trial court's "no duty" ruling was that no rational fact
finder could find defendant's conduct to pose a foreseeable risk to the appellant, it appears
to have been in error. Although a fact finder is free to reject imposing liability on
hearing the evidence, it cannot be said in advance that no rational fact finder, on the
allegations in plaintiff's pleading, could find defendant's conduct to pose a
foreseeable risk to plaintiff:
"A negligence complaint, to survive a motion to dismiss, must allege facts
from which a fact finder could determine (1) that defendant's conduct caused
a foreseeable risk of harm, (2) that the risk is to an interest of a kind that the
law protects against negligent invasion, (3) that defendant's conduct was
unreasonable in light of the risk, (4) that the conduct was a cause of plaintiff's
harm, and (5) that plaintiff was within the class of persons and plaintiff's injury
was within the general type of potential incidents and injuries that made
defendant's conduct negligent. Fazzolari v. Portland School Dist. 1J, 303 Or
1, 17, 734 P2d 1326 (1987); Stewart v. Jefferson Plywood Co.,
255 Or 603, 469 P2d 783 (1970)."
Solberg v. Johnson, 306 Or 484, 490-91, 760 P2d 867 (1988); see also Slogowski v.
Lyness, 324 Or 436, 441, 927 P2d 587 (1996). Appellant has pleaded facts from which a

16. 12
reasonable fact finder could make a determination in plaintiffs' favor in accordance with the
foregoing requirements. The trial court engaged in a knee-jerk dismissal with prejudice,
ignoring clear convincing evidence that the MHRT report is retaliatory, false, misleading, not
protected under existing laws or laws existing in 2015, and that it certainly constitutes a
credible foreseeable danger in the form of future harm as she continues to reside on
respondents' land in respondents' jurisdiction, Washington County.
CONCLUSION
The trial court erred when it ruled that the FAC failed to state ultimate facts sufficient to
constitute a claim. The Judgment of Dismissal should be reversed. Dated this 12th
day of
June 2016 in Aloha, Oregon.
Respectfully Submitted,
________________________________
Abby Jo Ovitsky
6900 SW 195th Avenue #133
Aloha, Oregon 97007
abby@parentadvocate.org
There is no phone

17. INDEX OF EXCERPTS OF RECORD
ER1 Order re Conduct of Hearing, 1 p.Judgment (TCF 22)
ER2 Model Policy: Lawrence v. Arapahoe County Sheriff, City of Englewood
ER 3 MHRT report
CERTIFICATION OF COMPLIANCE WITH BRIEF LENGTH AND TYPE SIZE
REQUIREMENTS
Brief length
I certify that (1) this brief complies with the word-count limitation in ORAP 5.05(2)(b) and (2)
the word count of this brief (as described in ORAP 5.05(2)(b)) is 10,955 words, including
indices the accompanying APPELLANTS' DECLARATION IN SUPPORT OF REPLY
BRIEF AND EXCERPT OF RECORD and proof of service. “whole document” and using
the word-count feature of the computer software I used to write and type this document by
myself.
Type size
I certify that the size of the type in this brief is not smaller than 14 point for both the text of
the brief and footnotes as required by ORAP 5.05(2)(d)(ii) and 5.05(4)(g).
________________________________
Abby Jo Ovitsky, Plaintiff-Appellant

18. PROOF OF SERVICE
I certify that on the 13th
day of June, 2016 the original foregoing APPELLANTS' REPLY
BRIEF AND EXCERPT OF RECORD and APPELLANTS' DECLARATION IN SUPPORT
OF REPLY BRIEF AND EXCERPT OF RECORD were deposited in the United States Post
Office at Aloha, Oregon, with first class postage prepaid thereon addressed to:
Appellate Court Administrator
Appellate Courts Records Section Records Section
1163 State Street
Salem OR 97301-2563
I further certify that on the 13th
day of June, 2016 two (2) copies of the foregoing
APPELLANTS' REPLY BRIEF AND EXCERPT OF RECORD were deposited in the United
States Post Office at Aloha, Oregon, with first class postage prepaid thereon addressed to:
Jeffrey S. Bennett
850 NE 122 Avenue
Portland, Oregon 97230
Phone: 503-255-8795
Attorney for Commonwealth, Jim Ryan and Claudia Lopez, “The Commonwealth
Defendants”
Elmer M. Dickens Jr.
Sr. Assistant County Counsel
155 N First Avenue, Suite: 340
Hillsboro, OR 97124-3072
Phone: 503-846-8747
Attorney for Washington Counsel, erroneously sued herein as “Sheriff's Department”
________________________________________
Abby Jo Ovitsky
6900 SW 195th Avenue #133
Aloha, Oregon 97007
abby@parentadvocate.org
There is no telephone