508 Tucker Telephone: 482-8506
Ashland, Oregon 97520
Licensed Clinical Psychologist
September 17, 1998
AFFIDAVIT OF DR. DAVID OAS
I, Dr. David Oas, being duly deposed and sworn to say as follows:
That I am a licensed clinical psycho lo gist in the state of
Oregon, practicing in Ashland, Oregon since 1973;
That I have over 25 years of experience, have achieved the
recognition of Professor Emeritus at Southern Oregon state
University, and have taught at the university for 30 years;
That I am a member of the American Psychology Association;
That I have testified in hundreds of child custody cases
throughout the state of Oregon with the best interests of the minor child always considered as the primary goal;
That on 9/12/97 I testified in the Court of Jackson County before
the Honorable Phil Arnold regarding the custody of Theodora (Teddy) Coutsoukis (DOB: 9/28/93), recommending that Photius Coutsoukis be the primary custodial parent of Teddy;
That the custody evaluation I conducted included psychological
evaluations of each parent as well as home visits with Ms. Samora and Teddy and with Mr. Coutsoukis and Teddy.
That the primary reason for my expert opinion was the strength of
Teddy's psychological and emotional attachment to her father;
That Teddy is an at risk child who has significant delays in
development and that I believe Mr. Coutsoukis is the best parent and best person to provide in-home parental care of Teddy with his capacity to use specific skill building strategies to offset the significant behavioral deficits she exhibits;
That such in-home care is preferable to out-of-home child care
for a child with Teddy's needs;
That since 6/12/97, during which time Teddy has been primarily
under the care of her mother, Susan Samora, with rninimal contact with her father, Photius Coutsoukis, Teddy's behavioral deficits have increased significantly, whereas before the separation she was progressing significantly;
That since the divorce, based on reports from special education
teachers in the Ossining Public School of Ossining, New York, and teachers from the Children's School for Early Development of Hawthorne, New York, Teddy has in fact shown regressive losses in cognitive, language, and physical development;
That I believe the best treatment strategies for Teddy, who is at
risk to live a life with mental and behavioral deficits which may include mental retardation, are as follows:
1. That custody of Teddy be modified with Teddy's father,
Photius Coutsoukis, as the primary custodial parent.
2. That Teddy's strength of attachment to her father is not
only psychological and emotional but that Mr. Coutsoukis is a best fit with his intuitive and scientific understanding of
3. That Mr. Coutsoukis recognizes the need for a comprehensive
early intervention program to offset what I believe are continuing traumatic, life-threatening stressors brought upon Teddy in her current living arrangement.
4. That the adaptive individual educational program from the
Ossining Public School and the Children's School for Early
Development lack comprehensiveness in the following ways:
a. the currently offered three individual 45 minute speech and
language therapy sessions, two individual occupational therapy sessions, and two individual physical therapy sessions are clearly inadequate for Teddy's special needs
b. The Children's School of 15 children utilizes aides who have
not had sufflcient training to provide direct strategies for working with Teddy's behavioral deficits
c. That I believe there is an absence of parent mentoring,
training, and the comprehensive follow-up of daily strategic early intervention strategies in speech and language, physical development, cognitive development, living skills, and social development between the Ossining School, the Children's School, and Teddy's home
5. That the most current research on early intervention
a. Long term brain deficits are known to be a consequence of traumatic life experience, especially in neonates, toddlers and
children the first three years and continuing through childhood. These deficits are even more pronounced if there are
b. These deficits are most strongly offset by comprehensive
early and immediate intervention that goes on seven days a week;
c. The most vital and directly effective intervention is a parent who has the knowledge of the specific skills to be applied and a strong emotional attachment to the child to offset environmental stressors;
intensity, breadth and duration of the application of
specifically developed individual educational programs has been shown to have the most significant effects for offsetting life long neurobiological consequences and life long mental
retardation. This means complete coordination between parent(s), school, and remedial specialists.
6. That Teddy's brain has its greatest plasticity in its early years. I believe the restrictions placed on Teddy's oppotunity to be with her most effective caregiver, her father, is criminal in that it has, in my opinion, contributed to very minimal gains in overcoming Teddy's developmental delays and if not already permanent, may lead to life long permanent deficits if not immediately resolved in court.
7. That I have reason to believe Ms. Samora has not been sufficiently committed to the comprehensive individual care Teddy needs from a parent.
8. That it is not in the best interest of Teddy Coutsoukis to remain in her current living arrangement nor in her
current remedial early intervention program.
I make this affidavit in support of the motion on file herein for
David A Oas, Ph.D.
SUBSCRIBED AND SWORN to before me this 17th
day September, 1998.
. . TRUTH METER
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