2—I4-c:6:4:o~pM:
217744
711
RECE~VED
CLERK’S OFFICE
TN.E ILLINOIS POLLUTION CONTROL BOARD
FEB 142005
PAUL and DONNA FREDRICKSON,
)
STATE OF ILLINOIS
husband and wife
)
Pollution Control Board
CompIain~nts
)
)
V.
)
PCB04-19
Jeff Grelyak,
)
Respondent.
)
NOTICE OF FILING
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the Pollution
Control Board Respondent’s Motion for Extension of Time. Said Motion is directed to Hearing
Officer Bradley P. Halloran.
CERTIFICATE OF SERVICE
I, the undersigned, certify that I have today served Respondent’s Motion for Extension of Time
to the entities listed below by telefax to (312) 814-3669 and by placing said documents in
envelopes with proper postage affixed and by depositing said envelopes in a U.S. Postal
Service receptacle in Springfield, Illinois. Said envelopes being addressed to the following:
Illinois PoJIution Control Board
Attention: Clerk
100 W. Randolph Street
Jeremy W. Shaw, Esq.
James R. Thompson Center
40 Brink Street
Suite 11-500
Crystal Lake, Illinois 60014
Chicago, Illinois 60601
An additional copy of the document was included in the envelope addressed to the Clerk of the
PCB, which copy is to be given to Hearing Officer Halloran.
Date: 14 February 2005
George W. Tin kham,
attorney for Respondent
ARDC reg. # 2836149
1119
S. 6~Street
Springfield, IL 62703
(217) 523-8300
2—14—05: 4:01PM
2177441711 ;~ 2
THE ILLINOIS POLLUTION CONTROL BOARD
RECE~V~D
CLERK’S OFFICE
PAUL and DONNA FREDRICKSON,
)
FEB 142005
husband and wife
)
STATEOFIWNO1S
Complainants
)
pollution Control Board
v.
)
PCB04-19
Jeff Grelyak,
Respondent.
MOTION FOR EXTENSIQN OF TIME
COMES NOW, Respondent by his attorney George W. Tinkham, and asks that he be granted
an extension of time to file his Motion for Summary Judgment. I support of this Motion,
Respondent states as follows:
1 Hearing Officer Halloran entered an order in this matter on 27 January 2005 directing that
Respondent’s motion for summary judgment is clue on or before
14
February 2005.
2. Shortly after that Order, Respondent submitted a Second Request to Admit to Complainant.
3. Counsel for Complainant communicated to Respondent’s lawyer that the response to the
request to admit was anticipated to be made in less than the 28 days allowed by Illinois
Pollution Control Board Procedural Rule 100.818(a).
4. Counsel has not yet received the response to the second set of requests to admit.
5. The response to the second set of requests to admit is needed before a Motion for
Summary Judgment can be made.
6. The purpose of this Motion is not to cause delay,
7, The granting of this Motion will not cause hardship on either party.
8. Granting this Motion may shorten and expedite the proceedings by allowing at least a partial
judgment on the pleadings.
NOW, THEREFORE, RESPONDENT asks that he be granted three (3) business clays from the
time that he receives a response to his second set of requests to admit to submit his motion for
summary judgment in this matter. If a date certain for such deadlineis to be set, Respondent
asks that the date be Monday, 9 March 2005. Respondent further asks that all other deadlines
—
in th is matter be extended accordingly.
Respectfully submitted,
Jeffre~.Grelyak, Respondent
Date: 14 February 2005
By
George W. Tinlcham, his attorney
ARDC # 2836149
GeorgeW. Tinkham, 1119 South
6th
Street, Springfield, IL 62703; (217) 523-8300