1. RECEIVED
RECEIVED
ILLINOIS POLLUTION CONTROL BOARD
CLERK’S OFFICE
SEP 27 2O~
PEOPLE OF THE STATE OF ILLINOIS
)
STATE OF ILLINOIS
/
Pollution Control Board
Complainant,
)
)
VS.
)
No. PCB 05-117
)
CITY OF CAIRO,
)
)
Respondent.
)
NOTICE OF FILING
To:
Thomas Davis
Office ofthe Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
PLEASE TAKE NOTICEthat on this date I mailed for filing with the Clerk of
the Pollution Control Board ofthe State ofillinois, a MOTION FOR EXTENSION OF
TIME TO FILE RESPONSIVE PLEADING, a copy ofwhich is attached hereto and
herewith served upon you.
RespectfUlly submitted,
BY:
MichaelCITY_9~AJJ~JP. O’Shea, Jr.
fL
Attorney for respondent
City of Cairo
BUSINESS ADDRESS:
Michael P. O’Shea, Jr.
216-10th St., P.O. Box 791
Cairo, Illinois 62914
Tel: (618) 734-1199
Fax: (618) 734-1245
ARDCNo: 2122197
CERTIFICATE OF SERVICE
It is hereby certified that the original ofthe foregoing notice of filing was mailed,
first class, for filing, on September 20, 2005, to the following address:
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100W. Randolph St., Ste.
11-500
Chicago, Illinois 60601
and a copy ofthe foregoing motion was mailed, first class, on September 20, 2005, to the
following person:
Thomas Davis
Office ofthe Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
ILLINOIS POLLUTION CONTROL BOARD
R
CLERK’S
E
CE
OFFICE
IV ED
PEOPLE OF THE STATE OF ILLINOIS,
)
SEP27 2005
STATE OF ILLINOIS
Complainant,
)
Pollution
Control Board
)
vs.
)
No. PCB 05-117
)
CITY OF CAIRO,
)
)
Respondent.
)
MOTION FOR EXTENSION OF TIME TO FILE
RESPONSIVE PLEADING
Now comes respondent, City ofCairo by its attorney, Michael P. O’Shea, Jr., and
fortheir motion for extension oftime to file responsive pleading, says as follows:
1.
That on or about August 30, 2005, respondent was ordered to file an
answer to the amended complaint filed by plaintiff, in the captioned cause.
2.
That attorney for this respondent has been unable to discuss this pending
litigation with the members ofthe council ofthe City ofCairo for the reason that, at the
most recent regularly scheduled meeting ofthis council on September 13, 2005, the
members ofthe council abruptly left the meeting before the meeting was adjourned and
as a result oftheir departure, their attorney did not have an opportunity to present this
matter to them.
3.
That there is another regularly scheduled meeting on September 27, 2005,
at which time, attorney for respondent intends to bring this mailer to their attention;
furthermore, that there is a special called meeting scheduled for September 22, 2005, but
this matter is not on the agenda and therefore may not be discussed.
4.
That this respondent hereby requests that it be given until October 11,
2005, to file its responsive pleading to the amended complaint filed herein.
WHEREFORE, respondent, City of Cairo, prays as follows
A.
That this respondent be granted until October 11, 2005, to file its
responsive pleading to the amended complaint filed herein by plaintiff;
B.
For such other relief as may be just and equitable.
CITY OF CAIRO
BY:
_______________
Its Attorney
BUSINESS ADDRESS:
Michael P. O’Shea, Jr.
216-10th St., P.O. Box 791
Cairo, illinois 62914
Tel: (618) 734-1199
Fax: (618) 734-1245
ARDCNo: 2122197
CERTIFICATE OF SERVICE
It is hereby certified that the original ofthe foregoing motion was mailed, first
class, for filing, on September 20, 2005, to the following address:
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph St., Ste. 11-500
Chicago, Illinois 60601
and a copy ofthe foregoing motion was mailed, first class, on September 20, 2005, to the
following person:
Thomas Davis
Office ofthe Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
~?t’h~oJz!Dft-~
RECEIVED
CLERK’S OFFICE
ILLINOIS POLLUTION CONTROL BOARD
SEP 272005
PEOPLE OF THE STATE OF ILLINOIS,
)
STATE OF ILLINOIS
)
Pollution Control Board
Complainant,
)
)
vs.
)
No. PCB 05-117
)
CITY OF CAIRO,
)
)
Respondent.
)
NOTICE OF FILING
To:
Thomas Davis
Office of the Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of
the Pollution Control Board of the State ofIllinois, an ENTRY OF APPEARANCE,
a copy of which is attached hereto and herewith served upon you.
Respectfully submitted,
BY:
MichaelCITY P. O’Shea,AIR
Jr.
IL
Attorney for respondent,
City of Cairo
BUSINESS ADDRESS:
Michael P. O’Shea, Jr.
216-10th St., P.O. Box 791
Cairo, Illinois 62914
Tel: (618)734-1199
Fax: (618) 734-1245
ARDCNo: 2122197
CERTIFICATE OF SERVICE
It is hereby certified that the original ofthe foregoing notice of filing was mailed,
first class, for filing, on September 20, 2005, to the following address:
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100W. Randolph St., Ste. 11-500
Chicago, Illinois 60601
and a copy ofthe foregoing motion was mailed, first class, on September 20, 2005, to the
following person:
Thomas Davis
Office ofthe Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
ILLINOIS POLLUTION CONTROL BOARD
SEP 27 2005
PEOPLE OF THE STATE OF ILLINOIS,
STATE OF ILLINOIS
pollution control Board
Complainant,
)
)
vs.
)
No. PCB 05-117
)
CITY OF CAIRO,
)
)
Respondent.
)
ENTRY OF APPEARANCE
The undersigned hereby enters his appearance as attorney for the above named
respondent, City ofCairo.
luJ~IL.
BUSINESS ADDRESS:
Michael P. O’Shea, Jr.
216-10th St., P.O. Box 791
Cairo, illinois 62914
Tel: (618)734-1199
Fax: (618) 734-1245
ARDCNo: 2122197
CERTIFICATE OF SERVICE
It is hereby certified that the original ofthe foregoing was mailed, first class, for
filing, on September 20, 2005, to the following address:
DorothyM. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100W. Randolph St., Ste. 11-500
Chicago, Illinois 60601
and a copy ofthe foregoing was mailed, first class, on September 20, 2005, to the
following person:
Thomas Davis
Office ofthe Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
1wdJft~—
ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
)
Complainant,
)
)
vs.
)
No. PCB 05-117
)
CITY OF CAIRO,
)
)
Respondent.
)
ENTRY OF APPEARANCE
The undersigned hereby enters his appearance as attorney for the above named
respondent, City ofCairo.
BUSINESS ADDRESS:
Michael P. O’Shea, Jr.
216-10th St., P.O. Box 791
Cairo, illinois 62914
Tel: (618) 734-1199
Fax: (618) 734-1245
ARDCNo: 2122197
CERTIFICATE OF SERVICE
It is hereby certified that the original ofthe foregoing was mailed, first class, for
filing, on September 20, 2005, to the following address:
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph St., Ste. 11-500
Chicago, Illinois 60601
and a copy of the foregoing was mailed, first class, on September 20, 2005, to the
following person:
Thomas Davis
Office ofthe Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706

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