1. NOTICE OF FILING
      2. CERTIFICATE OF SERVICE
      3. AGREED MOTION FOR EXTENSION OF TIME
      4. ORDER
RECE~VED
CLERK’S OFFICE
BEFORE TIlE ILLiNOIS POLLUTION CONTROL
BOARD
AUG 24 2004
PEOPLE OF THE STATE OF ILLiNOIS,
Complainant,
)
STATEOFILLINOIS
)
Poflution Control Board
)
PCB No. 04-224
(Enforcement
-
Water)
NOTICE OF FILING
TO:
Ms. Dorothy M. Gunn
Clerk ofthe Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
(VIA FEDERAL EXPRESS)
Carol Sudman, Esq.
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
Post Office Box 19274
Springfield, Illinois 62794-9274
(VIA FIRST
CLASS MAIL)
(SEE PERSONS
ON ATTACHED SERVICE LIST)
PLEASE TAKE NOTICE that I have today filed with the Office ofthe Clerk of
the Illinois Pollution Control Board an original and nine copies each ofan AGREED
MOTION FOR EXTENSION OF
TIME
and proposed
ORDER, copies ofwhich are
hereby served upon you.
Respectfully submitted,
Dated: August 23, 2004
Thomas G. Safley
HODGE DWYERZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois 62705-5776
(217) 523-4900
HERITAGE FS, iNC.,
Respondent,
By:
7~4~
One ~
V.
HERITAGE FS, iNC., an Illinois
incorporated cooperative,
Respondent.
)
)
)
)
)
)
)
THIS
FILING
IS SUBMITTED ON RECYCLED
PAPER
CERTIFICATE OF SERVICE
I, Thomas G. Safley, the undersigned, certify that I have served the attached
AGREED MOTION FOR EXTENSION OF TIME and proposed ORDER upon:
Ms. Dorothy M. Gunn
Clerk ofthe Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, illinois 60601
via Federal Express in Springfield, Illinois on August 23, 2004; and upon:
Jennifer Tomas, Esq.
Assistant Attorney General
Environmental Bureau
188 West Randolph Street
Suite 2001
Chicago, Illinois 60601
Charles Gunnarson, Esq.
Assistant Counsel
Division ofLegal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
Post Office Box 19276
Springfield, Illinois 62794-9276
Carol Sudman, Esq.
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
Post Office Box 19274
Springfield, Illinois 62794-9274
by depositing said documents in the United States Mail, postage prepaid, in Springfield,
Illinois, on August 23, 2004.
41’
~
HEFS:OO1IFiIJNOF
-
COS
- MET
Thoma/S4JIeY
D
RECE~VEDCLERK’S
OFFICE
BEFORE TUE ILLINOIS POLLUTION CONTROL BOAR9~UG242004
PEOPLE OF
THE STATE OF ILLiNOIS, )
STATE OF ILUNOIS
)
Pollution Control Board
Complainant,
S
)
)
v.
)
PCB No. 04-224
)
(Enforcement
-
Water)
HERITAGE PS, iNC., an Illinois
)
incorporated cooperative,
)
)
Respondent.
)
AGREED MOTION FOR EXTENSION OF TIME
NOW COMES Respondent, HERITAGE FS, INC. (“Heritage FS”), and for its
Agreed Motion for Extension ofTime, states as follows:
1.
Heritage F S’s Answer or other response to the Complaint in this matter
currently is due on August 24, 2004.
2,
Complainant and Respondent have reached a settlement ofthis matter in
principle and are fiflalizing settlement documents.
3.
In light ofthis fact, Heritage FS wishes to avoid the expense offiling an
Answer or other response to Complainant’s Com~plaint.
4.
Accordingly, Heritage FS respectfully moves the Illinois Pollution Control
Board (“Board”) for an extension oftime of sixty days, to and including October 23,
2004,.within which to file its Answer, in order to give the Parties time to finalize the
settlement ofthis matter.
5.
Counsel for the State has informed the undersigned that the State has no
opposition to this Motion.
6.
Heritage PS does not file this Motion for purposes ofdelay or for any
other improper purpose, but rather for the reasons stated above.
7.
Heritage FS has filed herewith a proposed Order granting this Motion, for
the Board’s convenience:
WIEREFORE, Respondent, HERITAGE FS, INC., respectfully moves the
Illinois Pollution Control Board to grant it an extension oftime as set forth above, and to
award it all other reliefjust and proper in the premises.
Respectfully submitted,
HERITAGE FS, INC.,
Respondent,
S
By:________
On~fItKA?Q~
Dated: August 23, 2004
Thomas G. Safley
HODGE
DWYER ZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois 62705-5776
(217) 523-4900
BEFS:OO1/Fil,MET
2
REC~JVED
LERK S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARD
AUG
242004
PEOPLE OF
THE
STATE
OF ILLINOIS,
)
PollutionSTATE OFControlILLINOISBoard
Complainant,
)
)
v.
)
PCB
No. 04-224
)
(Enforcement
-
Water)
HERITAGE PS, iNC., an Illinois
)
incorporated cooperative,
.
)
S
)
Respondent.
)
ORDER
The Illinois Pollution Control Board, having considered Respondent’s
AGREED
MOTIONFOR EXTENSION OF TIME, and being fully advised in the premises, hereby
grants said Motion.
IT IS THEREFORE ORDERED AND ADJUDGED that Respondent,
HERITAGE PS, INC., is granted an extension oftime for 60 days, or until October 23,
2004, in which to file its Answer or other response to Complainant’s Complaint.
ENTERED:_______________
_______________________
Dorothy M. Gunn
Clerk ofthe Board

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