1 – DECLARATION OF DAVID H. GRIGGS IN SUPPORT OF 

 PLAINTIFF’S SECOND UNOPPOSED MOTION FOR EXTENSION

 OF TIME TO RESPOND TO FEDERAL DEFENDANTS’ MOTION 

 FOR SUMMARY JUDGMENT

GRIGGS LAW GROUP, P.C.

4900 SW Griffith Dr., Ste. 165

Beaverton, OR 97005

David H. Griggs, OSB No. 982436

e-mail: david@griggslawpc.com

GRIGGS LAW GROUP P.C.

4900 SW Griffith Dr., Ste. 165

Beaverton, OR 97005

Telephone: (971) 228-8110

Fax: (971) 327-6735

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF OREGON

PORTLAND DIVISION

ANDREA OLSON, an individual 

 Plaintiff, 

v. 

UNITED STATES OF AMERICA, by 

and through the Department of Energy 

and Bonneville Power Administration; 

and JAMES RICHARD PERRY, 

Secretary of the Department of Energy, 

 Defendants.

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Case No.: 3:15-cv-02216-HZ

DECLARATION OF DAVID H. GRIGGS IN 

SUPPORT OF PLAINTIFF’S SECOND 

UNOPPOSED MOTION FOR EXTENSION 

OF TIME TO RESPOND TO FEDERAL 

DEFENDANTS’ MOTION FOR SUMMARY 

JUDGMENT

I, David H. Griggs, do declare and say: 

1. I am one of the attorneys for Plaintiff in the above-mentioned matter.

2. I have prepared this declaration in support of Plaintiff’s Second Unopposed Motion for 

Extension of Time to Respond to Federal Defendants’ Motion for Summary Judgment. 

/ / /

Case 3:15-cv-02216-HZ Document 107 Filed 01/19/18 Page 1 of 3
2 – DECLARATION OF DAVID H. GRIGGS IN SUPPORT OF 

 PLAINTIFF’S SECOND UNOPPOSED MOTION FOR EXTENSION

 OF TIME TO RESPOND TO FEDERAL DEFENDANTS’ MOTION 

 FOR SUMMARY JUDGMENT

GRIGGS LAW GROUP, P.C.

4900 SW Griffith Dr., Ste. 165

Beaverton, OR 97005

3. Defendant hereby requests an order allowing a 10-day extension of time from 

February 2, 2018, up to and including February 12, 2018, to file Plaintiff’s Response to 

Federal Defendants’ Motion for Summary Judgment.

4. Plaintiff seeks this extension of time for the following reasons: 

(a) Plaintiff filed a Motion for Extension of Time and Motion for Appointment of 

Counsel with the court on December 1, 2017.

(b) Defendant filed a Motion for Summary Judgment with the Court on December 4, 

2017. On that date the Court issued an Order granting Plaintiff’s Motion for Extension of Time 

and denying Plaintiff’s Motion for Appointment of Counsel. Also on that date, the court set the 

deadline for Plaintiff’s Response to Defendants' Motion for Summary Judgment to January 3, 

2018. 

(c) Plaintiff retained me as counsel on December 22, 2017.

(d) The same day, December 22, 2017, I conferred with counsel for Federal 

Defendants, James Cox, requesting 30 additional days to respond to Federal Defendants’ Motion 

for Summary Judgment. Mr. Cox agreed to the request. 

(e) On December 26, 2017, I filed a Notice of Appearance of Counsel for Plaintiff in 

this case and also filed an Unopposed Motion for Extension of Time to Respond to Federal 

Defendants’ Motion for Summary Judgment.

(f) On December 30, 2017, the Court issued an Order granting Plaintiff’s Motion for 

Extension of Time and set the deadline for Plaintiff’s Response to Defendants' Motion for 

Summary Judgment to February 2, 2018.

(g) We have been gathering the materials for this matter since our initial engagement 

and the volume of documents relevant to it is extensive. We have been diligently working on 

Case 3:15-cv-02216-HZ Document 107 Filed 01/19/18 Page 2 of 3
3 – DECLARATION OF DAVID H. GRIGGS IN SUPPORT OF 

 PLAINTIFF’S SECOND UNOPPOSED MOTION FOR EXTENSION

 OF TIME TO RESPOND TO FEDERAL DEFENDANTS’ MOTION 

 FOR SUMMARY JUDGMENT

GRIGGS LAW GROUP, P.C.

4900 SW Griffith Dr., Ste. 165

Beaverton, OR 97005

become familiar with the facts of the case, and preparing the response, but are concerned that we 

do not have time to prepare an adequate response in time by February 2, 2018. Therefore, we are 

requesting an extra ten days, to February 12, 2018. We will not seek another extension of time. 

(h) On January 18, 2018, I conferred with counsel for Federal Defendants, James 

Cox, requesting 10 additional days to respond to Federal Defendants’ Motion for Summary 

Judgment. Mr. Cox agreed to the request. 

DATED this 19th day of January, 2018.

GRIGGS LAW GROUP, P.C.

By: /s/David H. Griggs

David H. Griggs, OSB No. 982436

e-mail: david@griggslawpc.com

4900 SW Griffith Dr., Ste. 165

Beaverton, OR 97005

Telephone: (971) 228-8110

Fax: (971) 327-6735

Trial Attorney: David H. Griggs

Case 3:15-cv-02216-HZ Document 107 Filed 01/19/18 Page 3 of 3