1E?EI~JED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BO~
21 2003
PEOPLE OF THE STATE OF ILLINOIS,
vs.
Complainant,
COMMUNITY LANDFILL
COMPANY,
INC.,
an Illinois corporation,
Respondent.
)
)
)
)
)
PCBNo.97-193
)
(Enforcement)
)
)
)
)
STATE OF ILLINOIS
Pollution Control Board
NOTICE OF FILING
TO:
Ms. DorothyGunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph Street, 11-500
Chicago,IL 60601
Mr. Brad Halloran
Hearing Officer
Illinois Pollution Control Board
100 W. Randolph Street, Suite 11-500
Chicago,IL 60601
Mr. Christopher Grant
Assistant Attorney General
Environmental Bureau
188 W. Randolph, 20th Floor
Chicago,IL 60601
PLEASE TAKE NOTICE that on July 21, 2003, we filed with the Clerk of the Illinois
Pollution Control Board an original and four copies of AGREED MOTION TO EXTEND
DISCOVERY SCHEDULE, a copy ofwhich is attached and herewith served upon you.
Mark A. LaRose
Clarissa C. Grayson
Attorney No. 37346
LaRose & Bosco, Ltd.
734 N. Wells Street
Chicago,IL 60610
(312) 642-4414
Fax (312) 642-0434
Attorney for Respondent
U
THIS FILING IS SUBMITTED ON RECYCLED PAPER
Ju1~,17
03 O3:22p
p.3
RECEIVED
CLERK’S OFFICE
BEI~’ORE~
ILLINOIS POLLJUTION CONTROL
JUL
BOARD
212003
STATE OF ILUNOIS
PEOPLE
OF
THE
STATE
OF ILLINOIS,
)
Pollution Control Board
)
Complainant,
)
)
vs.
)
PCI3 No. 97-1 93
)
(Enforcement)
COMMUNITY LANDFILL COMPANY,
)
INC., an Illinois corporation,
)
)
Respondent.
)
AGREED MOTION TO EXTEND DISCOVERY SCHEDULE
This matter coming before the Illinois Pollution Control Board on the panics Agreed Motion
to Extend Discovery Schedule, Christopher Grant, Assistant Attorney General, on bchalf of the
People ofthe State ofIllinois, Complainant, arid Mark A. LaRoso and ClarissaGrayson, LaRose &
Bosco, Ltd., on behalfofCommunity Landfill Company, Respondent, and in support thereof, state
as
follows:
1.
The parties seek an extension from the Board ofthe discovery cut-off date to
September
15,
2003.
2.
The parties currently are under a discovery cul-olTdate ofAugus’t 1,2003. This date
had been extended previously from June 17, 2003.
3.
A series ofunfortunate events contributed to the necessity ofthe parties requesting
this additional extension, summarized briefly as follows:
a.
LaRosoand J3osco, Ltd. associateattorney Michael J. Vint died suddenly on
May 19, 2003. His untimely death was both a personal tragedy for the entire firm and a
cause ofnumcrous disruptionsto theremaining four attorneys in the firm ashis caseloadwas
reassigned. A largeportion ofhis cases were distributedto respondent’s attorneys Mark A.
Jul l~?03 O3:~3p
p~4
LaRose and Clanissa Grayson.
b.
Mr. Vint had been assisting Mark LaRose with the preparation for trial in a
case in the Western District ofMichiganwhich is scheduledto take place during theCourt’s
August trial term, August 4-29, 2003. Mr. Vint’s death has left Mr. LaRose with the sole
responsibility ofpreparing for the triaL
In late May, 2003, Ms. Grdyson’s brotherbecame seriously ill in Atlanta,
Georgiawhich required herpresence. His illness andsubsequent death in mid-luiie resulted
in her taking numerous unplanned personal days which placed an additional burden on
LaRose & Bosco, Ltd.
4.
The parties do not anticipate requesting any further extensions of the discovery cut-
off date in the above referenced matter. The parties have currently set dates for the exchange of
documents and are in theprocessofre-setting a limited numberofdepositions tentativelyscheduled
to take place starting August 13, 2003 through the end of August, 2003.
Wil ~REFOR.B,based on the foregoing, the parties respcctfully request that the Board grant
the parties’ Agreed Motion to Extend theDiscovery Schedule, and extend thediscovery cut-offdate
to September
15,
2003 in the above referenced matter.
Respectfully Submitted,
PEOP E OF TH STATE
ILLINOIS,
COMMUNITY LANDI~ILLCOMPANY,
stopher r nt
Clarissa Grayson
Assistant Attorney General
2
Jul~17, 03 03:23p
p.5
Christopher Grant
Assistant Attorney General
l~nviroflmefltalBureau
188 W. Randolph, 20th Floor
Chicago, Illinois 60601
(312)814-2381
Mark A. LaR0SC
Clarissa C. Grayson
LaRose & Bosco, Lid.
734 N. Wells Street
Chicago IL 60610
(312)642-4414
3
CERTIFICATE OF SERVICE
The undersigned, an attorney, on oath states that she caused to be served a copy of the
foregoing AGREED MOTION TO EXTEND DISCOVERY SCHEDULE to the following parties
ofrecord, by placing same in U.S. Mail, postage prepaid, this 21st day ofJuly, 2003:
Ms. Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph Street
Chicago,IL 60601
Mr. Christopher Grant
Environmental Bureau
Assistant Attorney General
188 West Randolph Street, 20th Floor
Chicago, IL 60601
Mr. Brad Halloran
Hearing Officer
Illinois Pollution Control Board
James R.Thompson Center
100 W. Randolph Street
Chicago, IL 60601
~c.
Attorney for Respondent
~
Mark A. LaRose
Clarissa C. Grayson
Attorney No. 37346
LaRose & Bosco, Ltd.
734 N. Wells Street
Chicago,IL 60610
(312) 642-4414
Fax (312) 642-0434