RECEIVED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
MAR
-
92005
STATEOF ILLINOIS
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
)
PollutIon Control Board
Complainant,
vs.
)
PCB 04-16
PACKAGING PERSONIFIED,
INC.,
)
(Enforcement)
an Illinois Corporation,
Respondent.
NOTICE OF FILING
PLEASE TAKE NOTICE that we have today, March
9,
2005,
filed
with the Office of the Clerk of the Illinois Pollution Control
Board its Response
to Motion to Modify,
a copy of which is
attached herewith and served upon you.
PEOPLE OF THE STATE OF ILLINOIS
By
LIS~IMADIG
Attor~y Gener
1 of the
liii ois
BY:
____________________
HRI
‘~OPHER
GRANT
ssstant Attorney General
vironmental Bureau
188 W. Randolph St.,
20th
Fir.
Chicago,
IL 60601
(312)
814-5388
BEFORE THE ILLINOIS POLLUTION CONTROL ~
MAR -92005
PEOPLE OF THE STATE OF ILLINOIS,
STATE OF ILLINOIS
Complainant,
)
Pollution
Control Board
vs.
)
PCB 04-16
PACKAGING PERSONIFIED,
INC.,
)
(Enforcement)
an Illinois corporation,
Respondent.
RESPONSE TO RESPONDENTS MOTION TO MODIFY
Complainant,
PEOPLE OF THE STATE OF ILLINOIS
,
by LISA
MADIGAN, Attorney General of the State of Illinois,
responds to
Respondent’s Motion to Modify Hearing Officer Order,
as follows:
1.
Respondent correctly notes that Complainant has not
responded to its written discovery request according to the
agreed schedule submitted to the Hearing Officer on December 15,
2004.
Complainant expects to respond to Respondent’s written
discovery request by March
15,
2005.
2.
Complainant also notes that it has did not file its
Motion to Amend by February 28,
as previously represented to the
Hearing Officer. Complainant expects
to file its motion to Amend,
along with a copy of the proposed amended complaint, before the
March 31,
2005 status in this case.
3.
Several factors contributed to this delay,
including
unexpected absences of Illinois EPA personnel,
and preparation
1
for trial
in another matter.
Complainant does not expect further
unexpected delays in prosecution of this case.
4.
In the event that the Board grants Complainant’s Motion
to Amend, discovery deadlines
in this matter will need to be
extended.
Complainant requests that a new discovery schedule be
discussed at the March 31, 2005 status in this case.
Complainant
will contact Respondent prior to the status to discuss an agreed
schedule.
WHEREFORE,
Complainant joins Respondent
in its request to
suspend the original discovery schedule,
and set a revised
schedule at the March 31,
2005 status.
Respectfully
Submitted,
LISA
MAJIGAN
Attorne/
GeneraVof the State of
Ill’nos
By:
~
Ch
i
t
her Grant
As~i~antAttorney General
Eni~ronmentalBureau
100 West Randolph,
11th
Floor
Chicago,
IL 60601
(312) 814-5388
2
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
vs.
)
PCB 04-16
PACKAGING PERSONIFIED,
INC.,
)
(Enforcement)
an Illinois corporation,
Respondent.
CERTIFICATE
OF SERVICE
I,
CHRISTOPHER GRANT,
an attorney,
do certify that
I caused
to be served this 9th day
of, March,
2005,
Complainant’s Response
to Respondent’s Motion to Modify upon the person listed below,
by
placing same in an envelope bearing sufficient postage with the
United States Postal Service located at
100 W.
Randolph,
Chicago
Illinois.
CHRISTOPHER GRANT
Service List:
Mr. Roy Harsch
Gardner Carton Douglas LLP
191 N.
Wacker Drive-Suite 3700
Chicago
IL
60606-1698
