Page 1 - DECLARATION OF ALLISON WOITALLA IN SUPPORT OF DEFENDANTS'

MOTION FOR EXTENSION OF TIME TO FILE A WAIVER OF SERVICE

AW4/ssp/6817261-v1

Department of Justice

1162 Court Street NE

Salem, OR 97301-4096

(503) 947-4700 / Fax: (503) 947-4791

ELLEN F. ROSENBLUM

Attorney General

ALLISON WOITALLA #113494

ANDREW HALLMAN #083480

Assistant Attorneys General

Department of Justice

1162 Court Street NE

Salem, OR 97301-4096

Telephone: (503) 947-4700

Fax: (503) 947-4791

Email: Allison.Woitalla@doj.state.or.us

Andrew.Hallman@doj.state.or.us

Attorneys for Defendant Oregon Department of Corrections

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

KONRAD GARCIA,

Plaintiff,

v.

RAMONA PERRAULT; KATE BROWN;

TED WHEELER; K. SCHAECHER;

BETHANY SMITH; JOHN DOE(S) Parole

Board Member 2010 thru 2015;

JANE DOE(S) Parole Board Member 2010

thru 2015; KIM BROCKAMP;

COLETTE PETERS; STEVE SHELTON;

DEPARTMENT OF CORRECTIONS, et al. ,

Defendants.

Case No. 2:15-cv-00419-PK

DECLARATION OF ALLISON WOITALLA

IN SUPPORT OF DEFENDANTS' MOTION

FOR EXTENSION OF TIME TO FILE A

WAIVER OF SERVICE

I, Allison L. Woitalla, declare:

Case 2:15-cv-00419-PK Document 10 Filed 09/28/15 Page 1 of 3
Page 2 - DECLARATION OF ALLISON WOITALLA IN SUPPORT OF DEFENDANTS'

MOTION FOR EXTENSION OF TIME TO FILE A WAIVER OF SERVICE

AW4/ssp/6817261-v1

Department of Justice

1162 Court Street NE

Salem, OR 97301-4096

(503) 947-4700 / Fax: (503) 947-4791

1. I am an attorney licensed to practice law in the State of Oregon and an Assistant

Attorney General for the Oregon Department of Justice.

2. Defendants’ current deadline for filing a Waiver of Service is September 28,

2015. The Oregon Department of Justice has not yet received written requests for representation

from each of the named Defendants.

3. Before appearing on behalf of State Defendants, the Oregon Department of

Justice must contact all Defendants and obtain written requests for representation pursuant to Or.

Rev. Stat. § 30.285. This cannot be accomplished by the current deadline.

4. By the accompanying Motion, the Oregon Department of Justice respectfully

requests additional time, up to and including October 28, 2015, to obtain authorization to

represent the named Defendants before waiving service on their behalf.

5. This Motion for Extension of Time constitutes a limited appearance by the State

as it does not consent to suit in federal court.

6. This motion is made in good faith and not for the purpose of delay.

I declare under penalty of perjury that the foregoing is true and correct.

EXECUTED on September 28 , 2015.

s/ Allison Woitalla

ALLISON WOITALLA

Honors Attorney

Case 2:15-cv-00419-PK Document 10 Filed 09/28/15 Page 2 of 3
Page 1 - CERTIFICATE OF SERVICE

AW4/cbh/6774557-v1

Department of Justice

1162 Court Street NE

Salem, OR 97301-4096

(503) 947-4700 / Fax: (503) 947-4791

CERTIFICATE OF SERVICE

I certify that on September 28 , 2015, I served the foregoing DECLARATION OF

ALLISON WOITALLA IN SUPPORT OF DEFENDANTS' MOTION FOR EXTENSION OF

TIME TO FILE A WAIVER OF SERVICE upon the parties hereto by the method indicated

below, and addressed to the following:

Konrad Garcia

SID # 4871332

Snake River Correctional Institution

777 Stanton Blvd.

Ontario, OR 97914

Plaintiff pro se

HAND DELIVERY

X MAIL DELIVERY

OVERNIGHT MAIL

TELECOPY (FAX)

E-MAIL

E-SERVE

s/ Allison Woitalla

ALLISON WOITALLA # 113494

ANDREW HALLMAN #083480

Assistant Attorneys General

Trial Attorneys

Tel (503) 947-4700

Fax (503) 947-4791

Allison.Woitalla@doj.state.or.us

Andrew.Hallman@doj.state.or.us

Of Attorneys for Defendant Oregon Department

of Corrections

Case 2:15-cv-00419-PK Document 10 Filed 09/28/15 Page 3 of 3