RECE~VED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARD
OCT
‘~
2004
PEOPLE OF THE STATE OF ILLINOIS
V.
Complainant,
THE HIGHLANDS, L.L.C., et a!.,
Respondents.
)
)
)
PCB No. 00-104
)
(Enforcement)
)
)
)
)
)
STATE OF ILLINOIS
Pollution Control Board
NOTICE OF FILING
Dorothy Gunn, Clerk
Illinois Pollution Control Board
State ofIllinois Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
Jane E. McBride
Assistant Attorney General
Environmental Law Bureau
Office ofthe Illinois Attorney General
500 South Second Street 062706
Bradley Halloran
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center, Suite 11-500
100 West Randolph
Chicago, Illinois 60601
Jeffrey W. Tock
Harrington, Tock & Royse
Suite 601, Huntington Towers
201 West Springfield Avenue
P.O. Box 1550
Champaign, Illinois 61824-1550
PLEASE TAKE NOTICE that on October 4, 2004, we filed with the Illinois Pollution
Control Board the attached Respondent Murphy Farms, Inc.’s Motion For Extension Of Time To
Respond To Complaint, a copy ofwhich is hereby served upon you.
Respectfully submitted,
MURPHY FARMS, INC.
Dated: October 4, 2004
Charles M. Gering
McDermott, Will & Emery
227 West Monroe Street
Chicago, Illinois 60606
(312) 372-2000
By:
One of its attorneys /
7
(THIS FILING IS MADE ON RECYCLED PAPER)
C11199 4369423-1.047331.0013
RECE~VED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARDOCT
k~2004
PEOPLE OF THE STATE OF ILLINOIS
)
p~Hution
Control
Board
)
Complainant,
)
PCB No. 00-104
)
(Enforcement)
v.
)
)
THE HIGHLANDS, L.L.C., et a!.,
)
)
Respondents.
)
RESPONDENT MURPHY FARMS, INC.’S
MOTION FOR
EXTENSION OF TIME TO RESPOND TO COMPLAINT
Respondent Murphy Farms, Inc. (“Murphy Farms”), by its attorneys, hereby moves this
Court to extend the time for Murphy Farms to respond to Complainant’s Second Amended
Complaint by one week, through October 18, 2004. In support ofits motion, Respondent states
as follows:
1.
In the Hearing Officer Order dated August 27, 2004, this Court set a deadline of
October 11, 2004, for Murphy Farms to respond to Complainant’s Second Amended Complaint.
2.
Because of deadlines in other matters, Respondent’s counsel anticipates difficulty
in having Murphy Farms’ response to Complainant’s Second Amended Complaint on file by
October 11, 2004. Respondent’s counsel believes that he will be able to have that response on
file by October 18, 2004.
3.
No hearing date has been set in this matter. The parties’ next status hearing with
the hearing officer is scheduled on October 21, 2004, by which date Respondent’s response to
Complainant’s Second Amended Complaint will be on file irrespective ofthe extension oftime
requested herein.
CH199 4369399-1.047331.0013
4.
Respondent’s counsel has discussed this matter with counsel for the Complainant,
and Complainant’s counsel has agreed to the requested extension.
WHEREFORE, Respondent Murphy Farms, Inc. respectfully requests that the Court
grant this Motion and enter an Order granting Respondent a one-week extension of the October
11, 2004 deadline, through October 18, 2004, for its response to Complainant’s Second
Amended Complaint.
Dated: October 4, 2004
.
MURPHY FARMS, INC.
By:
~
One of its attorneys
Charles M. Gering
McDermott, Will & Emery
227 West Monroe Street
Chicago, Illinois 60606
(312) 372-2000
-2
-
C1i199 4369399-1.047331.0013
CERTIFICATE OF SERVICE
I, the undersigned attorney, certify that on October 4, 2004, I served the attached
Respondent Murphy Farms, Inc.’s Motion For Extension Of Time To Respond To Complaint by
U.S. Mail with proper postage prepaid upon:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
State of Illinois Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
Jane E. McBride
Assistant Attorney General
Environmental Law Bureau
Office ofthe Illinois Attorney General
500 South Second Street 062706
Bradley Halloran
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center, Suite 11-500
100 West Randolph
Chicago, Illinois 60601
Jeffrey W. Tock
Harrington, Tock & Royse
Suite 601
Huntington Towers
201 West Springfield Avenue
P.O. Box 1550
Champaign, Illinois 61824-1550
c~ ~
Charles M. Gering
(THIS FILING IS MADE ON RECYCLED PAPER)
CH199 4369423-1.047331.0013
