RECEiVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
curs OFRCE
PEOPLE OF THE STATE OF ILLINOIS,
)
SEP 2 2 2003
Complainant,
STATE OF ILLINOIS
)
Pollution
Control
Board
vs.
)
PCB96-1
43
)
(Enforcement-Water)
MICHEL GRAIN COMPANY, INC., a/k/a
)
MICHEL FERTILIZER, an Illinois
)
corporation, CARYLE MICHEL,
)
RONNIE TODD and RONNIE TODD
)
LAND TRUST,
)
)
Respondents.
NOTICE OF FILING
To:
Doug Antonik
F. William Bonan
Antonik Law Offices
Bonan and Bonan and Rowland
1921 Broadway
P.O. Box 309
P.O. Box 594
McLeansboro, IL 62859
Mt. Vernon, IL 62864
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 AS TO DISCOVERY
SCHEDULE, 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
Litigation iv ion
BY:_________
PHILLI~’McQUILAN
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated:
oy-17—c13
CERTIFICATE OF SERVICE
I hereby certify that I did on September 17, 2003, send by First Class Mail, with postage
thereon fully prepaid, by depositing in a United States Post Office Box true and correct copies of
the following instruments entitled NOTICE OF FILING and MOTION FOR EXTENSION OF TIME
AS TO DISCOVERY SCHEDULE
To:
Doug Antonik
F. William Bonan
Antonik Law Offices
Bonan and Bonan and Rowland
1921 Broadway
P.O. Box309
P.O. Box 594.
McLeansboro, IL 62859
Mt. Vernon, IL 62864
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
James R. Thompson Center
Suite 11-500
100 West Randolph
Chicago, Illinois 60601
A copy was also sent by First Class Mail with postage thereon fully prepaid
To:
Carol Sudman
Hearing Officer
Pollution Control Board
1021 North Grand Avenue East
Springfield, Illinois 62702
Phillip McQ tllan
Assistant Attorney General
This filing is submitted on recycled paper.
ILLINOIS POLLUTION CONTROL BOARD
CLER~çS
OFFICE
PEOPLE OF THE STATE OF ILLINOIS,
)
SEp
2 2
2003
Complainant,
)
TATE OF ILLINOIS
)
utlon
Controj Board
vs,
)
PCB96-143
)
(Enforcement-Water)
MICHEL GRAIN COMPANY, INC., a/k/a
)
MICHEL FERTILIZER, an Illinois
)
corporation, CARLYLE MICHEL,
)
RONNIE TODD, and RONNIE TODD LAND
)
TRUST
)
Respondent.
)
MOTION FOR EXTENSION OF TIME AS TO
DISCOVERY SCHEDULE
Complainant, PEOPLE OF THE STATE OF ILLINOIS, by Lisa Madigan, Attorney
General of the State of Illinois, moves for an extension of time as to the discovery schedule,
and states the following:
1.
The Hearing Officer, Carol Sudman, ordered a discovery schedule on August !8,
2003, which sets the following due dates:
Depositions completed
September 18, 2003
Requests to Admit
October 31, 2003
Responses to Request to Admit
December 1, 2003
Dispositive Motions
To be set
2.
Complainant was represented by Assistant Attorney General Angela Eaton
Hamilton, who transferred from the Environmental Bureau to the Public Aid Bureau in the Office
of Attorney during early September and who is currently on leave of absence.
3.
The undersigned filed Substitution of Counsel on September 2, 2003.
4.
The undersigned obtained the Attorney General file in this case on September 8,
2003.
5.
The file in this case is very large and will take some time to read and assimilate.
6.
On September 15, 2003, the undersigned had a telephone conversation with
Attorney at Law F. William Bonan, who represents respondents Ronnie Todd and Ronnie Todd
Land Trust, wherein the undersigned explained his need for an extension of time as to the
discovery schedule; and, Mr. Bonan stated that he was in agreement with an extension of time.
7.
On September 15, 2003, the undersigned had a telephone conversation with
Attorney at Law Douglas A. Antonik, who represents Carlyle Michel et al., wherein the
undersigned explained his need for an extension of time as to the discovery schedule; and, Mr.
Antonik stated the he was in agreement with an extension of time.
8.
Due to the voluminous fi!e, the amount of review necessary to become prepared,
and the need to depose witnesses, the undersigned requests a ninety (90) day extension on the
due date of all activitieslisted in paragraph one herein.
9.
This motion is not made for the purpose of delay.
10.
The granting of this motion will not prejudice the parties hereto.
11.
The granting of this motion will serve the ends of justice.
Wherefore, complainant requests a ninety (90) day extension on the due date of all
activities listed in paragraph one herein.
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:__________
PHILLIP ~1cQL4LLAN
Assistant Attorney General
Environmental Bureau
Phillip McQuillan #03122873
Assistant Attorney General
500 S. Second St.
Springfield, IL 62706
217.782.9031