BEFORE THE POLLUTION CONTROL BOARD
    OF THE STATE OF ILLINOIS
      
     
    MCLEAN COUNTY ASPHALT, )
    Petitioner, )
    v. ) PCB No. 05-154
    ILLINOIS ENVIRONMENTAL ) (LUST Appeal)
    PROTECTION AGENCY, )
    Respondent. )
     
    NOTICE
     
     
    Dorothy M. Gunn, Clerk Curtis W. Martin
    Illinois Pollution Control Board Robert E. Shaw
    James R. Thompson Center Shaw & Martin, P.C.
    100 West Randolph Street 123 South 10
    th
    Street, Suite 302
    Suite 11-500 P.O. Box 1789
    Chicago, IL 60601 Mt. Vernon, IL 62864
     
    Carol Webb, Hearing Officer
    Illinois Pollution Control Board
    1021 North Grand Avenue, East
    P.O. Box 19274
    Springfield, IL 62794-9274
     
    PLEASE TAKE NOTICE that I have today filed with the office of the Clerk of the Pollution
    Control Board a MOTION FOR EXTENSION OF TIME, copies of which are herewith served upon you.
     
    Respectfully submitted,
     
    ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
    Respondent
     
     
    ____________________________
    John J. Kim
    Assistant Counsel
    Special Assistant Attorney General
    Division of Legal Counsel
    1021 North Grand Avenue, East
    P.O. Box 19276
    Springfield, Illinois 62794-9276
    217/782-5544
    217/782-9143 (TDD)
    Dated: November 23, 2005
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 23, 2005
    CERTIFICATE OF SERVICE
     
     
    I, the undersigned attorney at law, hereby certify that on November 23, 2005, I served
    true and correct copies of a MOTION FOR EXTENSION OF TIME, by electronic filing to the
    Clerk of the Illinois Pollution Control Board and by placing true and correct copies in properly
    sealed and addressed envelopes and by depositing said sealed envelopes in a U.S. mail drop box
    located within Springfield, Illinois, with sufficient First Class Mail postage affixed thereto, to the
    Petitioner and Hearing Officer:
    Dorothy M. Gunn, Clerk (Electronic filing) Curtis W. Martin
    Illinois Pollution Control Board Robert E. Shaw
    James R. Thompson Center Shaw & Martin, P.C.
    100 West Randolph Street 123 South 10
    th
    Street, Suite 302
    Suite 11-500 P.O. Box 1789
    Chicago, IL 60601 Mt. Vernon, IL 62864
     
    Carol Webb, Hearing Officer
    Illinois Pollution Control Board
    1021 North Grand Avenue, East
    P.O. Box 19274
    Springfield, IL 62794-9274
     
     
     
    ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
    Respondent
     
    ____________________________
    John J. Kim
    Assistant Counsel
    Special Assistant Attorney General
    Division of Legal Counsel
    1021 North Grand Avenue, East
    P.O. Box 19276
    Springfield, Illinois 62794-9276
    217/782-5544
    217/782-9143 (TDD)
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 23, 2005
     
    1
    BEFORE THE POLLUTION CONTROL BOARD
    OF THE STATE OF ILLINOIS
      
     
    MCLEAN COUNTY ASPHALT, )
    Petitioner, )
    v. ) PCB No. 05-154
    ILLINOIS ENVIRONMENTAL ) (LUST Appeal)
    PROTECTION AGENCY, )
    Respondent. )
     
    MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO
    PETITIONER’S MOTION FOR SUMMARY JUDGMENT
     
     
    NOW COMES the Respondent, the Illinois Environmental Protection Agency (“Illinois
    EPA”), by one of its attorneys, John J. Kim, Assistant Counsel and Special Assistant Attorney
    General, and, pursuant to 35 Ill. Adm. Code 101.522, hereby requests that the Illinois Pollution
    Control Board (“Board”) grant the Illinois EPA an extension of time within which to file its
    Response to the Petitioner’s Motion for Summary Judgment. In support of this motion, the
    Illinois EPA states as follows:
    1. On November 14, 2005, the Illinois EPA received service of the Petitioner’s
    motion for summary judgment. Pursuant to the Board’s procedural rules, a response to the
    Petitioner’s motion is due on or before November 28, 2005.
    2. This due date includes two days (November 24 and November 25, 2005) during
    which the Illinois EPA will be closed. Further, the undersigned counsel for the Illinois EPA is
    also preparing for a hearing to be held on December 1, 2005.
    3. The Illinois EPA hereby requests a short extension of time to complete
    researching and drafting a response to the Petitioner’s motion of seven (7) additional days, or
    until December 5, 2005.
    4. This short delay will not prejudice the Petitioner’s case, but will allow for
    sufficient time to present the Illinois EPA’s information and response.
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, NOVEMBER 23, 2005
     
    2
    WHEREFORE, for the reasons stated above, the Illinois EPA hereby respectfully
    requests that the Board grant the Illinois EPA an extension of time to file the response to the
    Petitioner’s motion for summary judgment.
    Respectfully submitted,
    ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
    Respondent
     
    ____________________________
    John J. Kim
    Assistant Counsel
    Special Assistant Attorney General
    Division of Legal Counsel
    1021 North Grand Avenue, East
    P.O. Box 19276
    Springfield, Illinois 62794-9276
    217/782-5544, 217/782-9143 (TDD)
    Dated: November 23, 2005
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
    This filing submitted on recycled paper.

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