BEFORE THE ILLINOIS POLLUTION CONTROL BOARDRECEIVED
CLERK'S OFFICE
PEOPLE OF THE STATE OF ILLINOIS, )
Complainant,
)
vs.
)
PCB No . 04-207
(Enforcement - Land)
EDWARD PRUIM and ROBERT PRUIM, )
Respondents.
)
PEOPLE OF THE STATE OF ILLINOIS, )
Complainant,
)
vs.
)
PCB No . 97-193
(Enforcement - Land)
COMMUNITY LANDFILL COMPANY, )
(consolidated)
INC.,
)
Respondent .
)
NOTICE OF FILING
TO : Christopher Grant
Bradley Halloran
Environmental Bureau
Hearing Officer
Assistant Attorney General
Illinois Pollution Control Board
188 West Randolph Street, 20th Floor
100 West Randolph, Suite 11-500
Chicago, Illinois 60601
Chicago, Illinois 60601
PLEASE TAKE NOTICE that on December
8, 2005, the undersigned filed an original
and four copies of
EDWARD PRUIM AND ROBERT PRUIM'S MOTION FOR
EXTENSION OF TIME TO FILE MOTION FOR SUMMARY JUDGMENT
with Ms.
Dorothy Gunn, Clerk of the Illinois Pollution Control Board, 100 West Randolph Street, Suite
11-500, Chicago, Illinois 60601, a copy of which is attached and hereby served upon you
.
DEC
0 8 2005
STATE OF ILLINOIS
Pollution Control Board
One of the Attorneys for
Edward Pruim and Robert Pruim .
Mark A. LaRose
Clarissa C . Grayson
LAROSE & BOSCO, LTD.
Attorney No . 37346
200 North LaSalle Street, Suite 2810
Chicago, Illinois 60610
(312) 642-4414
THIS FILING IS SUBMITTED ON RECYCLED PAPER .
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVEDCLERK'S
OFFICE
PEOPLE OF THE STATE OF ILLINOIS, )
DEC 0 8 2005
Complainant,
)
Pollution
STATE OF
Control
ILLINOIS
Board
vs.
)
PCB No . 04-207
(Enforcement - Land)
EDWARD PRUIM and ROBERT PRUIM, )
Respondents.
)
PEOPLE OF THE STATE OF ILLINOIS, )
Complainant,
)
vs.
)
PCB No. 97-193
(Enforcement -
Land)
COMMUNITY LANDFILL COMPANY, )
(consolidated)
INC.,
)
Respondent .
)
RESPONDENTS EDWARD PRUIM AND ROBERT PRUIM'S MOTION
FOR EXTENSION OF TIME TO FILE MOTION FOR SUMMARY JUDGMENT
Respondents, Edward Pruim and Robert Pruim, by and through their attorneys LaRose &
Bosco, Ltd ., and pursuant to 35 II1 .Adm . Code 101
.500(d) moves the Hearing Officer Bradley
Halloran and/or the Illinois Pollution Control Board for an extension of time to file a Motion for
Summary Judgment on behalf of respondents in PCB No . 04-207 (Enforcement), and in support
thereof, states as follows :
1 .
On November 10, 2005, Hearing Officer Bradley Halloran entered an order wherein
Respondents were to file their Motion for Summary Judgment on or before December 14, 2005
.
2.
Counsel for Respondents Edward and Robert Pruim request a short extension, until
1
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01:50pm
From-IAGO-ENVIRONMENTAL BUREAU
+3128142347
T-624
P .003/003
F-638
12/08/2005
December
1a
:~a
23,
rnn
2005,
JI4o9LV't
in order
.'
to file the above referenced motion
.
3.
Granting a shod extension will not result in prejudice to any ofthe parties involved in
this litigation
. Counsel for Complainant, whose signature appears below,
does not object to
Respondents' motion for an extension of time,
4.
Granting the requested extension will not result in a continuation of the hearing date
previously scheduled for April 10-13, 2006 .
WHEREFORE, Respondents respectfully request
that the Board and/or Hearing Officer
Bradley Halloran enter an order GRANTING its Motion for an Extension of Time to File its
Motion for Summary Judgment and allow Respondent until on or before December 23, 2005 to
file its above-referenced motion
.
Respectfully submitted,
Mark A. L aRose
Clarssa C
. Gmyson
LAROSE & BOSCO, LTD .
Attorney No. 37346
200 North LaSalle Sheet, Suite 2810
Cbleago Illinois 60610
(312) 642-4414
fax (312) 642-0434
2
Mr. Christopher Grant
Environmental Bureau
Assistant Attorney General
188 West Randolph Street
20th Floor
Chicago, Illinois 60601
Ms . Dorothy M . Gunn
Illinois Pollution Control Board
100 West Randolph
Suite 11-500
Chicago, Illinois 60601
Mark A . LaRose
Clarissa C. Grayson
LaRose & Bosco, Ltd
.
Attorney No . 37346
200 N. LaSalle Street
Suite 2810
Chicago, Illinois 60610
(312) 642-4414
CERTIFICATE OF SERVICE
I, Clarissa C. Grayson, an attorney hereby certify that I served a copy of the foregoing
RESPONDENTS EDWARD PRUIM AND ROBERT PRUIM'S MOTION FOR
EXTENSION OF TIME TO FILE MOTION FOR SUMMARY JUDGMENT by placing
the same in the United States Mail, first-class postage prepaid this S tn day of December 2005,
addressed as follows:
Bradley Halloran
Hearing Officer
Illinois Pollution Control Board
100 West Randolph
Suite 11-500
Chicago, Illinois 60601
C <
One of the Attorneys for
Edward Pruim and Robert Pruim
