BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CER~EoV
IED
DEC 1 G 2005
P
SSTA of OF ILLINOIS
Control Board
PEOPLE OF THE STATE OF ILLINOIS,
)
Complainant,
)
vs .
)
PCB No. 04-207
(Enforcement - Land)
EDWARD PRUIM and ROBERT PRUIM, )
Respondents .
)
vs .
)
Respondent .
)
NOTICE OF FILING
TO :
Christopher Grant
Bradley Halloran
Environmental Bureau
Hearing Officer
Assistant Attorney General
Illinois Pollution Control Board
188 West Randolph Street, 20th Floor
100 West Randolph, Suite 11-500
Chicago, Illinois 60601
Chicago, Illinois 60601
PLEASE TAKE NOTICE that on December 16, 2005, the undersigned filed an original
and nine copies of RESPONDENTS EDWARD PRUIM AND ROBERT PRUIM'S
MOTION FOR EXTENSION OF TIME TO FILE MOTION FOR SUMMARY
JUDGMENT with Ms. Dorothy Gunn, Clerk of the Illinois Pollution Control Board, 100 West
Randolph Street, Suite 11-500, Chicago, Illinois 60601, a copy of which is attached and hereby
served upon you .
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
COMMUNITY LANDFILL COMPANY,
INC.,
Mark A. LaRose
Clarissa C. Grayson
LAROSE & BOSCO, LTD
.
Attorney No. 37346
200 North LaSalle Street, Suite 2810
Chicago, Illinois 60610
(312) 642-4414
PCB No. 97-193
(Enforcement -Land)
(consolidated)
One of the Attorneys for
Edward Pruim and Robert Pruim .
THIS FILING IS SUBMITTED ON RECYCLED PAPER.
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
RECEIVED
Complainant,
)
CLERICS OFFICE
vs .
)
PCB No. 04-207
DEC 1 6 2005
(Enforcement -LattATE
OF ILLINOIS
EDWARD PRUIM and ROBERT PRUIM, )
Pollution Control Board
Respondents .
)
PEOPLE OF THE STATE OF ILLINOIS,
)
Complainant,
)
vs
.
)
PCB No. 97-193
(Enforcement - Land)
COMMUNITY LANDFILL COMPANY,
)
(consolidated)
INC .,
)
Respondent .
)
RESPONDENTS EDWARD PRUIM AND ROBERT PRUIM'S MOTION
FOR EXTENSION OF TIME TO FILE MOTION FOR SUMMARY JUDGMENT
Respondents, Edward Pruim and Robert Pruim, by and through their attorneys LaRose &
Bosco, Ltd., and pursuant to 35 Ill.Adm. Code 101.500(d) moves the Hearing Officer Bradley
Halloran and/or the Illinois Pollution Control Board for a brief extension of time to file a Motion for
Summary Judgment on behalf of respondents in PCB No. 04-207 (Enforcement), and in support
thereof, states as follows :
On December 15, 2005, Counsel for Respondents Edward Pruim and Robert Pruim
were notified that on December 12, 2005, Respondent Robert Pruim underwent emergency open
heart surgery which involved a quadruple bypass procedure . As such, he is currently unable to
1
participate in the preparation of the Motion for Summary Judgment which concerns a twenty count
complaint. Based on this unforeseen circumstance, Respondents therefore request an additional
short extension until Friday, January 13, 2006 to file their Motion for Summary Judgment
.
2 .
Respondents have previously requested a very short extension from December 14,
2005 until December 23, 2005 . This motion, currently pending before Hearing Officer Halloran
and/or the Pollution Control Board, was unopposed by the Complainant, People of the State of
Illinois .
3
.
Granting this short extension to Respondents under this circumstance will not result
in a continuation of the hearing date previously scheduled for April 10-13, 2006, and will not cause
any prejudice to Complainant
.
WHEREFORE, Respondents respectfully request that the Board and/or Hearing Officer
Bradley Halloran enter an order GRANTING their Motion for an Extension of Time to File its
Motion for Summary Judgment and allow Respondents a short extension until on or before
January 13, 2006 to file their above-referenced motion
.
Respectfully submitted,
LaROSE & BOSCO, LTD
.
2
Attorney for Edward Pruim and Rob
Pruim
Mark A. LaRose
Clarissa C. Grayson
LAROSE & BOSCO, LTD .
Attorney No. 37346
200 North LaSalle Street, Suite 2810
Chicago Illinois 60610
(312) 642-4414
fax (312) 642-0434
CERTIFICATE OF SERVICE
I, Clarissa C. Grayson, an attorney hereby certify that I served a copy of the foregoing
RESPONDENTS EDWARD PRUIM AND ROBERT PRUIM'S MOTION FOR
EXTENSION OF TIME TO FILE MOTION FOR SUMMARY JUDGMENT by placing
the same in the United States Mail, first-class postage prepaid this 16`h day ofDecember 2005,
addressed as follows :
Mr. Christopher Grant
Environmental Bureau
Assistant Attorney General
188 West Randolph Street
20th Floor
Chicago, Illinois 60601
Ms. Dorothy M. Gunn
Illinois Pollution Control Board
100 West Randolph
Suite 11-500
Chicago, Illinois 60601
Mark A. LaRose
Clarissa C. Grayson
LaRose & Bosco, Ltd .
Attorney No. 37346
200 N. LaSalle Street
Suite 2810
Chicago, Illinois 60610
(312) 642-4414
Bradley Halloran
Hearing Officer
Illinois Pollution Control Board
100 West Randolph
Suite 11-500
Chicago, Illinois 60601
One of the Attorneys for
Edward Pruim and Robert Pruim
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