PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN, Attorney General
State of Illinois,
SMITHFIELD PROPERTIES, L.L.C.
An Illinois limited liability Company,
WOOTON CONSTRUCTION LTD., an
Illinois corporation, and CHICAGO SUN-TIMES,
INC., a Delaware Corporation,
RECE~VEO
CLERK’S OFFICE
JU~Ir1
Li 200k
STATE OF ILLINOIS
)
pollution COfltt0t Board
)
)
PCBO4-192
)
(Enforcement-Land, Water)
)
)
)
)
)
)
)
)
)
NOTICE OF FILING
TO:
Zemeheret Bereket-Ab, Esq.
Assistant Attorney General
Environmental Bureau
188W. Randolph Street, 20th Floor
Chicago, Illinois 60601
Kevin B. Hynes
O’Keefe, Lyons & Hynes, LLC
30 North LaSalle Street
Suite 4100
Chicago, Illinois 60602
PLEASE TAKE NOTICE that I have today filed with the Clerk ofthe Pollution Control
Board the
Agreed Motion to Hearing Officer for Extension of Time
ofChicago Sun-Times,
Inc., a copy ofwhich is herewith served upon you.
Janine M. Landow-Esser
Michael S. Mostow
QUARLES & BRADY LLC
500 W. Madison Street, Suite 3700
Chicago, Illinois 60661
312.715.5000
ATTORNEYS FOR RESPONDENT
CHICAGO SUN-TIMES, INC.
Mich~’elS.M6~stow~
THIS DOCUMENT IS SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Complainant,
vs.
Respondents.
QBCHI\20 12447001 9\378899. I
RECEIVED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
JUN 1 42004
PEOPLE OF THE STATE OF ILLINOIS
)
Pollution
Control
Board
LISA MADIGAN, Attorney General
)
State of Illinois,
)
)
Complainant,
)
)
No. PCB No. 04-192
vs.
)
(Enforcement-Land &
)
Water)
SMITHFIELD PROPERTIES, L.L.C.
)
An Illinois limited liability
)
Company, WOOTON CONSTRUCTION
)
LTD., an Illinois corporation, and
)
CHICAGO SUN-TIMES, INC., a Delaware
)
Corporation,
)
)
Respondents.
)
AGREED
MOTION TO
HEARING
OFFICER FOR EXTENSION OF TIME
Respondent, Chicago Sun-Times, Inc. (“Sun-Times”), by its attorneys, Quarles & Brady
LLP, requests that the Hearing Officer grant Sun-Times until July 23, 2004 to answer The State
ofIllinois’ complaint, and in support thereofstates as follows:
1.
Sun-Times’ answer to the complaint in this action was due on orbefore July 7,
2004.
2.
Shortly before July 7, 2004, in-house counsel for Sun-Times originally
responsible for this action was replaced. The in-house counsel for Sun-Times currently
responsible for this action requires additional time to learn about this action before Sun-Times
will be able to answer the complaint.
3.
Upon learning ofthis situation on July 7, 2004, counsel for Sun-times contacted
counsel for the State of Illinois and requested and received the State’s agreement to a motion to
extend the time for Sun-Times to answer the complaint. Counsel for the Sun-Times and the
—1—
State ofIllinois agreed during a conference call on July 13, 2004 that said motion should request
that Sun-Times have until July 23, 2004 to answer the complaint.
WHEREFORE, Sun-Times respectfully request that it be granted until July 23, 2004 to
answer the complaint in this action.
Respectfully submitted,
.~
Mich~’elS. M~ostow
Janine Landow-Esser
Michael S. Mostow
Quarles & Brady LLP
500 West Madison St., Suite 3700
Chicago, IL 60661
312.715.5158
ATTORNEYS FOR THE CHICAGO SUN-TIMES, INC.
THIS DOCUMENT IS SUBMITTED ON RECYCLED PAPER
QBCHI\3795 13.1
-2
