BILLY J. WILLIAMS, OSB #901366 

United States Attorney 

District of Oregon 

JAMES E. COX, JR., OSB # 085653 

jim.cox@usdoj.gov 

Assistant United States Attorney 

United States Attorney's Office 

District of Oregon 

1000 SW Third Ave. , Suite 600 

Portland, Oregon 97204-2902 

Telephone: (503) 727-1026 

Facsimile (503) 727-1117 

Attorneys for Defendants the United States of America and James Richard Perry 

("Federal Defendants") 

THE UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

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. 

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

DECLARATION OF JAMES E. 

COX, JR. IN SUPPORT OF 

UNOPPOSED MOTION FOR 

EXTENSION OF DISCOVERY 

DEADLINE 

I, James E. Cox, Jr., hereby make the following declaration under penalty of 

perjury pursuant to 28 U.S.C. § 1746 and submit this declaration in support of the 

parties' joint motion for extension of pre-trial deadlines and continuance of trial 

date. 

Page 1 Declaration of James E. Cox, Jr. in Support of Unopposed Motion 

for Extension of Discovery Deadline 

Case 3:15-cv-02216-HZ Document 89 Filed 10/02/17 Page 1 of 3
1. I am an Assistant United States Attorney in the District of Oregon and am 

the primary attorney responsible for representing the Federal Defendants in 

this action. I make this declaration on personal knowledge and, if called 

upon to do so, I could and would competently testify to the following matters. 

2. I was on a lengthy paternity leave until August 26, 2017. Because of this 

absence, I was unable to complete the necessary preparation to hold 

Plaintiffs deposition in the case in September 2017, as contemplated by the 

current case schedule. In the past week, I have been in touch with Plaintiff 

and one of her power of attorneys regarding the possibility of scheduling 

Plaintiffs deposition in October 2017. 

3. A thirty day extension of the current discovery deadline to November 1, 2017, 

would assist in allowing Plaintiffs deposition to occur. 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. 

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

Executed this 2nd day of October 2017 at North Augusta, South Carolina. 

Is I James E. Cox Jr. 

JAMES E. COX, JR. 

Page 2 Declaration of James E. Cox, Jr. in Support of Unopposed Motion 

for Extension of Discovery Deadline 

Case 3:15-cv-02216-HZ Document 89 Filed 10/02/17 Page 2 of 3
CERTIFICATE OF SERVICE 

I h ereby certify that a copy of the foregoing Declaration of James E. Cox, 

Jr. in Support of Unopposed Motion for Extension of Discovery Deadline 

was placed in a postage prepaid envelope and deposited in the United States Mail at 

Portland, Oregon, on October 2, 2017, addressed to: 

Andrea Olson 

3404 SW Com us St. 

Portland, OR 97219 

Page 3 Declaration of James E. Cox, Jr. in Support of Unopposed Motion 

for Extension of Discovery Deadline 

Case 3:15-cv-02216-HZ Document 89 Filed 10/02/17 Page 3 of 3