1. NOTICE OF FILING
      2. THIS FILING IS SUBMITTED ON RECYCLED PAPER
      3. BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
      4. CERTIFICATE OF SERVICE
PEOPLE OF THE STATE OF ILLINOIS,
by LISAMADIGAN, Attorney General ofthe
State
ofIllinois,
V.
EDWARD PRUIM,
an individual, and
ROBERT PRUIM, an individual,
Respondents.
PCB No. 04-207
)
(Enforcement)
)
)
)
)
)
RECEiVED
CLERK’S
OFFICE
FEB
1
82005
STATE OF ILLINOIS
Poltutiofl Control Board
NOTICE OF FILING
TO:
Ms. Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R.
Thompson Center
100 W. Randolph Street, 11-500
Chicago,IL
60601
Mr. Bradley Halloran
Hearing Officer
Illinois Pollution Control Board
100 W. Randolph Street, Suite 11-500
Chicago,IL
60601
Mr. Christopher Grant
Assistant AttorneyGeneral
Environmental Bureau
188 W. Randolph, 20th Floor
Chicago, IL
60601
PLEASE TAKE NOTICE that on February 18, 2005, we filed with the Clerk ofthe
Illinois Pollution Control Board an original and four copies ofRESPONDENTS’
MOTION
FOR AN EXTENSION OF TIME TO RESPOND TO COMPLAINANT’S MOTION TO
STRIKE
AFFIRMATIVE DEFENSES,
a copy ofwhich is attached and herewith served upon
you.
Mark A. LaRose
Clarissa C.
Grayson
Attorney No. 37346
LaRose & Bosco, Ltd.
200 N. LaSalle Street, Suite 2810
Chicago, IL 60601
(312) 642-4414
Fax (312) 642-0434
p~~sp~tt
~
Attorney
BEFORE THE ILLINOIS POLLUTION CONTROLBOARD
Complainant,
)
)
)
)
)
)
THIS FILING IS SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF
THE STATE
OF ILLINOIS,
)
CLERK’S
OFFICE
)
FEB182005
Complainant,
)
)
STATEOFILLINOIS
VS.
)
PCB
No.
04-207
Pollution
Control Board
)
(Enforcement)
EDWARD PRUIM, an individual, and
)
ROBERT PRUIM,
an individual,
)
)
Respondents.
)
MOTION
FOR
AN
EXTENSION OF TIME TO RESPOND
TO COMPLAINANT’S
MOTION TO
STRIKE
AFFIRMATIVE DEFENSES
This matter coming before the Illinois Pollution Control Board and Hearing Officer Bradley
Halloran on Respondents’
Motion for an Extension ofTime to Respond to Complainant’s Motion to
Strike Affirmative Defenses, Edward Pruim
and Robert Pruim, Respondents, by and through their
attorneys, LaRose &
Bosco, Ltd., and in support thereof, state as follows:
1.
The Hearing Officerhas the authority to grant Respondent’s request for an extension
oftime pursuant to Section 101.522 ofthe Illinois Pollution Control Board rules (35111. Adm. Code
101.522)which states: “The Board orhearing officer, for good cause shown on a motion afternotice
to the opposite party, may extendthe time for filing any document or doing any actwhich is required
by these rules to be done within a limited period, either before or afterthe expiration oftime.”
2.
Complainant filed its Motion to
Strike Affirmative Defenses on February 4,
2005.
Counsel forRespondents received theMotion onFebruary
9,2005.
Respondents’ response is due on
February 22, 2005.
3.
Respondents hereby requesta short two-week extension oftime in which to respond
to
Complainant’s
MotiOn
due
to
numerous
conflicts
with
previously
scheduled
matters
and
1
CERTIFICATE OF SERVICE
The undersigned,
an
attorney,
on oath
states that
she caused to be
served
a copy of the
foregoing
RESPONDENTS’
MOTION
FOR
AN
EXTENSION
OF TIME
TO
RESPOND
TO
COMPLAINANT’S
MOTION
TO
STRIKE
AFFIRMATIVE
DEFENSES
to
the
following parties ofrecord, by hand delivery this
18th
day ofFebruary,
2005:
Mr. Christopher Grant
Environmental Bureau
Assistant Attorney General
188 West Randolph Street,
20th
Floor
Chicago, IL 60601
Ms. Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100
W. Randolph Street,
11-500
Chicago, IL
60601
Mark A. LaRose
Clarissa C. Grayson
Attorney No. 37346
LaRose & Bosco, Ltd.
200 N. LaSalle Street
Suite 2810
Chicago, IL 60601
(312) 642-4414
Mr. BradleyHalloran
Hearing Officer
illinois Pollution Control Board
100 W.
Randolph Street, Suite 11-500
Chicago,IL
60601
Attorney for Respondent
THIS FILING IS SUBMITTED ON RECYCLED PAPER

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