2Oo
P’YJNOiS
PCB
07-145
fltoI
9
oar
(Citizens
Enforcement-Noise)
ENTRY
OF
APPEARANCE
FOR
COMPLAINANTS
NOW COMES
the law
firm of WINTERS,
BREWSTER,
CROSBY
and SCHAFER
LLC, and
hereby
enters its
appearance
on
behalf of Complainants,
RANDY
GRANT,
DONALD
GRANT, and
PATRICIA
WALLACE,
in the
above-entitled
matter
and requests
that
all
further
pleadings
and/or notices
be
forwarded
to this
office.
WINTERS,
BREWSTE
, C
OSBY
and SCHAFER
LLC
BY
1ants
AR1ic,o.
06226013
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
RANDY
GRANT,
DONALD
GRANT
and
PATRICIA
WALLACE,
Complainants,
V.
CLINE
RESOURCE
AND
DEVELOPMENT
COMPANY
and MACH
MINING
LLC,
Respondents.
CERTIFICATE
OF MAILING
SThT. flfr
The undersigned
certifies
that a copy of the above and
foregoing instr
4
$OIS
by
depositing the same in
a
U.S.
Post Office Box in the City of
Marion, Illinois, postage
PUIP’
B0d
prepaid and addressed to:
Ms. Alison K. Hayden
Ms. Claire Manning &
Mr. Scott Helmolz
Brown,
Hay &
Stephens, LLP
205
5.
Fifth Street, Suite 700
P.O.
Box 2459
Springfield, IL 62705
Ms. Carol Webb
Hearing Officer
Illinois
Pollution Control Board
1021 North Grand
Avenue East
P.O.
Box 19274
Springfield, IL 62794-9274
Dated this dayof
, 2008.
WINTERS,
BREWSTER, CROSBY and SCHAFER, LLC
Attorneys at Law
111
West
Main, P.O. Box 700
Marion, IL 62959
Phone:
(618)997-5611
Fax:
(618)997-6522
2
BEFORE THE ILLINOIS
POLLUTION CONTROL
BOARD
CLERKOPICE
RANDY GRANT,
DONALD
GRANT
and
2008
PATRICIA
WALLACE,
•nit
Contro’
ILUN
Complainants,
v.
PCB
07-145
(Citizens Enforcement-Noise)
CLINE RESOURCE AND
DEVELOPMENT
COMPANY and
MACH MINING LLC,
Respondents.
COMPLAINANTS’
MOTION TO
CONTINUE THE
OCTOBER 27,
2008 TELEPHONE STATUS
CONFERENCE
NOW
COME the Complainants,
RANDY
GRANT,
DONALD GRANT, and
PATRICIA
WALLACE, hereinafter
“Complainants,”
by
and through their
attorneys,
WINTERS,
BREWSTER, CROSBY
and SCHAFER LLC, and for
their Motion
to
Continue
the October 27,
2008 Telephone Status
Conference hereby state as
follows:
1.
Complainants retained the undersigned
counsel to represent
them
in this matter.
The
contract of
employment retaining
counsel
was
signed today.
2.
Complainants’ attorney
has filed an Entry of
Appearance herewith and needs
time to
review
the documents on file and
discovery before
proceeding with a telephone status
conference.
3.
Complainants’ attorney
has another obligation scheduled
in
a
case before
the
U.S.
District
Court for the
Southern District of
Illinois on October 27, 2008.
Same was
scheduled
prior to entering an
appearance in the above
captioned matter.
4.
Complainants’ attorney has contacted
one of Respondents’
attorneys, Alison Hayden
from Brown,
Hay
&
Stephens, LLP who advised
that she does not have
an objection to
continuing
the October
27,
2008
telephone status
conference.
5.
This Motion
is not made for the
purpose of harassment
or
delay
and will not
prejudice
any party
to
this action.
WHEREFORE, Complainants
pray
that the October
27, 2008 telephone
status
conference
WINTERS,
BREWSTER,
CROSBY and
SCHAFER
LLC
BY
//
//
Jay
J\ttQruy
Schf
for
Coplainants
77
AaDNo.
06226013
CERTIFICATE OF
MAILING
be continued to
another date.
The
undersigned certifies that
a copy
of
the above
and
foregoing
instrument was mailed
by
depositing
the
same in
a
U.S. Post
Office Box in the City
of Marion,
Illinois, postage
fully
prepaid
and addressed
to:
Ms.
Alison
K.
Hayden
Ms.
Claire Manning
&
Mr.
Scott Helmolz
Brown,
Hay &
Stephens,
LLP
205 5. Fifth
Street, Suite 700
P.O.
Box 2459
Springfield,
IL 62705
Dated
this 2’day
of
WINTERS,
BREWSTER,
CROSBY and
Attorneys
at Law
111
West Main,
P.O. Box 700
Marion,
IL 62959
Phone:
(618)997-5611
Fax:
(618)997-6522
Ms.
Carol Webb
Hearing
Officer
Illinois
Pollution
Control Board
1021 North
Grand Avenue
East
P.O.
Box
19274
Springfield,
IL
62794-9274
(tobt’
J
2008.
o
SCHAFER, LLC
2
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
RANDY
GRANT,
DONALD
GRANT
and
PATRICIA
WALLACE,
‘2UO8
Complainants,
P01
SIATh
LUt
?or,
OF
Control
ILL1NO2S
Boarc
v.
PCB
07-145
(Citizens
Enforcement-Noise)
CLINE RESOURCE
AND
DEVELOPMENT
COMPANY
and
MACH
MINING
LLC,
Respondents.
ORDER
GRANTING
COMPLAINANTS’
MOTION
TO CONTINUE
THE
OCTOBER
27, 2008
TELEPHONE
STATUS
CONFERENCE
THIS
MATTER
coming
on Complainants’
Motion
to Continue
the
October
27,
2008
Telephone
Status
Conference
and the hearing
officer
having
reviewed
said Motion
and being
fully
advised
in the premises
thereof,
HEREBY
GRANTS
Complainants
Motion.
The October
27, 2008
telephone
status
conference
shall be
continued
to
the
day of
__________________________
2008,
with
to
initiate
the
call.
Dated this
day of
,
2008.
CAROL
WEBB,
PRESIDING
OFFICER
WINTERS,
BREWSTER,
CROSBY
AND
SCHAFER
LLC
ATTORNEYS
AT
LAW
111
West
Main,
P.O.
Box
700
MARiON,
IL
62959
JOHN
S.
BREWSTER
THOMAS F.
CROSBY
PAUL
J.
SCHAFER
LINDA
J.
BRAME*
MOLLY
R. WILSON
*
Also
licensed
in
Missouri
OCT
Clerk
of
the
Illinois
Pollution Control
100
W.
Randolph
Suite
11-500
Chicago,
IL
60601
RE:
Grant,
Donald;
Grant,
Randy
&
Wallace,
Patricia
v
Mach
Mining
LLC
Case
No.
PCB
No.
2007-145 &
08-MR-37,
Illinois
Pollution
Control
Board;
Johnson
County,
IL
WBCS
No.
8-236-PJS
Dear
Clerk:
Enclosed
you
will
find
an
original
and
one
copy
of
Entry
of
Appearance,
Motion
to
Continue and
proposed
Order
in
the
above
referenced
matter.
Please
file
the
originals
and
return
the
file-stamped
duplicates
to
me
in
the
self-addressed,
preposted
envelope
enclosed
for
this
purpose.
Thank
you
for
your
courtesy
and
cooperation
in
this
matter.
PJS:ag
cc:
Ms.
Alison
K.
Hayden,
Ms.
Claire
Manning &
Mr.
Scott
Helmolz
Ms.
Carol
Webb
CHARLES
D.
WINTERS
(19
17-1992)
TELEPHONE: (618)997-5611
FAX:
(618)
997-6522
ECVED
CLERK’S
October
21,
2008
QFFfAIL.
winlaw@winterslaw.com
1’
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313
STATE
OF
ILUNOIS
IOfl
Control
Board
Very