BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ILLINOIS ENVIRONMENTAL
)
DEC 062005
PROTECTION AGENCY,
)
STATE OF ILLINOIS
Complainant,
)
AC
05-18
Pollution Control Board
)
V.
)
(IEPA No. 409-04-AC)
)
WILLIAM SHRLJM,
)
Respondent.
NOTICE OF FILING
To: Kevin J.Babb
309 Hilisboro Avenue
Edwardsville, IL 62025
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
Control Board of the State of Illinois the following instrument(s) entitled APPEAJ(ANCE and
MOTION TO FILE INSTANTER.
Respectfully submitted,
Michelle M. Ryan
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
Dated: November 21, 2005
THIS FLUNG SUBMITtED ON RECYCLED PAPER
RECEIVED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
DEC 062005
STATE OF ILLINOIS
Pollution Control Board
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Complainant,
)
AC 05-18
)
V.
)
(IEPA No. 409-04-AC)
)
WILLIAM SHRUM,
)
Respondent.
)
ENTRY OF APPEARANCE
The undersigned hereby enters her appearance in the above-captioned matter as
counsel for the Illinois Environmental Protection Agency.
Respectfully submitted,
Michelle M. Ryan
Special Assistant Attorney General
DATED: November 21, 2005
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Springfield, IL 62702-4059
(217) 782-5544
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVED
CLERK’S OFFICE
ILLINOIS ENVIRONMENTAL
)
.
DEC 062005
PROTECTION AGENCY,
))
Pollution
STATE OF
ControlILLINOISBoard
Complainant,
)
AC 05-18
)
V.
)
(IEPA No. 409-04-AC)
)
WILLIAM SHRUM,
)
)
Respondent.
)
MOTION TO FILE INSTANTER
NOW COMES the Complainant, the Illinois Environmental Protection Agency (“Illinois EPA”),
by and through its attorney, Michelle M. Ryan, pursuant to 35 Ill. Adm. Code 101.522, and respectfully
states as follows:
(1)
This matter was initially filed on August 26, 2004 on behalfof the Illinois EPA by the
undersigned attorney. No specific designation of lead counsel was made by Illinois EPA in this
proceeding. Pursuant to 35 Ill. Adm. Code 101 .400(a)(4), the undersigned attorney was designated lead
counsel in this matter by operation ofrule.
(2)
On December 8, 2004, James M. Kropid filed a formal appearance on behalfofIllinois
EPA as the newly assigned attorney.
(3)
The undersigned attorney was reassigned to this matter prior to hearing, participated in
status calls with the assigned Hearing Officer, and scheduled the matter for hearing on November 17,
2005.
(4)
The undersigned attorney prepared a formal written appearance, as required by 35 Ill.
Adm. Code 101.400(a)(4), in advance ofhearing for filing during the hearing. However, therequired
documents were inadvertently left on the undersigned attorney’s desk in Springfield when shetraveled to
Perry County for the hearing.
(5)
No specific timeframe is set forth in the Board’s rules for the filing of a written
appearance, although the undersigned attorney has previously filed written appearances at or prior to
hearing.
(6)
Pursuant to 35111. Adm. Code 101.522, the Board may allow foran extension oftime for
filing any document either before or after the due date.
(7)
Respondent did not object at hearing to the lack of a formal written appearance.
(8)
No prejudice will result by granting this motion, as the Hearing Officer and opposing
counsel were kept informed of the assigned attorney at all times, and this case does not contain a
statutory decision deadline.
WHEREFORE, Illinois EPA requests that the Board grant this Motion to File Instanter and
accept the undersigned attorney’s appearance as timely filed.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant
DATED: November 21, 2005
‘K k i~\~L1J.
~
ichelle M. Ryan
—
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217)782-5544
THIS FILING SUBMITtED ON RECYCLED PAPER
PROOF OF SERVICE
I hereby certify that I did on the 2l~day ofNovember, 2005, send by U.S. Mail with postage
thereon fully prepaid, by depositing in a United States Post Office Box a true and correct copy ofthe
following instrument(s) entitled APPEARANCE and MOTION TO FILE INSTANTER
To: Kevin J. Babb
Carol Webb
309 Hillsboro Avenue
Hearing Officer
Edwardsville, IL 62025
Illinois Pollution Control Board
1021 North Grand Avenue East
P.O. Box 19274
Springfield, Illinois 62794-9274
and the original and nine (9) true and correct copies ofthe same foregoing instruments on the same
date by U.S. Mail with postage thereon fully prepaid
To: Dorothy Gunn, Clerk
Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
\J~\AvJAAL
Michelle M. Ryan
UitCt(A
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217)782-5544
THIS FILING SUBMIflED ON RECYCLED PAPER
