BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
vs.
PCB No . 03-191
(Enforcement)
COMMUNITY LANDFILL COMPANY,
INC., an Illinois corporation, and
the CITY OF MORRIS, an Illinois
municipal corporation,
Respondents.
TO
: Christopher Grant
Environmental Bureau
Assistant Attorney General
188 West Randolph Street
20th floor
Chicago, Illinois 60601
Charles F. Helsten
Scott Belt
Hinshaw & Culbertson, LLP
Scott Belt and Associates, PC
100 Park Avenue
105 East Main Street
PLO . Box 1389
Suite 206
Rockford, Illinois 61105-1389
Morris, Illinois 60450
PLEASE TAKE NOTICE that on March 8, 2006,
the undersigned filed an original and
four (4) copies of RESPONDENT'S COMMUNITY LANDFILL COMPANY AND THE
CITY OF MORRIS' JOINT RESPONSE TO COMPLAINANT'S
MOTION TO SET
EXPEDITED HEARING DATE
with Ms . Dorothy Gunn, Clerk of the Illinois Pollution
Control Board, 100 W
. Randolph Street, Suite 11-500, Chicago, Illinois 60601, a copy of which
is attached and hereby served upon you .
Mark A. LaRose
Clarissa C. Grayson
LAROSE & BOSCO, LTD .
Attorney No . 37346
200 North LaSalle Street, Suite 2810
Chicago, Illinois 60610
(312) 642-4414
NOTICE OF FILING
Bradley Halloran
Hearing Officer
Illinois Pollution Control Board
100 West Randolph
Suite I I
Chicago, Illinois 60601
FOUR
One o he Attorneys for Community Landfill Co
.
THIS FILING IS SUBMITTED ON RECYCLED PAPER .
PEOPLE OF THE STATE OF
IT
LINOIS, )
Complainant,
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
vs .
PCB No . 03-191
Enforcement
COMMUNITY LANDFILL COMPANY ;
INC.,
an Illinois corporation, and
the CITY OF MORRIS, an Illinois
municipal corporation,
Respondents .
RESPONDENTS' COMMUNITY LANDFILL COMPANY AND THE CITY OF
MORRIS' JOINT RESPONSE TO COMPLAINANT'S MOTION TO SET
EXPEDITED HEARING DATE
Respondents COMMUNITY LANDFILL COMPANY and THE CITY OF MORRIS hereby
jointly respond to the Complainant, PEOPLE OF THE STATE OF ILLINOIS' Motion to Set
Expedited Hearing Date, and in support thereof, state as follows
:
PROCEDURAL HISTORY
On April 16,
Complarnarit People of the State of Illinois ("Complainant or
"People") fi ed a One-Co
complaint against Respondents Community Landfill Company and the
City of Morris ("Respondents", collectively, or "CLC or "City", individually) alleging violations of
35 Ill.Adm. Code 800
.700(f) and 800 .712(b) resulting in violation of Section 21(d)(2) of the Illinois
Environmental Protection Act ("the Act") .
Complainant filed a Motion for Summary Judgment on July 21, 2005 to which
Respondents appropriately and timely filed its responses and/or cross-motions and/or motion to
strike
. The Board's Order concerning the parties' various motions is dated February 16, 2006
.
1
"imperative" that the
Board with the r u
Board did not
e ,
on certain issue
a ropriate. (Order, p. 16).
CONCLUSION
fling, Respondents
Community
Landfill Comp
e Boar and/or the Hearing Offi DENNY Co
allo Re pond
Attorney for Community Landfill Company
o
of
(312) 642-4414
the opportunity o
process as soon as possible" and "provide the
ete mischaract
lion the process. The
arties to
proceed to hearing
Mark A. LaRose
Clarissa C. Grayson
LaRose &Bosco, Ltd.
200 N. LaSalle Street,
Chicago, IL 60601
ite 2810
Charles F. Helsten
Richard Porter
Hinshaw & Culbertson
100 Park Avenue
Rockford IL 61105-1389
CERTIFICATE OF SERVICE
I, Clarissa C
. Grayson, an attorney hereby certify that I served a copy of the foregoing
RESPONDENT'S COMMUNITY LANDFILL
COMPANY AND THE CITY OF
MORRIS' JOINT RESPONSE TO COMPLAINANT'S MOTION TO SET EXPEDITED
HEARING DATE
by facsimile transmission from fax number (312) 642-0434 and by placing
same in first-class postage prepaid envelopes and depositing same in the U
.S. Mail Box located
at 200 N. LaSalle Street, Chicago, Illinois, this 8
th day of March 2006, addressed as follows
:
BY FAX (312) 814-2549 & U
.S. MAIL
Christopher Grant
Environmental Bureau
Assistant Attorney General
188 West Randolph Street
20th Floor
Chicago, Illinois 60601
BY FAX (815) 490-4901& U .S. MAIL
Charles F. Helsten
Hinshaw & Culbertson, LLP
100 Park Avenue
P.O. Box 1389
Rockford, Illinois 61105-1389
Mark A. LaRose
Clarissa C. Grayson
LaRose & Bosco, Ltd .
Attorney No . 37346
200 TV: LaSalle Street
Suite 2810
Chicago, Illinois 60610
(312) 642-4414
BY FAX (815) 941-4677 & U .S. MAIL
Scott Belt
Scott Belt and Associates, PC
105 East Main Street
Suite 206
Morris, Illinois 60450
BY HAND-DELIVERY
Bradley Halloran
Hearing Officer
Illinois Pollution Control Board
100 West Randolph
Suite 11-500
Chicago, Illinois 60601
One of the Attorneys for Community Landfill Co .
I
