UNITED ST ATES DISTRICT COURT FILED2

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1713:49.JSDC-l'RP 

DISTRICT OF OREGON 

ANDREA OLSON, an individual, Plaintiff Case No. 3:15-cv-02216-HZ 

-vsMBO PARTNERS, INC., A Virginia 

Corporation; UNITED STATES OF AMERICA, by and 

Through the Department of Justice, Department of Energy, and Bonneville Power 

Administration; and JAMES COX, United States Attorney's Office 

MOTION FOR EXTENSION OF TIME TO ANSWER 

Plaintiff, Andrea Olson, respectfully requests an order granting plaintiff, an additional 14 days in 

which to move, plead or otherwise respond to Defendant MBO's Motion to Dismiss Plaintiff's 

Amended Complaint, or in the Alternative, to Stay and Compel Arbitration and 

Memorandum in Support. I have been unable to find an attorney who can assist me and I have 

been denied legal counsel as a reasonable accommodation and as an indigent party. 

In addition, Plaintiff has been in contact with opposing counsel to discuss the possibility of 

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

Respectfully Submitted, 

J it-/ tf/-zojzr>l7 

~~ea Olson, Plaintiff 

3404 SW Comus St 

Portland, OR 97219 

Andrea.olson8888<mgmail.com 

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Case 3:15-cv-02216-HZ Document 72 Filed 04/20/17 Page 1 of 5
l of2 

Olson v. MBO Partners/SPA 

Mooney, Jenna <jennamooney@dwt.com> 

To: Andrea Olson <andrea.olson8888@gmail.com> 

Cc: "Folkestad, Vicki" <vickifolkestad@dwt.com> 

Hi Andrea, 

Andrea Olson <andrea.olson8888@gmail.com> 

Wed, Apr 19, 2017 at 9:45 AM 

I'm happy to talk. Unfortunately, I am in meetings until about 2:00. Can you make a call at or after 2:00 work? 

Will you have your power of attorney available on the phone as well? 

I have not been in touch with Jim Cox, but I will find his contact information and inquire about his availability 

this afternoon. 

Best, 

Jenna 

From: Andrea Olson [mailto:andrea olson8888@gmai!com] 

Sent: Tuesday, April 18, 2017 6:30 PM 

To: Mooney, Jenna 

SUbject: Olson v. MBO Partners/SPA 

Hi JennaAs I mentioned in the voicemail, Eric Rumbaugh suggested I get in touch with you regarding settlement. He also 

indicated you would know how to reach Jim Cox, who is apparently representing SPA 

I would like to discuss settlement over the phone. May I call you and Jim Cox at noon tomorrow? If the proposed 

time is inconvenient, please let me know an alternative time that works better for both of you. I will also need 

Jim's contact phone number. 

Thank you for your consideration. 

Andrea 

503 452 8888 

4/20/2017 12:30 PM 

Case 3:15-cv-02216-HZ Document 72 Filed 04/20/17 Page 2 of 5
l of l 

Olson v. MBO Partners/BPA 

Andrea Olson <andrea.olson8888@gmail.com> 

To: "Mooney, Jenna" <jennamooney@dwt.com> 

Cc: daodenorr@bpa.gov 

Hi JennaAndrea Olson <andrea.olson8888@gmail.com> 

's 4 s 

Wed, Apr 19, 2017at11:49AM 

Thank you for your message. I am cc'ing Donna Oden-Orr in this message so that she may help facilitate a 

connection to Jim or other representative from SPA 

Without SPA in the conversation, it seems it would be difficult to come up with the proper resolution. Does that 

seem logical? 

Hope Donna can help us find a BPA representative to join us in the conversation today. I appreciate your help in 

gathering all parties together as Eric mentioned you would be able to assist with that during my phone 

conversation with him yesterday. 

Thanks again. 

Andrea 

[Quoted text hidden] 

4/20/2017 12:35 Pl\. : 

Case 3:15-cv-02216-HZ Document 72 Filed 04/20/17 Page 3 of 5
UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

ANDREA OLSON, an individual, Plaintiff Case No. 3:15-cv-02216-HZ 

-vsMBO PARTNERS, INC., A Virginia 

Corporation; UNITED STATES OF AMERICA, by and 

Through the Department of Justice, Department of Energy, and Bonneville Power 

Administration; and JAMES COX, United States Attorney's Office 

MOTION FOR EXTENSION OF TIME TO ANSWER 

ENTRY 

The foregoing request is APPROVED/DENIED. Plaintiff's time to move, plead or otherwise 

respond to Defendant MBO's Motion to Dismiss Plaintiff's Amended Complaint, or in the 

Alternative, to Stay and Compel Arbitration and Memorandum in Support is extended to 

the ________ day of ________ , 2017. 

It is so ORDERED. 

Honorable Marco A. Hernandez 

R1~~tfu~y Submitted, (//.._,,- 4/z 6/z 01 I 

Andrea Olson, Plaintiff 

3404 SW Comus St 

Portland, OR 97219 

Andrea.olson8888@.gmail.com 

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Case 3:15-cv-02216-HZ Document 72 Filed 04/20/17 Page 4 of 5
CERTIFICATE OF SERVICE 

On April 20, 2017, I, Andrea Olson, Plaintiff, am serving a Motion for Extension of Time to 

Answer with this Court to the following parties: 

Hand-delivered to 'J'h floor: 

Honorable Marco A. Hernandez 

Mark 0. Hatfield United States Courthouse 

Room 1427 

1000 Southwest Third A venue 

Portland, OR 97204-2944 

Electronic Mail and U.S. Mail: 

Jenna L. Mooney, Esq. 

jennamooney@dwt.com 

Kalia Walker, Esq. 

kaliawalker@dwt.com 

Davis Wright Tremaine, LLP 

1300 SW Fifth A venue, Suite 2400 

Portland, OR 97201-5610 

James E. Cox, Jr., Esq. 

Jim.cox@usdoj.gov 

United States Attorney's Office 

Assistant United States Attorney 

1000 SW Third Ave., Suite 600 

Portland, OR 97204 

Andrea Olson r I 

jvJ,4=, 

Crc.-7~~rPoA lor a_,.,,./'M...@lto i.-

Case 3:15-cv-02216-HZ Document 72 Filed 04/20/17 Page 5 of 5