1. MOTION FOR EXTENSION OF TIME TO FILE AN AMENDED RESPONSE TO REQUEST FOR
 
 
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BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
 
 
PEOPLE OF THE STATE OF ILLINOIS, )
LISA MADIGAN, Attorney General of )
the State of Illinois, )
)
Complainant, )
)
vs ) PCB No. 05-51
) (Enforcement-Air)
ENVIRONMENTAL HEALTH AND SAFETY )
SERVICES, INC., an Illinois corporation )
)
Respondent. )
 
 
MOTION FOR EXTENSION OF TIME TO FILE
AN AMENDED RESPONSE TO REQUEST FOR
ADMISSION OF FACT
 
NOW COMES the Respondent, ENVIRONMENTAL HEALTH AND SAFETY
SERVICES, INC., an Illinois corporation, by its attorneys, SCHLUETER ECKLUND and for
its Motion for Extension of Time to File an Amended Response to Request for Admission of
Fact states as follows:
1. On or about March 3, 2006, Respondent filed an Amended Response to
Request for Admission of Fact, along with a Response to Motion to Gain Facts Admitted.
2. Throughout much of February, the principal officer of Environmental Health
and Safety Services, Inc. was working on projects that took him out of town and he was
unable to appear in his counsel’s office to execute the pleading until the afternoon of
February 28, 2006, which pleading was then generated to the state and the parties March
3, 2006.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 14, 2006
 
 
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3. As the responses to the Request for Admission of Facts did not change,
Respondent believes the Complainant was not prejudiced by the delay, and counsel for the
Respondent had written to the attorney for Complainant in a letter of February 9, 2006
indicating the Verified Response was forthcoming.
4. While the Complainant objects to this motion, Complainant believes that a
favorable decision on this motion will further a just result in this matter.
WHEREFORE, Respondent, ENVIRONMENTAL HEALTH & SAFETY SERVICES,
INC., an Illinois corporation, respectfully requests that the Hearing Officer grant this motion
and accept the Amended Response to Request for Admission of Facts.
Respectfully submitted,
ENVIRONMENTAL HEALTH AND SAFETY
SERVICES, INC., an Illinois corporation, Respondent
 
By: SCHLUETER ECKLUND
 
_____________________________________
BRYAN G. SELANDER, One of its attorneys
 
 
 
 
DATE: March 14, 2006
 
 
Bryan G. Selander #316
SCHLUETER ECKLUND
4023 Charles Street
Rockford, IL 61108
(815) 229-5333
       
  
 
 
 
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 14, 2006
 
 
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CERTIFICATE OF SERVICE
 
I, BRYAN G. SELANDER, Attorney for Respondent, do certify that I caused to be
mailed this 14
th
day of March, 2006, the foregoing Motion for Extension of Time to File an
Amended Response to Request for Admission of Fact to the persons listed on the said
NOTICE by first-class mail in a postage prepaid envelope and depositing same with the
United States Postal Service located at 5225 Harrison Avenue, Rockford, IL 61125.
It is hereby certified that a true copy of the foregoing Notice was electronically filed
with the following on March 14, 2006.
Dorothy M. Gunn
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph, Suite 11-500
Chicago, IL 60601
 
________________________________
BRYAN G. SELANDER
Attorney for Respondent
Schlueter Ecklund
4023 Charles Street
Rockford, IL 61108
(815) 229-5333
 
   
  
  
 
 
 
 
 
 
 
 
 
 
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
 
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 14, 2006
 
 
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PEOPLE OF THE STATE OF ILLINOIS, )
LISA MADIGAN, Attorney General of )
the State of Illinois, )
)
Complainant, )
)
vs ) PCB No. 05-51
)
) (Enforcement-Air)
ENVIRONMENTAL HEALTH AND SAFETY )
SERVICES, INC., an Illinois corporation, )
)
Respondent. )
 
NOTICE OF FILING
 
TO: Katherine M. Hausrath Bradley P. Halloran
Assistant Attorney General Hearing Officer
Environmental Bureau Illinois Pollution Control Board
188 W. Randolph St., 20
th
Flr. James R. Thompson Center, Suite 11-500
Chicago, IL 60601 100 W. Randolph Street
Chicago, IL 60601
 
 
  
PLEASE TAKE NOTICE that I have today electronically filed with the Office of the
Clerk of the Illinois Pollution Control Board a copy of Motion for Extension of Time to File an
Amended Response to Request for Admission of Fact, a copy of which is attached and
herewith served upon you.
 
Dated: March 14, 2006.
Respectfully submitted,
 
RANDY OLDENBERGER d/b/a
ENVIRONMENTAL HEALTH and SAFETY
 
BY: SCHLUETER ECKLUND
 
_____________________________________
BRYAN G. SELANDER, one of its attorneys
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 14, 2006

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