1. BEFORE THE ILLINOIS POLLUTION CONTROL BOARBLERKS OFFICE
      2. CERTIFICATE OF SERVICE
BEFORE THE ILLINOIS
PEOPLE OF THE STATE OF ILLiNOIS,
Complainant,
vs.
COMMUNITY LANDFILL COMPANY,
INC., an Illinois corporation, and
the CITY OF MORRIS, an Illinois
municipal corporation,
Respondents.
RECEIVED
CLERK’S OFFICE
POLLUTION CONTROL BOARq’:~
2005
)
)
)
)
)
PCBNo.03-191
)
(Enforcement)
)
)
)
)
)
)
STATE OF QLINOJS
Palluton
Control
Board
NOTICE OF FILING
TO: Christopher Grant
Environmental Bureau
Assistant Attorney General
188 West Randolph Street
20th Floor
Chicago, Illinois 60601
Charles F. Heisten
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 North LaSalle Street, Suite 2810
Chicago, Illinois 60610
(312) 642-4414
Bradley Halloran
Hearing Officer
Illinois Pollution Control Board
100 West Randolph
Suite 11-500
Chicago, Illinois 60601
Scott Belt
Scott Belt and Associates, PC
105 East Main Street
Suite 206
Morris, Illinois 60450
PLEASE TAKE NOTICE that on October 12, 2005, the undersigned filed an original
and four copies of RESPONDENT COMMUNITY LANDFILL COMPANY INC.’S
MOTION FOR EXTENSION OF TIME TO RESPOND TO RESPONDENT CITY OF
MORRIS’ CROSS-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 ofwhich is attached and he
ed upon you.
One o the Attorneys for Community3tandfill Co.
THIS FILING IS SUBMITTED ON RECYCLED PAPER.
RECEIVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARBLERKS OFFICE
OCT 1
2005
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.
)
RESPONDENT COMMUNITY LANDFILL COMPANY INC.’S MOTION FOR
EXTENSION OF TIME TO RESPOND TO RESPONDENT CITY OF MORRIS’ CROSS-
MOTION FOR SUMMARY JUDGMENT
Respondent, Community Landfill Company, Inc., (“CLC” or “Respondent”) by and through
its attorneys LaRose & Bosco, Ltd., and pursuant to 35 Ill.Adm. Code 101.500(d) moves the Hearing
Officer Bradley Halloran and/or the Illinois Pollution Control Board for an extension of time to
respond to Respondent City of Morris’ Cross-Motion for Summary Judgment, (“City ofMorris” or
“Respondent” and in support thereof, states as follows:
1.
On October 4, 2005, Respondent City of Morris filed a Response to Complainant’s
Motion for Summary Judgment and Cross-Motion for Summary Judgment. Pursuant to 35 Ill.Adm.
Code 101.500(d), all responses to the Cross Motion for Summary Judgment are due to be filed on or
before October 21, 2005.
2.
Clarissa Grayson, the attorney for Respondent Community Landfill Co. who is
primarily responsible for filing the response, is getting married on October 15, 2005. She will be
away from the office forseveral days following her wedding and therefore, requests a short extension
1
in order to file the above referenced response.
3.
Granting a short extension will not result in prejudice to any ofthe parties involved in
this litigation.
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 Respond to
Respondent City ofMorris’ Cross-Motion for Summary Judgment and allow Respondent until on
or before October 31, 2005 to file its above-referenced response.
Respectfully submitted,
Attorney for Community Landfill Company
Mark A. LaRose
Clarissa C. Grayson
LAROSE & BOSCO, LTD.
Attorney No. 37346
200 North LaSalle Street, Suite 2810
Chicago Illinois 60610
(312) 642-4414
fax (312) 642-0434
2
CERTIFICATE OF SERVICE
I, Clarissa C. Grayson, an attorney hereby certify that I served a copy of the foregoing
RESPONDENT COMMUNITY LANDFILL COMPANY INC.’S MOTION FOR
EXTENSION OF TIME TO RESPOND TO RESPONDENT CITY OF MORRIS’ CROSS-
MOTION FOR SUMMARY JUDGMENT by placing the
same in the United States Mail,
first-class postage prepaid this
12th
day of October 2005, addressed as follows:
Mr. Christopher Grant
Mr. Scott Belt
Environmental Bureau
Scott Belt and Associates, PC
Assistant Attorney General
105 East Main Street
188 West Randolph Street
Suite 206
20th Floor
Morris, Illinois 60450
Chicago, Illinois 60601
Mr. Bradley Halloran
Mr. Charles F. Heisten
Hearing Officer
Hinshaw & Culbertson, LLP
Illinois Pollution Control Board
100 Park Avenue
100 West Randolph
P.O. Box 1389
Suite 11-500
Rockford, Illinois 61105-1389
Chicago, Illinois 60601
~u~C
One ofthe Attorneys for Community
(~
Landfill Co.
Mark A. LaRose
Clarissa C. Grayson
LaRose & Bosco, Ltd.
Attorney No. 37346
200 N. La5alle Street
Suite 2810
Chicago, Illinois 60610
(312) 642-4414

Back to top