BEFORE THE ILLINOIS POLLUTION CONTROL BOARD RECEIVED
PEOPLE OF THE STATE OF
)
JUL
8 2003
ILLINOIS,
)
STATE OF ILLINOIS
Complainant,
)
Pollution Control Board
v.
)
PCB NO. 03-22
(Enforcement)
SAINT-GOBAIN CONTAINERS,
INC., a Delaware corporation,
)
Respondent.
)
NOTICE OF FILING
To:
N.
LaDonna Qriver
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
Litigati
isiori
BY:________________________
DELBERT i3. 1~’ASCHEMEYER
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: July 2, 2003
1
CERTIFICATE OF SERVICE
I hereby certify that I did on July 2, 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 p6stage 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
EertD.HaIhemeyer~~~
Assistant Attorney General
This filing is submitted on recycled paper.
/
1
BEFORE THE ILLINOIS POLLUTION CONTROL BOARDR.ECEIVE
CLERK’S OFF~~
PEOPLE OF THE STATE OF
)
ILLINOIS,
)
JUL.
8 2003
Complainant,
PolJutj~~~
STATE OF
ControlILLINOIS
Board
v.
PCB NO. 03-22
)
(Enforcement)
SAINT-GOBAIN CONTAINERS,
)
INC., a Delaware corporation,
)
)
Respondent.
)
MOTION FOR EXTENSION OF TIME TO RESPOND
TO RESPONDENT’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 Ill. 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.
On June 16, 2003, Complainant submitted a Motion for Extension of Time to
Respond to Respondent’s Discovery Requests requesting an extension to July 24, 2003, in
which to file its Response to Respondent’s Discovery Request.
4.
Complainant is attempting to respond to the Respondent’s discovery requests.
Nevertheless, Complainant will be unable to complete its responses by July 24, 2003.
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Therefore, Respondent requests an extension of time for 15 days, to and including August 8,
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.
5.
Counsel for the Complainant has contacted counsel for 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 15 days, or until August
8, 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
Litigation Division
BY:_____
DELBERT D’HA’SCHEMEYER
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: July 2, 2003
2