REC~JVEL~
CLERK’S
JUN 182003
OFFICE
OFFICE OF THE ATTORNEY GENERAL
STATE OF ILLINOIS
STATE
OF
ILLINOIS
Pollution Control Board
Lisa Madigan
AYFORNEY GENERAL
June 16, 2003
The Honorable Dorothy Gunn
Illinois Pollution Control Board
State of Illinois Center
100 West Randolph
Chicago, Illinois 60601
Re:
People v. Saint-Gobain Containers, Inc., a Delaware corporation
PCB No. 03-22
Dear Clerk Gunn:
Enclosed for filing please find the original and five copies of a NOTICE OF FILING and
MOTION FOR EXTENSION OF TIME TO RESPOND TO RESPONDENT’S DISCOVERY
REQUESTS in regard to the above-captioned matter. Please file the original and return a file-
stamped copy of the document to our office in the enclosed self-addressed, stamped envelope.
Thank you for your cooperation and consideration.
Very truly yours,
Delbert D. Haschemeyer
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
(217) 782-9031
DDH/pp
Enclosures
500 South Second Street, Springfield, Illinois 62706
•
(217) 782-1090
•
TTY: (217) 785-2771
•
Fax: (217) 782-7046
100 West Randolph
Street, Chicago, Illinois 60601 •
(312) 814-3000
•
YT’Y: (312) 814-3374
•
Fax: (312) 814-3806
1001
East Main, Carbondale, Illinois 62901 •
(618) 529-6400
• TfY:
(618) 529-6403
•
Fax: (618) 529-6416
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CLERIcs OFFfr~’F
PEOPLE OF THE STATE OF
)
JUN
1 8
2oo~
ILLINOIS,
)
-
STATE
OFILLINOIS
Pollutj0,-, Co~tro/
Boar
Complainant,
v.
)
PCB NO. 03-22
)
(Enforcement)
SAINT-GOBAIN CONTAINERS,
INC., a Delaware corporation,
- )
)
Respondent.
)
NOTICE OF FILING
To:
N. LaDonna Driver
Hodge Dwyer Zeman
3150 Roland Avenue
P.O. Box 5776
Springfield, IL 62705-5776
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
Control Board of the State of Illinois, a MOTION FOR EXTENSION OF TIME TO RESPOND TO
RESPONDENT’S DISCOVERY REQUESTS, a copy of which is attached hereto and herewith
served upon you.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN
Attorney General of the
State of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/Asbestos
~
DELBERT D. HASCHEMEYER
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: June 16, 2003
1
CERTIFICATE OF SERVICE
I
hereby certify that I did on June 16, 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 NOTICE OF FILING and MOTION FOR EXTENSION OF TIME
TO RESPOND TO RESPONDENT’S DISCOVERY REQUESTS
To:
N. LaDonna Driver
Hodge Dwyer Zeman
3150 Roland Avenue
P.O. Box 5776
-
Springfield, IL 62705-5776
and the original and ten 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
Suite 11-500
100 West Randolph
Chicago, IL 60601
A copy was also sent by First Class Mail with postage thereon fully prepaid
To:
Carol Sudman
Hearing Officer
Illinois Pollution Control Board
600 South Second Street
Springfield, IL 62704
•
_____
Delbert D. Haschemeyer
Assistant Attorney General
This filing is submitted on recycled paper.
BEFORE THE ILLINOIS POLLUTION CONTROL BOARr~ECE~V
PEOPLE OF THE STATE OF
)
CLERK’R o~v~
ILLINOIS,
)
-
JUN
1
8 2003
Complainant,
STATE OP
)
OllUtlOfl Con troi Board
v.
)
PCB NO. 03-22
)
(Enforcement)
SAINT-GOBAIN CONTAINERS,
INC., a Delaware corporation,
Respondent.
MOTION FOR EXTENSION OF TIME TO RESPOND
TO RESPON DENT’S DISCOVERY REQUESTS
NOW COMES the Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General of the State of Illinois, and pursuant to 35 III. Adm. Code Sections
101.502, 101,422 and 101.610(n), requests that the Hearing Officer grant Complainant’s Motion
for Extension of Time to Respond to Respondent’s Discovery Requests. In support of this
Motion, Complainant states as follows:
1.
On or about May 27, 2003, Respondent served its Requests for Production and
First Set of Interrogatories Directed to the Complainant on Complainant.
2.
Pursuant to the Illinois Pollution Control Board’s procedural rules at 35 III. Adm.
Code Part 101, responses to Respondent’s discovery are currently due within 28 days of
service,
i.e.,
June 24, 2003.
3.
Complainant is attempting to respond to the Respondent’s discovery requests.
Nevertheless, Complainant will be unable to complete its responses by June 24, 2003.
Therefore, Respondent requests an extension of time for 30 days, to and including July 24,
2003, in which to file its responses to Respondent’s discovery requests.
4.
This Motion is made in good faith and not for purposes of delay.
1
5.
Counsel for the Complainant has contacted ~counselfor the Respondent, and he
has indicated that he has no objection to this request being granted.
WHEREFORE, for the above and foregoing reasons, Complainant, PEOPLE OF THE
STATE OF ILLINOIS, respectfully requests that the Hearing Officer grant this Motion for
Extension of Time, and allow the Complainant an extension of time for 30 days, or until July 24,
2003, in which to file its responses to Respondent’s Requests for Production and First Set of
Interrogatories Directed to the Complainant.
-
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN,
Attorney General
of the State of Illinois,
MATTHEW J. DUNN, Chief
Environmental Enforcement/Asbestos
Litiga~
ivision
BY:
DELBERT D. HA CHEMEYER
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
.z /
Dated:________
‘1
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 DELBERT D. HASCHEMEYER
1.
I am a
licensed Illinois attorney, and counsel of record for Complainant, State of
Illinois.
2.
I have assisted in the preparation of, and have reviewed, Complainant’s Motion for
Extension of Time to Respond to Respondent’s Discovery Requests (“Motion”).
3.
The statements contained in the Motion, that are not otherwise of record, are true
and accurate to the best of my knowledge and belief.
FURTHER AFFIANT SAYETH NOT.
DELBERT-15. HASbHEMEYER
‘~
SUBSCRIBED AND SWORN to
before e this 16th da of June, 2003.
t’Jbt~ryPublic
4~~/
r6~IALSEAr~I~
P~GGyj.P0lTEvgfq~ ~
~NOTARY PUBLIC, STATE OF ILLINOIS ~
L~2~P~XPI~ES4~162008