RECEI~VE~
    CLERK’S
    Q~FTCi~
    NOV
    6
    2003
    STAlE OF ILUNOIS
    )
    Pollution
    Control Bocird
    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    The CITY OF CHICAGO,
    a Delaware corporation,
    FEDERAL CHICAGO CORP.,
    an Illinois corporation, and
    FEDERAL DIE CASTiNG CO.,
    an Illinois corporation,
    RAYMOND E. CROSS, an individual,
    Respondents.
    )
    )
    )
    )
    )
    PCB 04-29
    )
    )
    (Enforcement—Land,
    Citizens)
    )
    )
    )
    )
    )
    )
    )
    )
    To:
    See attached service list
    NOTICE OF FILING
    PLEASE TAKE NOTICE that I shall today file with the Office of the Clerk ofthe
    Pollution Control Board the City ofChicago’s “Unopposed Motion to Hearing Officer to Extend
    Time For Respondents to
    Answer,” a copy ofwhich is herewith served upon you.
    Dated: November 6, 2003
    Diane M. Pezanoski
    Deputy Corporation Counsel
    RosemaryKrimbel
    Charles A. King
    Assistant Corporation Counsel
    Chicago Department ofLaw
    30 N. LaSalle St., Suite 900
    Chicago, IL 60602
    (312) 742-0330
    THE CITY OF CHICAGO
    Mara S. Georges
    Corporation
    By:
    CERTIFICATE OF SERVICE
    I, Charles A.
    King,
    an attorney, certify that
    I caused copies of this notice and the
    document referenced herein to be served on the parties to whom it is di~e~ed
    by U.S.
    Mail, first
    class postage prepaid, on November 6, 2003.
    an Illinois municipal corporation,
    Complainant,
    V.
    PUREX INDUSTRIES, INC.,
    Assistant Corporation Counsel
    SERVICE LIST
    Jeffrey M. Smith
    19782
    MacArthur Blvd., Suite 260
    Irvine, CA 92612
    Authorized agent ofPurex Industries, Inc.
    Robert L.
    Graham
    Bill S. Forcade
    Steven M.
    Siros
    Jason E. Yearout
    Jeimer & Block
    One IBMPlaza
    Chicago, IL 60611
    Counsel ofrecordfor Purex Industries,
    Inc.,
    in PCB 03-55
    Cary R. Penman
    Shorge K. Sato
    Latham &
    Watkins
    5800 Sears Tower
    233
    South Wacker Drive
    Chicago, Illinois 60606
    Attorneys and agentsfor all other
    respondents
    Francis A. Citera
    Daniel T. Fahner
    Greenberg Traurig, P.C.
    77 W.
    Wacker Dr., Suite 2500
    Chicago, IL
    60601
    Craig V. Richardson
    Christopher J. Neumann
    Greenberg Traurig, L.L.P.
    1200 Seventeenth
    St., 24th Floor
    Denver, CO 80202
    Counsel ofrecordfor 2222 Elston LLC
    in PCB
    03-55
    RECEIVED
    CL.I!RK’S OF1-~~CE
    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    NOV
    62003
    The CITY OF CHICAGO,
    .
    )
    STATE OF ILUNOIS
    an Illinois municipal corporation,
    Pollution
    Control Bocrd
    Complainant,
    )
    )
    v.
    )
    PCB 04-29
    )
    PTJREX INDUSTRIES, INC.,
    )
    (Enforcement—Land,
    Citizens)
    a Delaware corporation,
    )
    FEDERAL CHICAGO CORP.,
    )
    an Illinois corporation, and
    )
    FEDERAL DIE CASTING CO.,
    )
    an Illinois corporation,
    )
    RAYMOND E. CROSS,
    an individual,
    )
    )
    Respondents.
    )
    UNOPPOSED MOTION TO HEARING OFFICER
    TO EXTEND TIME FOR RESPONDENTS TO ANSWER
    Petitioner, the City ofChicago (“City”), by its attorney, Mara
    S.
    Georges, Corporation
    Counsel, by this motion requests that the hearing officer extend the time for the respondents in
    this action to answerthe City’s
    complaint, pursuant to
    35
    Ill. Adm.
    Code 101.522.
    In support of
    its motion the City states:
    1.
    The respondents in this case were served with the complaint on September
    8,
    2003.
    Accordingly, under 35
    Ill.
    Adm.
    Code
    103.204(d), the time within which they may file
    answers to the complaint ends on November 7, 2003.
    2.
    The parties to this
    case and 2222
    Elston LLC
    v. Purex Industries, Inc., et al., PCB
    03-55,
    are in negotiation toward
    a global settlement of both cases,
    and hope to reach an
    agreement in the near future.
    3.
    If the cases
    are settled, any response to the City’s complaint by the respondents
    will be moot.
    It would thus be
    a needless expenditure ofresources by the respondents to prepare
    responses to the City’s complaint.
    The City believes that at present the respondents’
    resources
    are better directed towards concluding a settlement.
    4.
    To
    foster settlement ofthese cases, the City requests that the hearing officer enter
    an order pursuant to 35
    Ill. Adm. Code 101.522 extending the time within which the respondents
    may respond to the City’s complaint to
    and including December
    5,
    2003.
    5.
    No otherparty to this case opposes the requested relief.
    WHEREFORE,
    the City requests that the hearing officer enter an order extending the
    time within which
    the respondents may respond
    to the City’s complaint to and including
    December
    5,
    2003.
    Respectfully submitted,
    THE
    CITY OF CHICAGO
    Mara S. Georges
    Corporation Couns~ei~
    By:
    /
    ~
    Corporation Counsel
    Diane M. Pezanoski
    Deputy Corporation Counsel
    Rosemary Knimbel
    Charles A. King
    Assistants Corporation Counsel
    Chicago Department of Law
    30 N. LaSalle St.,
    Suite 900
    Chicago, IL 60602
    (312) 742-0330

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