RECEIVED
CLERICS OFFICE
BEFORE THE
20
ILLINOIS
POLLUTION CONTROL BOARD
STATE OF ILLINOIS
PAUL AND DONNA FREDRICKSON,
)
Pollution
Control
Board
husband and wife,
)
Complainants
)
v.
)
PCB 04-19
)
JEFF GRELYAK,
)
Respondent.
)
MOTION FOR CONTD4UANCE
Complainant,
DONNA
FREDRICKSON,
by
and
through her
attorneys,
MILITELLO,
ZANCK
&
COEN,
and in support of her Motion for Continuance,
hereby
states
as follows.
1.
That hearing on
this matter was
set by
the Illinois Pollution Control
Board for November
3, 2005
at 9:00 a.m. in Woodstock, Illinois.
2.
That
Complainant’s
case
is
largely
dependant
upon
the
testimony
of an
expert witness
who will analyze,
interpret, testi~’and be available for cross-examination
by the Respondent.
3.
That
Complainant’s
expert
witness
is
unavailable
to
attend
the
hearing
scheduled
for
November 3, 2005.
4.
That
Complainant’s
case will be unfairly prejudiced without
the testimony of the
expert
witness.
5.
That Respondent
will not be adversely affected by
a change of hearing date.
WHEREFORE,
Complainant respectfully requests that the Illinois Pollution Control Board set
a
new hearing date on this matter.
Dated this
18th day of October, 2005.
Respectfully submitted,
MILITELL
& COEN, P.C.,
Attorneys
lai
B:
Jee
.
haw
Jeremy W.
Shaw
MILITELLO, ZANCK & COEN, P.C.
40
Brink St.
Crystal Lake, IL
60014
(815)459-8800
STATE
OF ILLINOIS
OCT
~~2QQ
POLLUTION CONTROL
BOARD
100W. RANDOLPH STREET,
SUITE
11-500
p~TATE
OFfLLlivogs
CHICAGO, ILLINOIS 60601
“~W~
Control Board
NOTE: All
items must be completed.
If
there is insufficient space to complete any item, additional
sheets maybe attached, speci~’ing
the number of the item you are completing.
Once completed, you
must file the original and nine copies with the Board.
BEFORE THE
ILLINOIS
POLLUTION
)
)
)
)
)
)
)
)
)
)
PROOF OF SERVICE
PAUL
AND DONNA FREDRICKSON,
husband and wife
Complainants
V.
JEFF GRELYAK,
Respondent.
CONTROL
BOARD
PCB 4-19
TO:
Bradley P. Halloran
Hearing Officer
Illinois Pollution Control
Bd.
James R.
Thompson Center
Suite 11-500
100
W. Randolph Street
Chicago, IL
60601
George W. Tinkham
Attorney for Respondent
423
W. Vine Street
Springfield,
IL
62704
Fax:
217-744-1711
Attached
is a Motion for Continuance.
Respectfully
submitted,
Jeremy W.
Shaw
MILITELLO.
ZANCK & COEN, P.C.
40 Brink
Street
Crystal
Lake, IL
60014
(815) 459-8800
MILITELLO, ZANCK & COEN, P.C.
Attorneys for
By:
J
PROOF OF SERVICE
STATE OF
ILLINOIS
)
)SS
COUNTY OF McHENRY
)
The undersigned
states,
under
oath,
that
she
served the
above
Notice,
together
with
the
documents referred to therein, via facsimile transmittal as noted at approximatel~~,~Q5~m.
and by
mailing copies ofthe same to the service list above by depositing the same in the U.S. mail at Crystal
Lake,
Illinois,
with proper postage fully prepaid, at approximately
5:00
p.m.
on
the
19th
day of
October, 2005.
SUBSCRIBED
and SWORN to before
me
this 19th day of October,
2005.
67Notary Public
Sn
—
MY
cau!flens:
11-1146
