1. NOTICE OF FILING
      2. AFFIDAVIT OF DAVID M. WALTER
CLERR~S(‘~FFTCF
BEFORE
~
BOARD
JUN
92003
PEOPLE OF THE STAT~FILLINOIS,
)
y.
)
PCB No. 03-22
)
(Enforcement)
SAINT-GOBAIN CONTAINERS, INC.,
)
a Delaware corporation,
STATE
OF ILLINOIS
PoJ/u~0~
Control Board
NOTICE OF FILING
TO:
Ms. Dorothy M. Gunn
Clerk of the Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois
60601
(VIA FIRST CLASS MAIL)
Carol Sudman, Esq.
Hearing Officer
Illinois Pollution Control Board
600 South Second Street
Suite 402
Springfield,
Illinois
62704
(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 four copies each ofSAINT-
GOBAIN CONTAINERS, INC.’S MOTION FOR EXTENSION OF TIME TO
RESPOND TO
COMPLAINANT’S DISCOVERY REQUESTS
and AFFIDAVIT
OF
DAVID M. WALTER
copies ofwhich is herewith served upon you.
Respectfully submitted,
SAINT-GOBAIN CONTAINERS, INC.,
Respondent,
Dated:
June 4, 2003
N. LaDonna Driver
David M. Walter
HODGE DWYER ZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois
62705-5776
(217) 523-4900
By:
David M. Walter
THIS FILING
SUBMITTED ON
RECYCLED PAPER
/
Complainant,
)
)
)
Respondent.
)
)
)
CERTIFICATE OF SERVICE
I, David M. Walter, the undersigned, certify that I have served the attached
SAINT-GOBAIN CONTAINERS, INC.’S MOTION FOR EXTENSION OF TIME TO
RESPOND TO COMPLAINANT’S DISCOVERY REQUESTS and AFFIDAVIT OF
DAVID M. WALTER upon:
Ms. Dorothy M. Gunn
Clerk ofthe Board
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, Illinois
60601
Carol Sudman, Esq.
Hearing Officer
Illinois Pollution Control Board
600 South Second Street
Suite 402
Springfield, Illinois
62704
Delbert D. Haschemeyer, Esq.
Assistant Attorney General
Office of the Attorney General
500 South Second Street
Springfield, Illinois
62706
by depositing said
documents in the United States Mail, postage prepaid, in Springfield,
Illinois
on June 4, 2003.
David M. Walter
SGCO:OO1/Fil/NOF-COS
—
Motion
for Ext.
RECEIVED
CLER~’~~
BOAJ~
92003
PEOPLE
OF
STATE OF ILLINOIS
Pollution
Control Board
Complainant,
)
)
v.
)
PCB No. 03-22
)
(Enforcement)
SAINT-GOBAIN CONTAINERS, INC.,
)
a Delaware corporation,
)
)
Respondent.
)
SAINT-GOBAIN CONTAINERS, INC.’S MOTION FOR EXTENSION
OF TIME TO
RESPOND TO COMPLAINANT’S DISCOVERY REQUESTS
NOW COMES the Respondent SA1NT-GOBAIN CONTAINERS, INC. (“Saint-
Gobain”), by and through its attorneys, HODGE DWYERZEMAN, and pursuant to 35
Ill. Admin. Code
§~
10 1.502,
101.522, and
101.610(n), requests that the Hearing Officer
grant Respondent’s Motion for Extension of Time to Respond to Complainant’s
Discovery Requests.
In support ofthis Motion, Respondent states as follows:
1.
On or about May
8, 2003, Complainant served its Requests for Production
and First Set ofInterrogatories Directed to
the Respondent on Saint-Gobain.
2.
Pursuant to the Illinois Pollution Control Board’s procedural rules at 35
Ill. Admin.
Code Part 101, responses to Complainant’s discovery are currently
due within
28
days ofservice,
i.e.,
on June
5,
2003.
3.
Saint-Gobain is attempting to respond to the Complainant’s discovery
requests.
Nevertheless, Saint-Gobain will be unable to complete its responses by June 5,
2003.
Therefore,
Respondent requests an extension oftime for 22 days, to
and including
June 27, 2003, in which to file its responses to Complainant’s discovery requests.
4.
This Motion is made in good faith and not for purposes ofdelay.
BEFORE THE
)
5.
Counsel for the Respondent has contacted counsel for the Complainant,
and he has indicated that he has no objection to this request being granted.
WHEREFORE, for the above and foregoing reasons, Respondent, SAINT-
GOBAIN CONTAINERS, INC., respectfully requests that the Hearing Officer grant this
Motion for Extension of Time, and allow Respondent an extension oftime for 22 days, or
until June 27, 2003,
in which to file its responses to Complainant’s Requests for
Production and First Set of Interrogatories Directed to the Respondent.
Respectfully submitted,
SAINT-GOBAIN CONTAINERS, INC.,
Respondent,
By:_______________
One of its Attorneys
Dated:
June4,
2003
N. LaDonna Driver
David M. Walter
HODGE DWYER ZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois
62705-5776
(217) 523-4900
SGCO:OOlIPil/Motion for Ext.
2
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE
OF THE
STATE OF ILLINOIS,
)
)
Complainant,
)
)
v.
)
PCB
No. 03-22
)
(Enforcement)
SAINT-GOBAIN CONTAINERS, INC.,
)
a Delaware corporation,
)
)
Respondent.
)
AFFIDAVIT OF DAVID M. WALTER
1.
I am a licensed Illinois attorney, and one ofthe counsel ofrecord for
Respondent,
Saint-Gobain Containers, Inc.
2.
I have assisted in the preparation of, and have reviewed, Respondent,
Saint-Gobain Containers, Inc. Motion for Extension ofTime to Respond to
Complainant’s Discovery Requests (“Motion”).
3.
The statements contained in the Motion, that are not otherwise ofrecord,
are true and accurate to the best of my knowledge and belief.
FURTHER AFFIANT SAYETH NOT.
David M. Walter
Subscribed and sworn to before
me this 4th day ofJune 2003.
NoZry~bi~6~’
~1I~
SGCO:OOlfFil/affidavit
-
motion for ext.

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