ESG WATTS,
INC.,
(Taylor Ridge/Andulusia
Landfill)
an
Iowa Corporation,
Petitioner,
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent.
NOTICE OF
FILING
TO:
Michelle
M.
Ryan
Special Assistant Attorney General
Illinois
EPA
1021
North Grand Avenue
East
POBox 19276
Springfield,
IL 62794-9276
Hearing Officer
Pollution Control
Board
100 West Randolph Street
Suite
11-500
Chicago,
IL
60601
PLEASE
TAKE NOTICE
that
I
have today filed with
the Office of the
Clerk of the
Illinois Pollution Control Board the following document,
a true and correct copy ofwhich
is
herewith served
upon you: MOTION
FOR CONTINUANCE
Dated:
March
10, 2004
Respectfully submitted
by,
~,
~fJ
Larr~4\.
oodward, AttorØey for Petitioner
525
1’l’th Street
/
Rock Island,
IL 61201
309-788-7700
BEFORE
THE
ILLINOIS POLLUTION CONTROL
BOARD
RECEIVE~
CLERK’S OFFICE
MAR
1
12004
vs.
STATE OF
ILLINOIS
)
Pollution Control Board
)
)
)
)
PCB
No. 02-55
)
(Permit Appeal-Land)
)
)
)
RECEIVED
CLERK’S OFFICE
BEFORE THE
MAR
112004
ILLINOIS POLLUTION CONTROL
BOARD
STATE OF
ILLINOIS
Pollution Control Board
ESG WATTS, INC.,
)
(Taylor Ridge Landfill)
)
an
Iowa Corporation,
)
Petitioner,
)
)
vs.
)
PCB No. 02-55
)
(Permit Appeal)
ILLINOIS
ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent.
)
MOTION
FOR CONTINUANCE
NOW COMES Petitioner, ESG Watts,
Inc., acting by and through
its attorney Larry
A.
Woodward,
and
pursuant
to
35
III.
Adm.
Code
§101.500(a)
moves
the
Honorable
Hearing
Officer of
the
Pollution
Control
Board
to
grant it
a
continuance
of
the
status
conference set for March
16, 2004 and as grounds therefor Petitioner states:
1.
The Petitioner’s attorney
has been
required to
leave
the
state
in
order to
attend to pressing
business and medical
matters of his elderly parents and will
be away
from
March
11,
2004 to at least March 22, 2004.
2.
There
is
status
conference
set
for
March
16,
2004,
at
10:30
a.m.
and
Petitioner’s attorney cannot
be available
for said telephonic conference
because of the
above personal matter.
3.
That
this
motion
is
not
made
for
the
purpose
of
delay
but
because
of
pressing and
unexpected personal needs of Petitioner’s attorney.
4.
That the
interests of justice and
administrative economy will be served by
granting
Petitioner’s motion for continuance to until at least April
5,2004.
Respecifully submitted by,
ESG
Watts,
Inc.,
Petitioner
By
~
Petitioner
RECEIVED
CLERK’S OFFICE
MAR
112004
CERTIFICATE OF SERVICE
STATE OF ILLINOIS
Pollution Control Board
I hereby certify that
I
did
on the
10th
day of March, 2004,
on
or before
6:00 p.m.
send by First Class Mail, with postage thereon fully prepaid, by depositing
in the
U.S. mails
a
true
and
correct copy
of the
following
instruments
entitled
NOTICE
OF
FILING
and
~AOTION
FOR CONTINUANCE to the following persons addressed as follows:
Division of Legal Counsel
Carol Sudman
Attn:
Michelle M. Ryan
Board Hearing Officer
Special Asst Atty General
Pollution Control Board
Illinois
EPA
State of Illinois Center
1021
North Grand Avenue, E
Suite
11-500
Springfield,
IL 62794-9276
100 West Randolph
Chicago,
IL 60601
and the original of said foregoing instruments by First Class Mail with
postage thereon fully
prepaid to the following
person addressed as follows:
Dorothy Gunn, Clerk
Pollution
Control Board
State of Illinois Center
Suite 11-500
100 West Randolph
Chicago, IL 60601
Lan\J\.
Woodward, ~porne~for Petitioner