Julie A. Toth - Page 3

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          petitioner fell from her horse during a stadium jumping clinic              
          and suffered a head injury which caused continuing episodes of              
          severe fatigue, mental apathy, dizziness, and nausea.2  Her                 
          illness resulted in permanent disability and caused her to lose             
          her job with Pfizer on May 9, 2000.                                         
               Petitioner is one of six individuals in the Pacific                    
          Northwest qualified to teach Eventing3 at the beginning novice,             
          novice, training, and preliminary levels.4  In 1998 petitioner              
          purchased 17 acres of land in Newberg, Oregon (Newberg property),           
          between Portland and Salem, Oregon, in an area well known within            
          the equestrian community for horse boarding, training, and                  
          lessons.                                                                    
               In 1998, petitioner began operating a horse boarding and               
          training facility upon the Newberg property for profit.  Although           
          income from the activities in 1998 was modest, it gradually                 
          increased as improvements were made to the Newberg property and             
          petitioner was able to hire additional staff.  By early 2004,               


               2 Petitioner was initially diagnosed with chronic fatigue              
          syndrome.  However, in June 2001, a cardiologist diagnosed her as           
          suffering from neurocardiogenic syncope, an incurable disease               
          caused by the nerve damage she suffered from her head injury.               
               3 Eventing is an Olympic sport made up of three disciplines            
          in which a horse and rider compete in dressage, stadium jumping,            
          and cross-country jumping.                                                  
               4 Eventing has six levels of difficulty which are in order             
          of difficulty:  Beginning novice; novice; training; preliminary;            
          intermediate; and advanced.                                                 





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