ILLINOIS POLLUTION CONTROL BOARD
    PEOPLE OF THE STATE OF ILLINOIS,
    Complainant,
    BRIDGEPORT GRAIN, INC.,
    Respondent.
    Ms. Dorothy M. Gunn
    Clerk of the Board
    Illinois Pollution Control Board
    100 West Randolph Street
    N
    NOTICE OF FILING
    TO:
    1 1-500
    Chicago, Illinois 60601
    (VIA ELECTRONIC MAIL)
    PCB 06-8
    (Enforcement - Air)
    Carol Webb, Esq.
    Hearing Officer
    Illinois Pollution Control Board
    1021 North Grand Avenue East
    Post Office Box 19274
    Springfield, Illinois 62794-9274
    (VIA FIRST CLASS MAIL)
    (PERSONS ON ATTACHED SERVICE LIST)
    PLEASE TAKE NOTICE
    that I have today filed with the Office of the Clerk of
    Illinois Pollution Control Board Bridgeport Grain, Inc.'s MOTION FOR EXTENSION
    OF TIME, a copy of which is herewith served upon you.
    Respectfully submitted,
    BRIDGEPORT
    Dated: December 13, 2005
    Katherine
    D. Hodge
    Thomas G. Safley
    HODGE DWYER ZE
    3150 Roland Avenue
    Post Office Box 5776
    Springfield, Illinois 62705-5776
    (217) 523-4900
    )
    )
    )
    )
    )
    )
    GRAIN, INC.,
    By: /s/ Katherine D. Hod
    One of Its Attorneys
    THIS FILING SUBMITTED ON RECYCLED PAPER
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 13, 2005
    CERTIFICATE OF SERVICE
    1, Katherine D. Hodge, the undersigned, certify that I have served the attached
    MOTION FOR EXTENSION OF TIME upon:
    Ms. Dorothy M. Gunn
    Clerk of the Board
    Illinois Pollution Control Board
    100 West Randolph Street
    Suite 11-500
    Chicago, Illinois 60601
    electronic mail on December 13, 2005, and upon:
    Carol Webb, Esq.
    Hearing Officer
    Illinois Pollution Control Board
    1021 North Grand Avenue East
    Post Office Box 19274
    Springfield, Illinois 62794-9274
    id docume
    nois, on December 13, 2005.
    Phillip McQuillan, Esq.
    Senior Assistant Attorney General
    Office of the Attorney General
    500 South Second Street
    Springfield, Illinois 62706
    United States Mail, postage prepai
    /s/ Katherine D. Hodge
    Katherine
    D. Hodge
    Springfield,
    BPG1:001/Fi1/CCJS - MET
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 13, 2005
    ILLINOIS POLLUTION CONTROL BOARD
    PEOPLE OF THE STATE OF ILLINOIS, )
    Complainant,
    )
    v.
    )
    PCB 06-8
    (Enforcement - Air)
    BRIDGEPORT GRAIN, INC.,
    )
    Respondent.
    )
    MOTION FOR EXTENSION OF TIME
    NOW COMES Respondent, BRIDGEPORT GRAIN, INC. ("Bridgeport"), by its
    attorneys, HODGE DWYER ZEMAN, and, pursuant
    to 35111. Admin. Code § 10 1.522,
    moves the Hearing Officer or Illinois Pollution Control Board ("Board") in this matter, to
    enter an Order granting Respondent an extension of time for sixty (60) days, to and
    16, 2006, in which to answer or otherwise respond to Complainant's
    Complaint. In support of this Motion, Respondent states as follows:
    1.
    "The [Illinois Pollution Control] Board or hearing officer, for good cause
    shown on a motion after notice to the opposite party, may extend the time for filing any
    document or doing any act which is required by these rules to be done wit
    a lim
    period, either before or after the expiration of time." 35 111. Admin. Code § 101.522.
    2.
    Compla
    On July 19, 2005, the People of the State of Illinois ("the State") filed a
    above-captioned
    matter, alleging violations of Sections 9(a) of the
    tion (415 ILLS § 5/9(a)); and
    Illinois Environmental Protection Act regarding air
    Sections 212.461(b), 212.462(4)(1), and 201.141 of the Board's regulations (35111. Adm.
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 13, 2005
    Code §§ 212.461(b), 212.462(d)(1), and 201.141); and, Conditions 5(b), 6(a), 6(e), and
    8(a)(i) of Bridgeport's operating permit.
    3 .
    The law firm of HODGE DWYER ZEMAN was retained by Bridgeport to
    represent it in the above-captioned matter, and filed its Entry of Appearance on
    September 29, 2005.
    4 .
    Bridgeport
    never received official notice of the Complainant's Complaint.
    On October 19, 2005, Counsel for Respondent signed a Waiver of Service of
    Complainant's Complaint. At the same time, Counsel for Complainant agreed to a
    deadline of December 18, 2005, i.e. sixty (60) days from the date of the Waiver of
    Service, for Respondent to file its Answer.
    5.
    Bridgeport
    is requesting an extension of time for sixty (60) days, or until
    February 16, 2006, to answer Complainant's Complaint so that the parties may discuss
    possible settlemen
    issues involved in this matter. Counsel for Complainant has no
    objection to this Motion.
    WHEREFORE,
    Respondent, BRIDGEPORT GRAIN,
    tfiilly moves
    the Hearing Officer to enter an Order granting its request for an extension of time
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 13, 2005
    for sixty (60) days, to and including February 16, 2006, in which to file its Answer to
    Complainant's Complaint.
    Respectfully submitted,
    BRIDGEPORT GRAIN, INC.,
    Respondent,
    Dated: December 13, 2005
    By:/s/ Katherine D. Hodge
    One of Its Attorneys
    Katherine D. Hodge
    Gale W. Newton
    HODGE DWYER ZEMAN
    3150 Roland Avenue
    Post Office Box 5776
    Springfield,
    Illinois 62705-5776
    (217) 523-4900
    BPGI:00UFiliMotion for Extension
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 13, 2005

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