RECE!VED
CLERK’S OFFICE
OCT
142005
BEFORE THE
ILLINOIS POLLUTION CONTROL BOARD
STATE OF ILLINOIS
Pollution Control Board
SILBRICO CORPORATION,
Petitioner,
v.
)
PCBO6-O11
(Variance—land)
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent.
NOTICE OF
FILING
To:
(See attached Service
List.)
PLEASE
TAKE
NOTICE
that
on
this
14th
day
of
October
2005,
there
was
filed
with
the
Illinois
Pollution
Control
Board,
Petitioner Silbrico
Corporation’s
Motion for
Extension of Time, which
is attached
and herewith
served
upon you.
SILBRICO
CORPORATION
‘¼
QElizabethS.frla
ey
çj
One of its
attorneys
Elizabeth
S.
Harvey
Michael J. Maher
SWANSON,
MARTIN & BELL, LLP
One IBM
Plaza,
Suite 3300
330 North Wabash Avenue
Chicago,
Illinois 60611
Telephone: (312)
321-9100
CERTIFICATE OF
SERVICE
I,
the
undersigned
non-attorney,
state
that
I
served
a
copy
of
Petitioner
Silbrico
Corporation’s
Petition
for Variance
to counsel
of record
in
the
above-captioned
matter
via
U.S.
Mail at One IBM
Plaza,
Chicago,
IL 60611
on or before
5:00 pm.
on October
14,
2005.
~i1~
~
(j~fi~tte
Podlin
x)
Under penalties
as provided
by
law
pursuant to 735 ILCS
5/1-109,
I certify
that the statements set forth
herein
are
true
and correct.
2049-00
1
SERVICE LIST
Case
No. PCB 06-011
(Variance
--
Land)
Mark V. Gurnik, Assistant Counsel
Illinois
Environmental
Protection Agency
Division of Legal Counsel
1021
North Grand Avenue
East
P.O.
Box 19276
Springfield,
IL 62794-9276
BEFORE THE
ILLINOIS
POLLUTION CONTROL
BOARERECEIVED
CLERKS OFFICE
SILBRICO CORPORATION,
)
OCT
142005
STATE OF ILLINOIS
Petitioner,
)
Pollution Control Board
v.
)
PCB 06-011
(Variance—land)
ILLINOIS ENVIRONMENTAL
PROTECTION
AGENCY,
Respondent.
MOTION
FOR EXTENSION
OF TIME
Petitioner
SILBRICO
CORPORATION
(“Silbrico”),
by
its
attorneys
Swanson,
Martin
&
Bell,
LLP,
moves for
a further extension of time, to
and
including
October 24,
2005, to file
its
amended petition for variance.
1.
On
September
1,
2005,
the
Board
issued
an order directing
Silbrico to file
an
amended petition,
providing responses to issues identified
by the
Board.
That
order established
a deadline of October
3,
2005, to file the
amended
petition.
2.
On
October
3,
2005,
Silbrico filed
a
motion
for extension of time
to
October
11,
2005,
to allow it to gather all
of the
requested information.
3.
The process of gathering the
requested
information has taken
more time than
anticipated.
Therefore,
Silbrico seeks a further extension of time.
4.
Silbrico seeks an extension to October 24,
2005.
5.
In
the
absence
of an
extension,
Silbrico
will
suffer
prejudice.
Conversely,
Silbrico believes that a grant of a
short
extension will
not
prejudice the
Board,
the
Illinois
Environmental
Protection Agency (IEPA), or the
public.
6.
Counsel for
the
IEPA has no objection
to the grant of this
motion.
WHEREFORE,
Silbrico
moves
the
Board
for
an
extension
of
time,
to
and
including October 24,
2005, to file
its
amended petition for variance.
Respectfully submitted,
SILBRICO CORPORATION
By
Dated:
October
14,
2005
Elizabeth
S.
Harvey
Michael J.
Maher
Swanson,
Martin
& Bell,
LLP
One IBM
Plaza,
Suite 3300
330 North Wabash Avenue
Chicago,
Illinois
60611
Telephone:
(312) 321-9100
