THIS FILING SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
MORTON F. DOROTHY,
)
)
C om pl ai n an t,
)
)
v.
)
PCB No. 05-49
)
FLEX-N-GATE CORPORATION,
)
an Illinois corporation,
)
)
Respondent.
)
NOTICE OF FILING
TO:
Ms. Dorothy M. Gunn
Carol Webb, Esq.
Clerk of the Board
Hearing Officer
Illinois Pollution Control Board
Illinois Pollution Control Board
100 West Randolph Street
1021 North Grand Avenue East
Suite 11-500
Post Office Box 19274
Chicago, Illinois 60601
Springfield, Illinois 62794-9274
(VIA ELECTRONIC MAIL)
(VIA ELECTRONIC MAIL)
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of
the Illinois Pollution Control Board Respondent Flex-N-Gate Corporation’s
RESPONSE
TO MOTION FOR TIME TO RESPOND,
a copy of which is herewit h served upon
you.
Respectfully submitted,
FLEX-N-GATE CORPORATION,
Respondent,
Dated: June 7, 2005
By:/s/ Thomas G. Safley
One of Its Attorneys
Thomas G. Safley
HODGE DWYER ZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois 62705-5776
(217) 523-4900
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 7, 2005
CERTIFICATE OF SERVICE
I, Thomas G. Safley, the undersigned, certify that I have served the attached
RESPONSE TO MOTION FOR TIME TO RESPOND upon:
Ms. Dorothy M. Gunn
Clerk of the Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
Carol Webb, Esq.
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
Post Office Box 19274
Springfield, Illinois 62794-9274
via electronic mail on June 7, 2005; and upon:
Mr. Morton F. Dorothy
804 East Main
Urbana, Illinois 61802
by depositing said documents in the United States Mail in Springfield, Illinois, postage
prepaid, on June 7, 2005.
/s/ Thomas G. Safley
Thomas G. Safley
GWST:003/Fil/NOF and COS – Response to Motion for Time To Respond
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 7, 2005
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
MORTON F. DOROTHY,
)
)
C om pl ai n an t,
)
)
v.
)
PCB 05-49
)
FLEX-N-GATE CORPORATION,
)
an Illinois corporation,
)
)
Respondent.
)
RESPONSE TO MOTION FOR TIME TO RESPOND
NOW COMES Respondent, FLEX-N-GATE CORPORATION (“Flex-N-Gate”),
by and through its attorneys, HODGE DWYER ZEMAN, and for its Response to Motion
for Time to Respond, states as follows:
1.
Complainant has moved the Illinois Pollution Control Board (“Board”) to
grant him until June 24, 2005, to respond to Flex-N-Gate’s Motion for Partial Summary
Judgment and Motion for Summary Judgment as to All Counts of Complainant’s
C om pl ai n t.
2.
Flex-N-Gate has no objection to the Board, or the Hearing Officer (see
35
Ill. Admin. Code § 101.522), granting Complainant’s Motion for Time to Respond.
Respectfully submitted,
FLEX-N-GATE CORPORATION
R
e
s
p
o
n
d
e
n
t
,
Dated: June 7, 2005
By:/s/ Thomas G. Safley
One of Its Attorneys
Thomas G. Safley
HODGE DWYER ZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois 62705-5776
(217) 523-4900
GWST:003/Fil/Response to Motion for Time to Respond
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 7, 2005