BEFORE
THE
ILLINOIS POLLUTION
CONTROL BOAR~EC~VED
LERK S OFFICE
INTHEMATTEROF:
)
FEB042005
PETITION OF JO’LYN CORPORATION
)
STATE OF ILLINOIS
and FALCON WASTE AND RECYCLING,
)
AS 04-02
POgI~t~~~
Control Board
INC. for an ADJUSTED STANDARD from
)
(Adjusted Standard
—
Land)
portions of 35
III.Adm.Code 807.103
and
)
35
III.Adm.Code 810.103, or in
the
)
alternative, A FINDING OF
)
INAPPLICABILITY.
)
NOTICE OF
FILING
To:
(See attached Service
List.)
PLEASE TAKE NOTICE that on this
4th
day of February 2005,
the following was filed
with
the
Illinois
Pollution
Control
Board:
Petitioners’
Motion
for
Extension
of
Time,
attached
and herewith
served
upon you.
JO’LYN CORPORATION
and
FALCON WASTE AND
RECYCLING,
INC.
~
Attorney for Petitio
ers
Elizabeth
S.
Harvey
SWANSON,
MARTIN
& BELL,
LLP
One IBM
Plaza,
Suite 3300
330 North Wabash Avenue
Chicago,
Illinois 60611
Telephone:
(312) 321-9100
Firm
I.D.
No. 29558
CERTIFICATE OF SERVICE
I,
the
undersigned
non-attorney,
state
that
I
served
a
copy of the
above-described
document to
counsel of record in the above-captioned
matter via
U.S.
Mail at One IBM
Plaza,
Chicago, IL
60611
on or
before 5:00 p.m.
on February 4, 2005.
(~~nette
M. Podlin
x
Under penalties
as provided
by law
pursuant to
735 ILCS 5/1 -1 09,
I certify
that the statements set forth
herein
are true and correct.
6332-002
SERVICE LIST
AS 04-02
(Adjusted
Standard
—
Land)
Mr. John J.
Kim
Division of Legal Counsel, IEPA
1021
North Grand Avenue
East
P.O. Box 19276
Springfield,
IL 62794-9276
Bradley
P. Halloran
Hearing Officer
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago,
IL 60601
L
•
BEFORE THE
ILLINOIS POLLUTION
CONTROL
~
CLERK’S OFFICE
IN THE
MATTER OF:
)
FEB
042005
•
PETITION OF JO’LYN CORPORATION
)
STATE OF
ILLINOIS
and
FALCON WASTE AND RECYCLING,
)
AS 04-02
OII~tionControl
Board
INC. for an ADJUSTED STANDARD from
)
(Adjusted Standard
—
Land)
portions of 35
lII.Adm.Code 807.103 and
)
35 III.Adm.Code 810.103, or in
the
)
alternative, A FINDING OF
)
INAPPLICABILITY.
)
MOTION
FOR EXTENSION
OF TIME
Petitioners
Jo’Lyn
Corporation
and
Falcon
Waste
and
Recycling,
Inc.,
by their
attorneys Swanson,
Martin
&
Bell,
hereby
move
the
hearing
officer or the
Board for
a
short extension of time
in which to file petitioners’ reply:
1.
Petitioners filed their
post-hearing brief on
January
14, 2005.
Pursuant to
the
briefing
schedule
set
at
hearing,
the
Illinois
Environmental
Protection
Agency’s
(Agency)
response was due on January 28,
2005.
Petitioners’
reply is due on
February
7, 2005.
2.
The Agency did
not file its
response until February
2, 2005.
3.
Because
the
Agency’s
response
was
filed
late,
petitioners
seek
a
short
extension of
time
to
file
their
reply.
Petitioners
seek
an
extension
to
and
including
February
10, 2005,
in which to file their reply.
WHEREFORE,
petitioners respectfully move the
hearing
officer or the
Board
to
grant this short extension of time.
Michael J.
Maher
Elizabeth
S. Harvey
Swanson,
Martin
& Bell,
LLP
One IBM
Plaza,
Suite 3300
330 North Wabash Avenue
Chicago,
IL 60611
Telephone:
(312) 321-9100
Facsimile:
(312) 321-0990
Respectfully submitted,
JO’LYN CORPORATION and
FALCON WASTE AND RECYCLING,
INC.
By:
