1 – LAY WITNESS STATEMENT 

 

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 

PLAINTIFF’S LAY WITNESS 

STATEMENT 

 Plaintiff will call the following witnesses: 

1 Andrea Olson, Plaintiff. 

 Ms. Olson will testify that, in 2010, she executed a contract with Defendant Bonneville 

Power Administration (BPA) to provide reasonable accommodation services to BPA’s 

employees including guidance under the Federal Rehabilitation Act and the Americans with 

Disabilities Act (ADA). Ms. Olson worked under the direction of Sharon Hale-Mockley, BPA’s 

Case 3:15-cv-02216-HZ Document 125 Filed 06/15/18 Page 1 of 3
2 – LAY WITNESS STATEMENT 

 

GRIGGS LAW GROUP, P.C. 

4900 SW Griffith Dr., Ste. 165 

Beaverton, OR 97005 

Talent Sustainment Manager and maintained the title of Reasonable Accommodation 

Coordinator and used a BPA email address. 

In April 2013, Ms. Olson had her first onset of anxiety while working for BPA and, in 

February 2014, notified BPA Management that she suffered from anxiety. She prepared an 

FMLA leave request in March 2014 through MBO, the contracting employer. Neither MBO nor 

BPA responded about her specific rights and responsibilities and entitlement to leave and she 

was given no notice of her rights under the FMLA. 

On March 3, 2014, Ms. Olson requested reasonable accommodation and on March 25, 

2014 requested leave under the FMLA. Ms. Olson was qualified for leave under the FMLA 

because she had worked enough hours within the requisite time and was suffering from a serious 

health condition. 

 The day after she filed an unlawful discrimination complaint for harassment with the 

BPA Civil Rights Equal Employment Opportunity office, BPA terminated Ms. Olson by email. 

She received an email from BPA notifying her that she had been terminated. 

 Ms. Olson wanted to return to work for BPA while on FMLA leave but her medical 

condition had worsened when she filed the EEOC Complaint against BPA for retaliation and 

harassment for filing an ethics complaint in December, 2013. She wanted to return to work but 

was responsible for cooperating in multiple complaint investigations and never given an 

opportunity to care for her medical condition. She intended to return upon the abatement of her 

medical condition. 

 Under significant and intentional deception and confusion of her identity by BPA and 

MBO, and because she had already been terminated, her job already given away while out on 

Case 3:15-cv-02216-HZ Document 125 Filed 06/15/18 Page 2 of 3
3 – LAY WITNESS STATEMENT 

 

GRIGGS LAW GROUP, P.C. 

4900 SW Griffith Dr., Ste. 165 

Beaverton, OR 97005 

FMLA, Ms. Olson was pressured to meet with Mr. Scott Hampton on June 5, 2014. The meeting 

was indicative of continued harassment by BPA personnel. 

 Ms. Olson was making $95 per hour and working an average of 27.75 hours per week but 

was not permitted to be paid for work BPA required she perform for MBO. Ms. Olson’s original 

BPA contract with MBO was closed by BPA without her knowledge or consent on May 14, 

2012. BPA’s contract with MBO for her services that she was unaware existed prior to early 

2014 was through the end of January 2015. 

 DATED this 15th day of June, 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 125 Filed 06/15/18 Page 3 of 3