JUL—27—2009
15:32
JENNER
&
BLDCK
3125270484
P.02
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
CLERK’S
OFFICE
PEOPLE
OF THE
STATE
OF
ILLINOIS,
)
)
iUL22OO
9
Complainant,
)
TE
OF
ILLINOIS
pitiofl
Control
Board
v.
)
PCB
NO.
09-110
)
(Enforcement-Land)
E.F. HElL,
LLC,
an
Illinois
limited
liability
)
company,
)
Respondent.
)
NOTICE
OF
IILING
TO:
Illinois
Pollution
Control
Board,
Ann:
Clerk
100
W.
Randolph
Street
Suite
11-500
Chicago.
lilinois
60601
Brad
P.
Halloran
Hearing
Officer
Illinois
Pollution
Control
Board
100 W.
Randolph
Street
Suite
11-500
Chicago,
IL
60601
PLEASE
TAKE
NOTICE
that
I
have
today,
by
facsimile,
filed
with
the Office
of
the
Clerk
of
the
Pollution
Control
Board
the parties’
Joint
Motion
for
an
Extension
of
Time
to
Answer
or
Otherwise
Respond,
and
Appearance
of
Bill S.
Forcade,
copies
of
which
are
herewith
served
upon
you.
Bill S.
Forcade
Jenner
&
Block
LLP
330
N.
Wabash
Avenue
Chicago,
IL
60611
312/923-2964
Dated:
July
28, 2009
I
783
38,1
JUL—27—2009
15:32
JENNER
a
BLOCK
3125270464
P.03
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
PEOPLE
OF
THE
STATE
OF
ILLJNOIS,
)
)
Complainant,
)
)
v.
)
PCB NO.
09-110
)
(Enforcement-Land)
E.F.
HElL, LLC,
an
Illinois
limited
liability
)
eompany,
)
Respondent
)
JOINT.M.OTION
FOR
AN
EXTENSION
O
TIME
TO
ANSWER
OR
OTHERWISE RESPOND
NOW
COMES
the
Respondent,
E.F.
ileil, LLC,
an
Illinois
limited
liability
company,
by
and
through
its
attorney,
and
Complainant,
The
People
of
the
State
of
Illinois,
by
and
through its
attorney
and
respectfully
request
that
this
Board
grant
an
extension
up
to
and
including
Friday,
August 28,
2009
to
answer or
otherwise
respond.
In support
of
this
Motion,
the
Respondent
states
as
follows:
1.
This
matter arose from
a
complaint
filed
by
The
People of
the
State
of
Illinois
alleging
various
violations
regarding
Respondents
clean
construction
and
demolition
debris
(CCDD)
facility,
located at
CR
089SE,
in Kankakee,
Kankakee
County
2.
The
Parties
have
been
negotiating
a
settlement
agreement
and
have
reached
substantial
agreement
on
the
terms
and
conditions
of
such
settlement
agreement.
The
parties
anticipate
that
such
an
agreement
can
be
filed
within
the
next
30
days.
3.
The
Complainant
has
previously
agreed
to
extend
the
time
to
answer
or
otherwise
respond
4.
Complainant,
The
People
of
the
State
of
Illinois,
has
reviewed
and
approved
filing
this
Joint
Motion
for
an
Extension
of
Time
to
Answer
or
Otherwise
Respond.
1753366,
JUL—27—2009
15:32
JENNER
BLOCK
3125270494
P.04
WHEREFORE,
Respondent,
E.F.
Heil,
LLC,
an
Illinois
limited
liability
company,
and
Complainant,
The
People
of
the
State
of
Illinois,
request
that
this
Board
grant
it
an
extension
up
to
and
including
lriday, August
28,
2009,
in
Bill
S.
Forcade
Jenner
&
Block LLP
Attorney
for
E.F.
Neil,
LLC,
an
Illinois limited
liability
company
330
N.
Wabash
Avenue
Chicago,
IL
60611
312/923-2964
Dated: July
28,
2009
1783366.1
JUL—27—2009
15:33
JENNER
&
BLOCK
3125270484
P.05
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
)
)
Complainant,
)
)
v.
)
PCB
NO.
09-110
)
(EnforcementLand)
EF.
HElL,
LLC,
an
Illinois
limited
liability
)
company,
)
Respondent.
)
APPEARANCE
The
undersigned,
Bill
S.
F’orcade,
as
attorney,
enters
the
appearance of
Respondent,
BY.
Heil,
LLC,
an Illinois
limited
liability
company.
Bill
S. Forcade
Jernier
& Block
LLP
Attorney
for
BY.
Hell,
LLC,
an
Illinois
limited
liability
company
330
N.
Wabash
Avenue
Chicago,
IL
60611
312/923-2964
Dated:
July
28,
2009
Bill
1783363.1
JUL—27—2009
15:33
JENNER
&
BLOCK
3125270494
P.06
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
)
)
Complainant,
)
)
v.
)
PCU
NO.
09-1
10
)
(Enforcement-Land)
E.F.
HElL,
LLC, an
Illinois
limited
liability
)
company,
)
Respondent.
)
PROOF
OF
SERVICE
NOW
COMES
the
Respondent,
E.F.
Heil, LLC,
an
Illinois
limited
liability
company,
by
and
through
its
attorney,
and
pursuant
to
the
Board’s
procedural
rules, provides
proof
of
service
of
the
attached
Appearance
and
Joint
Motion
for
Extension
of
Time
to
Answer
or
Otherwise
Respond
on
Stephen
J.
Sylvester,
Assistant
Attorney
General,
Illinois
Attorney
General’s
Office,
Environmental
Bureau
North,
69
W.
Washington
Street,
Suite
1800,
Chicago,
IL.
Bill
S.
Forcade
Jenner &
Block
LLP
Attorney
for
EF. Hell,
LLC,
an
Illinois
limited
liability
company
330
N.
Wabash
Avenue
Chicago,
IL
60611
312/923-2964
Dated:
July
28,
2009
[783401.1
TOTIL
P.06
JUL—27—2009
15:32
JENNER
g
BLOCK
3125270484
P.01
FAXTRANSMITTAL
JENNER&LQCK
Jenner
&
Block
LLP
Chicago
S30
N.
Wabash
Avenue
Los
Angeles
Chicago.
IL
60611
NewYork
Tel
312
222.0350
Washington,
DC
www.jenner.com
Date:
July
28, 2009
To:
Illinois
Pollution
Control
Board
Fax:
312-814-3669
Attention:
Clerk
From:
Bill S
Forcade
Fax:
312-840-1364
bforcactejenner.com
Voice:
312-923-2964
Client
27008
-
10651
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Thank
you.
Message:
--
-
FILING
BY
FACSIMILE
APPROVED
BY
KATHLEEN
CR0
WLEY
cVED
CLERK’S
OFFICE
JUL
2
82009
STATE
OF
ILLINOIS
ollutton
Control
Board
Total
number
of
pages
including
this
cover
sheet:
Time
Sent:
If
you
do
not
receive
all
pages
pleaae
call:
312
222-9350
Sent
By:
Janet
K.
Wall
Extension:
8863