NOTICE OF FILING
To:
Ms. Jane E. McBride
Assistant Attorney General
Environmental Bureau
500 S. Second Street
Springfield, IL 62706
Mr. Charles M. Gering
McDermott, Will & Emery
227 West Monroe Street
Chicago, IL 60606-5096
PLEASE TAKE NOTICE that I have today filed with the Office of the
Clerk of the Pollution Control Board a Motion for Extension of Time Within
Which to File a Response to Complainant’s Amended Complaint, a copy of
which is herewith served upon you.
Jeffrey W. Tock
Harrington, Tock & Royse
201 W. Springfield Avenue, Suite 601
P.O. Box 1550
Champaign, IL 61824-1550
Telephone: (217) 352-4167
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Tock
BEFORE THE ILLINOIS POLLUTION CONTROL BOAR~ECEIVED
CLERK’S OFFICE
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
vs.
THE HIGHLANDS, LLC, an Illinois limited
liability corporation, MURPHY FARMS, INC.,
a/k/a MURPHY FAMILY FARMS, a North
Carolina corporation, and BION
TECHNOLOGIES, INC., a Colorado
corporation,
Respondents.
JUN 112003
STATE OF ILLINOIS
Pollution Control Board
PCB No. 00-104
(Enforcement)
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June 6, 2003
RECEIVED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
JUN 112003
PEOPLE OF THE STATE OF ILLINOIS,
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STATE OF ILLINOIS
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Pollution Control Board
Complainant,
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vs.
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PCB No. 00-104
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(Enforcement)
THE HIGHLANDS, LLC, an Illinois limited
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liability corporation, MURPHY FARMS, INC.,
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a/k/a MURPHY FAMILY FARMS, a North
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Carolina corporation, and BION
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TECHNOLOGIES, INC., a Colorado
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corporation,
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Respondents.
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MOTION DIRECTED TO THE HEARING OFFICER FOR
EXTENSION OF TIME WITHIN WHICH TO RESPOND TO
COMPLAINANT’S AMENDED COMPLAINT
COMES NOW the Respondent The Highlands, L.L.C. by its attorneys,
Harrington, Tock & Royse, and respectfully moves the Hearing Officer for an
extension of time within which to respond to the Amended Complaint in this
matter and, in support thereof, states as follows:
1. By Hearing Officer Order dated March 19, 2003, this Respondent was
required to answer or otherwise plead to the Amended Complaint of
the Complainant on or before June 6, 2003.
2. Although counsel for The Highlands has been working diligently in
preparation of a response to the Amended Complaint, the response is
not ready to be filed as of June 6, 2003 as previously ordered.
3. On June 6, 2003, counsel for The Highlands spoke with Ms. Jane
McBride of the Illinois Attorney General’s office and inquired as to
whether or not the Illinois Attorney General’s office had any objection
to an extension of 7 days for the Respondent to file its response to the
Amended Complaint. Ms. McBride, on behalf of the office of the
Illinois Attorney General, stated that she had no objection to the
extension requested.
WHEREFORE, the Respondent The Highlands, LLC respectfully requests
that the time within which it is required to respond to the Amended Complaint
be extended through Friday, June 13, 2003.
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ock, Attorney
Prepared by:
Jeffrey W. Tock
Harrington, Tock & Royse
201 W. Springfield Avenue
P.O. Box
1550
Champaign, IL 61824-1550
Telephone: (217) 352-4167
CERTIFICATE OF SERVICE
I hereby certify that I did on June 6, 2003, send by First Class Mail, with
postage thereon fully prepaid, by depositing in a United States Post Office Box a
true and correct copy of the following instruments entitled Motion for Extension
of Time Within Which to File a Response to Complainant’s Amended Complaint
To:
Ms. Jane E. McBride
Assistant Attorney General
Environmental Bureau
500 S. Second Street
Springfield, IL 62706
Mr. Charles M. Gering
McDermott, Will & Emery
227 West Monroe Street
Chicago, IL 60606-5096
and the original and four copies by First Class Mail with postage thereon fully
prepaid of the same foregoing instrument(s):
To:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
State of Illinois Center
100 W. Randolph, Suite 11-500
Chicago, IL 60601
a copy was also sent by First Class Mail with postage thereon fully prepaid
To:
Mr. Brad Holloran, Hearing Officer
Illinois Pollution Control Board
State of Illinois Center
100 W. Randolph, Suite 11-500
Chicago, IL 60601
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vlb/Complain.jef/2003/Highlands-MtnExtension