Petitioner,
)
ILUNOIS
ENVIRONMENTAL
PROTECTION
AGENCY,
)
)
)
)
PCB 09-025
)
(Permit
Appeal-Water)
)
Respondent.
)
TO:
See Attached
Service
List
NOTICE
OF FILING
PLEASE
TAKE
NOTICE that
on December 16,
2008, we filed
with
the
Office
of the
Clerk of
the Pollution Control
Board
the
attached Joliet’s
Motion
Requesting
an
Extension
for
Pre-filed
Testimony,
a copy of
which
is served
upon
you.
Dated:
December 16,
2008
Roy
M. Harsch, Esq.
Yesenia
Villasenor-Rodriguez,
Esq.
Drinker
Biddle
& Reath
LLP
191
North
Wacker Drive
- Suite
3700
Chicago,
Illinois
60606
(312) 569-1441
(Direct Dial)
(312) 569-3441
(Facsimile)
Respectfully
submitted,
THE CITY
OF JOLIET
By:
CITY OF JOLIET,
BEFORE
THE ILLINOIS
POLLUTION CONTROL
BOARD
DEC
s
2008
?OUj,
STATE
OF
ILLINOIS
0
)
v.
Attorneys
THIS FILING IS
BEING SUBMITTED
ON RECYCLED
PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
EcvE
CLERKS
OFFIG?
DEC.
62008
CITY
OF JOLIET,
)
ST,.vr2
OF
ILLINO
Control
Petitioner,
)
)
v.
)
PCB 09-025
)
(Permit Appeal-Water)
ILLINOIS
ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
)
JOLIET’S
MOTION
REQUESTING
AN EXTENSION FOR
PRE-FILED
TESTIMONY
NOW COMES,
Petitioner,
TI-IE CITY OF JOLIET (hereinafter,
“Joliet”), by and
through
its attorneys,
and
respectfully
requests that the Hearihg Officer grant this
motion requesting
an
extension to
submit its pre-filed testimony.
In
support thereof, Joliet states as follows:
1.
On December
8,
2008,
the
parties in this matter participated
in a
status conference
in
which Joliet indicated its intent to submit pre-filed
testimony prior to
the hearing.
2.
On December 9, 2008, the hearing
officer in this matter
issued an
order indicating
that
any
pre-filed testimony must
be submitted on or before
December 22, 2008.
3.
Joliet’s witnesses
are unable to complete
their respective
pre-filed testimony
on
or
before
the required date
due to several reasons including
the fact that
one of
its witnesses
is
currently
in the hospital.
4.
Joliet has confirmed
the above with Senior
Assistant Attorney
General
Gerald
Karr,
attorney for respondent;
and he has indicated
that he has no
objections
to this request
so
long as
the pre-filed testimony
is received on or before
January 2, 2009.
THIS FILING
SUBMITTED ON
RECYCLED PAPER
5.
The parties will be not prejudiced by extending the due date
for the pre-filed
testimony as
provided
above.
WHEREFORE, for all the foregoing reasons, Petitioner, THE
CITY OF
JOLIET,
respectfully requests
that the Hearing
Officer grant its Motion Requesting
an
Extension
to
submit
its Pre-Filed Testimony
on or before
January
2, 2009.
Respectfully submitted,
THE CITY OF JOLIET,
Petitioner,
By
Dated:
December 16, 2008
Roy M.
Harsch, Esq.
Yesenia
Villasenor-Rodriguez,
Esq.
Drinker Biddle
&
Reath LLP
191 North Wacker Drive - Suite 3700
Chicago, Illinois 60606
(312)
569-1441 (Direct Dial)
(312)
569-3441
(Facsimile)
Attorneys
THIS FILING SUBMITTED
ON RECYCLED PAPER
CERTIFICATE
OF
SERVICE
I, the
undersigned,
certify
that I
have served
the
attached
Motion
Requesting
an
Extension
for
Pre-Filed
Testimony,
by First
Class
Mail,
postage
pre-paid
on December
16, 2008.
See
Attached
List.
Y
THIS
FILING
SUBMITTED
ON
RECYCLED
PAPER
Service
List
PCB
09-25
(Permit
Appeal
— Water)
Gerald
T.
Karr
Senior
Assistant
Attorney
General
69 West
Washington
—
Suite
1800
Chicago,
IL 60602
John
T.
Therriault
Illinois
Pollution
Control
Board
James
R.
Thompson
Center
100
W.
Randolph
Street
— Suite
11-500
Chicago, IL 60601
Bradley
P.
Halloran
Hearing
Officer
Illinois
Pollution
Control
Board
James
R. Thompson
Center
100
W.
Randolph
Street
— Suite
11-500
Chicago,
IL
60601
CI-1Ol/
25273753.1
THIS
FILING
SUBMITTED
ON
RECYCLED
PAPER