BEFORE THE ILLiNOIS POLLUTION CONTROL BOARD
PEOPLE OF
THE STATE OF ILLINOIS,
)
)
Complainant,
)
)
v..
)
)
REILLY INDUSTRIES, INC.,
)
)
Respondent.
)
PCB No. 03-182
R~CE1V~
CLERK’S OFFICE
APR U’~
2005
STATE OF
ILUNO1S
pollution Control Board
(Enforcement
—
Air, Water)
NOTICE OF FILING
TO:
Ms. Dorothy M. Gunn
Clerk ofthe Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois
60601
(VIA
FIRST CLASS
MAIL)
Carol Webb, Esq.
Hearing Officer
Illinois Pollution Control Board
1021
North Grand Avenue East
Post Office Box
19274
Springfield, Illinois
62794-9276
(VIA FIRST CLASS
MAIL)
(SEE PERSONS ON ATTACHED SERVICE LIST)
PLEASE TAKE NOTICE that I have today filed with the Office ofthe Clerk of
the Illinois Pollution Control Board an original and nine copies ofa
MOTION FOR
EXTENSION
OF TIME,
a copy of which is hereby served upon you.
Respectfully submitted,
Dated:
April
1, 2005
Thomas G. Safley
N. LaDonna Driver
HODGE DWYER ZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois
62705-5776
(217) 523-4900
By:
REILLY INDUSTRIES, INC.,
Respondent,
THIS FILING
SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION ~
PEOPLE OF THE STATE OF ILLiNOIS,
)
Complainant,
)
~
~
v.
)
PCB No. 03-182
)
(Enforcement
—
Air, Water)
REILLY iNDUSTRIES, INC.,
)
)
Respondent.
)
MOTION FOR EXTENSION OF TIME
NOW COMES Respondent REILLY INDUSTRIES, INC. (“Reilly”), by its
attorneys, HODGB DWYER ZEMAN, and requests that the Illinois Pollution Control
Board (“Board”) enter an
Order granting Reilly an extension oftime
for fourteen (14)
days, to
and including April 17, 2005, in which to file its Answer in the above-captioned
matter.
In support ofthis Motion, Reilly states as follows:
1.
On April 8, 2003, the People of the State of Illinois
(“the State”) filed a
Complaint in the above-captioned matter, alleging violations ofthe Environmental
Protection Act.
On November 26, 2003, the State filed its First Supplemental Complaint
alleging violations of Sections 9(à) and (b) (415 ILCS
5/9
(a) and (b)), Sections 2 1(e) and
(f)
(415
ILCS
5/21(e) and (f), and Section
12(d) (415 ILCS
5/12(d))
ofthe Environmental
Protection Act.
2.
The law firm ofHODGE DWYER ZEMAN was retained by Reilly to
represent it in the above-captioned matter, and filed its
entry of appearance on
August
5,
2004.
3.
Pursuant to the Hearing Officer Order dated October
14, 2004, Reilly’s
Answer was due October
18, 2004.
4.
On October 18, 2004,
Reilly filed its
Answer and Affirmative Defenses to
the State’s First Supplemental Complaint.
5.
On February
1, 2005, the State filed its Second Supplemental Complaint,
allegingviolations ofthe Environmental Protection Act.
6.
The deadline for filing an Answer to
the State’s Second Supplemental
Complaint is currently April 3, 2005.
7.
Counsel is requesting an extension oftime for fourteen (14) days, or until
April
17, 2005, so that Reilly may complete its Answer to the State’s Second
Supplemental Complaint.
8.
Counsel for Reilly has conferred with counsel for the
State and was
advised that Counsel for the
State has no objection to this Motion.
WHEREFORE, Respondent Reilly Industries,
Inc., respectfully requests that the
Board enter an Order granting this request for an extension oftime for fourteen (14) days,
to
and including April
17, 2005, in which to file its Answer to the State’s Second
Supplemental Complaint.
Respectfully submitted,
REILLY INDUSTRIES, INC.,
Respondent,
Dated:
April
1, 2005
By:_________________________
One
Att~rfi~rs
Thomas G. Safley
N. LaDonna Driver
HODGE DWYER ZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois
62705-5776
(217) 523-4900
REIL:005/Pil/Motion for Extension
CERTIFICATE OF SERVICE
I, Thomas G.
Safley, the undersigned, certify that I have served the attached
MOTION FOR EXTENSION OF TIME, upon:
Ms.
DorothyM. Gunn
Clerk of the Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois
60601
Carol Webb, Esq.
Hearing Officer
Illinois Pollution Control Board
1021
North Grand Avenue East
Post Office Box 19274
Springfield, Illinois
62794-9274
Thomas Davis, Esq.
Office ofthe Attorney General
Environmental Bureau
500 South Second
Street
Springfield, Illinois
62706
by depositing said documents in the United States Mail, postage prepaid, in
Springfield,
Illinois, on April
1, 2005.
REIL:OO5IFilingsiNOF-COS
-
MET
