THE UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON FILED31 OCT '1712:46USDC-ORP 

ANDREA OLSON 

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 

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

2nd UNOPPOSED MOTION FOR 

EXTENSION OF DISCOVERY 

v.DEADLINE 

Andrea Olson, the Plaintiff, respectfully moves for an additional thirty day extension to the 

discovery deadline, from November 1, 2017 to December 1, 2017. One of Ms. Olson's POA's, 

Dana Hoffman, acting on Ms. Olson's behalf has conferred with James E. Cox, Jr., Assistant 

United States Attorney for the Federal Defendants. Mr. James E. Cox, Jr., has informed the 

Plaintiff and her POA that the Federal Defendants do not oppose this motion. 

Attorney Ivan Resendiz-Gutierrez filed an amended complaint in March 2017 (ECF 56) on 

behalf of Ms. Olson via a limited /special court order (ECF 53) which added the United States of 

America and the Secretary of Energy as Defendants in this case based on violations of the 

Americans with Disabilities Act and Family Medical Leave Act. In July, 2017, the Court set a 

case schedule that included a discovery cut-off of October 2, 2017. (ECF 87) 

However James E. Cox, Jr. counsel for Defendants was on a lengthy paternity leave until August 

26, 2017. Because of this absence, Mr. Cox was unable to complete the necessary preparation to 

hold Plaintiff/ Ms. Olson's deposition in the case in September 2017, as contemplated by the 

current case schedule. Both the Plaintiff and Defendants agreed upon a 30 day extension. Mr. 

Case 3:15-cv-02216-HZ Document 91 Filed 10/31/17 Page 1 of 11
Cox filed the motion on October 2, 2017 (ECF 88) and that motion was granted on October 3, 

2017 (ECF 90) putting the new deadline being due on November 1, 2017. 

During that time Ms Olson's POA/ Ms. Hoffman had to undergo an unexpected breast cancer 

surgery. Due to the unexpected circumstances, Mr Cox was unable to complete the deposition on 

Ms. Olson because of these unforeseen set of circumstances. 

Plaintiff Ms. Olson and one of her PO A's Ms. Hoffman after conferring with the Defendants' 

Attorney Mr. Cox, were able to reach an agreement to a deposition date. An additional 30 day 

extension of the current discovery deadline to December 1, 2017 will help allow this disposition 

to take place. 

Furthermore, an extension would not result in any delay in trial or other pre-trial deadlines, as the 

deadline for dispositive motions is not until December 4, 2017. (ECF 87) With the exception of 

the Expert Disclosure due on November 5, 2017 which both parties have agreed upon would be 

due the same date December 1, 2017 as the discovery date that we are asking for in this motion, 

therefore there still would not be a delay on any other deadlines that have been scheduled. 

WHEREFORE, Ms. Olson respectfully requests that the Court grant this 2nd unopposed motion 

to extend the discovery deadline in this case from November 1, 2017 to December I, 2017. 

Dated this 31st day of October 2017. 

Respectfully Submitted, 

Plaintiff I Andrea Olson 

3404 SW Comus St 

Portland, Oregon, 97219 

(503) 452-8888 

andrea.olson8888@gmail.com 

Craig Butler/PO A for Plaintiff Ms. Olson 

Case 3:15-cv-02216-HZ Document 91 Filed 10/31/17 Page 2 of 11
IN THE DISTRICT COURT OF THE STATE OF OREGON 

FOR THE COUNTY OF MULTNOMAH FILED31OCT'1712:46!.JSDC-ORP 

ANDREA OLSON 

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 

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

CERTIFICATE OF DOCUMENT 

PREPARATION AND 

FILING OF COURT DOCUMENTS 

You are required to truthfully complete this certificate regarding the documents you are filing with the 

court. 

Check all boxes and complete all blanks that apply: 

_X_ I selected these documents for myself, and I had assistance filling them out with my POA without 

paid assistance. 

_I paid or will pay money to----------for assistance in preparing these 

documents. 

_ X _ The documents referred to are entitled: I, Andrea Olson, the Plaintiff to the above case suffer from 

a mental illness. I do not have an attorney. I have two POA's to assist me with all my needs. I am filing 

(3) documents with the District Court Of Oregon. 

1) 2°d Unopposed Motion For an Extension to File Discovery v. Deadline 

2) Unopposed Motion For an Extension to File Expert Disclosure v. Deadline 

3) Medical documentation 

I, Andrea Olson, the Plaintiff to ~e above case have assisted my PO A's in the contents that I wanted 

placed in the first two court documents. Neither of my PO A's are entitled to payment for their 

Case 3:15-cv-02216-HZ Document 91 Filed 10/31/17 Page 3 of 11
P "\j<, Lf of{ (] 

assistance. Neither of my POA's are Attorneys. Neither of my POA's have offered legal advice. 

As this court has repeatedly denied me assistance for the purposes of reasonable accommodation as 

well as indigence, I am submitting a third document from the treating medical provider detailing my 

current mental health status for the record. The court and opposing counsel are both privately in 

possession of additional medical documentation from two additional medical providers (that the court 

appears to have ignored). 

Dated: October 31, 2017 

Signature:-..S.~"----------------- !!L-----

] '-{D y s v! G {IA- lAi .r rr fdf2,,,"k-' N 0 0 re r 7 J. ( r 

Address or Contact Address City, State, Zip 

Telephone or Contact Telephone 

POA's Name(s) 

POA's Name Filing these documents on my behalf: Craig Butler 

POA's Name Assisting me with filling out the two stated documents: Dana Hoffman 

My POA's telephone number: 318-533-2818 

Case 3:15-cv-02216-HZ Document 91 Filed 10/31/17 Page 4 of 11
October 3th 2017 

Re: Andrea Olson DOB 8/22/1964 

First seen December 15th 2015 for treatment related to diagnostics below. 

I continue to see Andrea on a weekly basis except for time when she was in residential 

and outpatient treatment. Her mental and emotional health continues to be severe and 

she is limited in her ability to navigate the basic daily requirements of functioning in 

order to care for herself. Her cognitive functioning is impacted by her intense 

experiences of interpersonal distrust and paranoia related to seeking treatment and her 

navigating her ongoing legal process. She is unable to regulate her emotions of both 

anger and crying in relational interactions. Client wears hearing aids and reports 

congenital legal deafn~ess. 

F34.1 Persistent depressive disorder, severe, late onset, With intermittent major 

depressive episodes, with current episode severe with psychotic features, 

paranoia 

F43.10 Posttraumatic stress disorder 

Z56.9 Other problem related to employment 

Termination of fulltime employment from professional career 

Z65.3 Problems related to other legal circumstances 

Ongoing legal processes, with stressful and overwhelming circumstances 

Page 1 of2 

Case 3:15-cv-02216-HZ Document 91 Filed 10/31/17 Page 5 of 11
Z60.5 Target of adverse discrimination or persecution 

Current and lifelong impact of discrimination and insidious trauma due to 

"cultural ableism" because of her atypical hearing (lack of/ legal deafness)) 

present since birth. 

GAF45 

Margaret Eichler PhD LPC NCC ACS 

Individual, Child and Family Therapist 

503-956-7398 

dr-meichler.com 

resona ncecou nsel i ng@msn.com 

Licensed Professional Counselor Oregon #C2058 

Nationally Certified Counselor #47334 

NPI number #1477703452 

Nationally Approved Clinical Supervisor #ACS00851 

EIN # 87-0792980 

Page 2 of2 

Case 3:15-cv-02216-HZ Document 91 Filed 10/31/17 Page 6 of 11
-6 iPwOVIDENCE W Health & Services 

Providence St. Vincent Hospital 

Providence St. Vincent Medical Center 

9205 SW Barnes Road, Suite 333 

Portland, OR 97225 

October 28, 2016 

Regarding Andrea Olson vs MBO Partners, INC 

3: 15-CV-02216-HZ 

To Whom It May Concern: 

Tel: 503.216.3591 

Fax: 503.216.3583 

I am the treating physician for Andrea Olson. She has been hospitalized at Providence St. 

Vincent Hospital since October 13, 2016. 

Because of her mental health conditions she is unable to participate in proceedings before the 

court. I do not have an estimate as to when she will be able to proceed. Please excuse her from 

the proceedings. Her absence from the proceedings is medically necessary. 

My understanding is that she has been representing herself in court. Because of the degree of 

distress she is experiencing it is my medical opinion that she is unable to continue to do so. She 

has asked that I request that the court provide her with legal counsel to assist her. I do think that 

this request is appropriate, and ask that the court provide her with legal counsel to assist in the 

proceedings. 

I do feel that the absence from the proceedings and the assistance of legal counsel are 

medically necessary. 

Sincerely, 

~>410 

James Reuther MD 

Case 3:15-cv-02216-HZ Document 91 Filed 10/31/17 Page 7 of 11
-----~-------

Providence St. Vincent Medical Center 

9450 S.W Barnes Road, Suite 200 

Portland, OR 97225 

t: 503.216.2025 

f: 503.216.5529 

www.providence.org/oregon 

Outpatient Behavioral Health Services 

Mr. Ivan Resendiz- Guiterrez 

Miller Nash, Graham and & Dunn 

Via fax: S03-224-o1ss 

Dear Mr. Resendiz-Guiterrez, 

+ ?ROVIDENCE ~ St. Vincent 

Medical Center 

December 19, 2016 

Re: Andrea Olson 

DOB: 8/22/1964 

The Honorable Marco Hernandez, is in possession of medical documentation involving Andrea Olson, 

and it is suggested that you are aware of the information contained in the documents. In following up 

to the most recent letter provided on October 28, 2016, Ms. Olson's absence from legal proceedings 

continues to be medically necessary and I do not have an estimated date as to when she will be able to 

proceed. She is currently in a clinically necessary intensive outpatient treatment program that is 

conducted Monday through Saturday, 8:30 AM to 4:30 PM. 

Please take the information contained in this letter and prior documents into consideration. 

Sincerely, 

Brian Becker-Broncheau, M.D. 

Cc: Honorable Marco Hernandez; 3:15-CV-2216-HZ viua fax 503-326-8219 

Case 3:15-cv-02216-HZ Document 91 Filed 10/31/17 Page 8 of 11
THE UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

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

Plaintiff 

UNOPPOSED MOTION FOR 

EXTENSION OF EXPERT DISCLOSURE 

v. DEADLINE 

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 

Andrea Olson, the Plaintiff respectfully moves for a Twenty Seven day extension to the Expert Disclosure 

deadline, from Novemeber 5, 2017 to December l, 2017. One of Ms Olsons PO A's Dana Hoffman who is 

assisting and acting on Ms. Olsons behalf has conferred with James E Cox Jr, Assistant United States Attorney 

for the Federal Defendants. Mr. James E Cox Jr has informed Ms. Olson I Plaintiff and her POA/Ms. Hoffman 

that the Federal Defendants do not oppose this motion. 

Case 3:15-cv-02216-HZ Document 91 Filed 10/31/17 Page 9 of 11
On July 2017, the Court set a case schedule that included a Expert Disclosure cut-off of November 5 2017. 

(ECF 87) Due to the Defendents' Counsel Mr. James E Cox Jr's lengthy paternity leave, and one of the 

Plaintiff/Ms. Olsons POA's/Ms. Hoffman having an unscheduled surgery, the parties conferred and agreed to 

ask this court for an extension that would fall on the same date as the extension for the discovery deadline as to 

not delay any future deadlines that have already been scheduled as of July 2017. 

An additional 27 day extension of the current Expert Disclosure deadline to December 1, 2017 will allow for no 

delays to the case schedule that was put into order in July 2017 .(ECF 87) 

Furthermore, an extension would not result in any delay in trial or other pre-trial deadlines, as the deadline for 

dispositive motions is not until December 4, 2017. (ECF 87) With the exception of the Expert Discovery due on 

November s", 2017 which both parties have agreed upon would be due the same date December 1, 20 I 7 as the 

discovery deadline date that we are asking for in this motion, therefore there still would not be a delay on any 

other deadlines that have been scheduled. 

WHEREFORE, Ms. Olson /Planitiff respectfully requests that the Court grant this unopposed motion to extend 

the Expert Disclosure deadline in this case from Novemeber 5, 2017 to December 1, 2017. 

Dated this 3 I st day of October 2017 

/l~lly Submitted, 

Plaintiff I Andrea Olson 

3404 SW Comus St 

Portland, Oregon, 97219 

(503) 452-8888 

andrea.olson8888@gmail.com 

raig Butler/POA for Plaintiff Ms. Olson 

Case 3:15-cv-02216-HZ Document 91 Filed 10/31/17 Page 10 of 11
CERTIFICATE OF SERVICE 

On October 31, 2017, I, Andrea Olson, Plaintiff, am serving a Second Unopposed Motion For 

An Extension to File Discovery v. Deadline and Unopposed Motion For an Extension to File 

Expert Disclosure v. Deadline through a representative to the following: 

Hand-delivered: 

Honorable Marco A. Hernandez 

Mark 0. Hatfield United States Courthouse 

Room 1427 

1000 Southwest Third Avenue 

Portland, OR 97204-2944 

James E. Cox, Jr., Esq. 

United States Attorney's Office (current medical documentation was also hand-delivered on Oct. 

25, 2017) 

Assistant United States Attorney 

1000 SW Third Ave., Suite 600 

Portland, OR 97204 

Case 3:15-cv-02216-HZ Document 91 Filed 10/31/17 Page 11 of 11