BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
by LISA MADIGAN, Attorney General of the
)
~ E
C E
~
V
ED
State ofIllinois,
)
CLERK’S OFFICE
)
OCT-52004
Complainant,
)
)
PCB No. 04~2O2STATE
OF
ILLINOIS
v.
)
(Enforcement) Pollution
Control Board
)
EDWARD PRUIM, an individual, and
)
ROBERT PRUTh’I, an individual,
)
)
Respondents.
)
NOTICE OF FILING
TO:
Ms. Dorothy Gunn, Clerk
.
Mr. Christopher Grant
Illinois Pollution Control Board
Assistant Attorney General
James R. Thompson Center
Environmental Bureau
100 W. Randolph Street, 11-500
188 W. Randolph, 20th Floor
Chicago, IL 60601
Chicago, IL 60601
PLEASE TAKE NOTICE that on October
5,
2004, we filed with the Clerk ofthe Illinois
Pollution Control Board an original andnine copies of
RESPONDENTS EDWARD PRUIM
AND
ROBERT PRUIMS’ MOTION FOR LEAVE TO FILE A REPLY,
a copy ofwhich is attached
and herewith served upon you.
~
Attorney for Respondent
Mark A. LaRose
Clarissa C. Grayson
Attorney No. 37346
LaRose & Bosco, Ltd.
200 N. LaSalle Street
Chicago, IlL 60601
(312)642-4414
Fax (312) 642-0434
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
by LISA MADIGAN, Attorney General ofthe
)
State offlhinois,
)
)
Complainant,
)
)
v.
)
PCB No. 04-207
)
EDWARD PRUIM, an individual, and
)
ROBERT PRUIM, an individual,
)
)
Respondents.
)
RESPONDENTS EDWARD PRUIM
AND
ROBERT PRUIMS’ MOTION FOR LEAVE
TO FILE A REPLY
RESPONDENTS, EDWARD
PRUIIM
and ROBERT PRUIM, by and through his attorneys
LAROSE & BOSCO, LTD. hereby movethe Board for leave to file a reply and in support thereof,
states as follows:
1.
On September 10, 2004, Respondents filed a motion to dismiss the complaint filed
by the People ofthe State ofIllinois in the above matter.
2.
Pursuant to Board rule Section 101.500(d), Complainant’s response was to be filed
on S eptember 24, 2004. D uring a telephonic status c onference on S eptember 3 0, 2004, o ver
Respondents’ objection, HearingOfficer BradleyHalloran grantedComplainant’s oral motion to file
its response late, on October 4, 2004.
3.
During the telephonic status conference, Hearing Officer Halloran indicated that
there was a possibility that the Board could consider Respondents’ motion to dismiss as early as
Thursday, October 7, 2004.
1
4.
While Respondents only received the Complainant’sresponse yesterday, October 4,
2004, they would like to reserve the right to file a reply prior to the Board’s considering theirmotion
to dismiss.
5.
While Respondents have not yet had the opportunity to fully review Complainant’s
response, Respondents are filing the current motion for leave tofle a reply in order to protect their
right to do so pri6r to the next Board hearing currently scheduled for October 7, 2004.
WHEREFORE, Respondents EDWARD PRUIM andROBERTPRUlMrespectfallyrequest
that the Board grant them leave to file a reply in the above matter, if they choose to do so, on or
before October 18, 2004.
Respectfully submitted,
ne ofRespondent’s attorneys
U
Mark A. LaRose
Clarissa C. Grayson
LAIROSE & BOSCO, LTD.
200 North LaSalle Street
Chicago, IL 60601
(312) 642-4414
Fax (312) 642-0434
Attorney No. 37346
2
CERTIFICATE OF SERVICE
The undersigned, an attorney, on oath states that she caused to be served a copy of the
foregoing RESPONDENTS EDWARD
PRUIM
AND
ROBERT PRIUIM’S MOTION FOR
LEAVE TO FILE A REPLY
to the following parties ofrecord, by placing same in the U.S. Mail,
postage prepaid this 5rn day ofOctober, 2004:
Mr. Christopher Grant
Environmental Bureau
Assistant Attorney General
188 West Randolph Street, 20t1~Floor
Chicago, IL 60601
Mr. Bradley Halloran
Hearing Officer
illinois Pollution Control Board
100 W. Randolph Street, Suite 11-500
Chicago, IL 60601
CQJ~uL~LC~
Attorney for Respondent
~
Mark A. LaRose
Clarissa C. Grayson
Attorney No. 37346
LaRose & Bosco, Ltd.
200 N. LaS alle Street
Suite 2810
Chicago, IL 60601
(312) 642-4414
