BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    C&F PACKIG COMPAN, INC., an )
    Ilinois corporation, )
    )
    Petitioner, )
    )
    v. )
    )
    ILLINOIS ENVIRONMENTAL )
    PROTECTION AGENCY and LAK )
    COUNTY, )
    )
    Respondents. )
    PCB 06-053
    (Water -Variance)
    NOTICE OF MOTION
    TO: All counsel of
    record.
    PLEASE TAK NOTICE that on Thursday, December 22, 2005 at 10:00 a.m. CST,
    Counsel for Petitioner C&F Packing Company, Inc. wil appear in a telephonic status hearing,
    Toll Free Dial in Number 1-888-476-3757, Participant Code 460377 before Hearing Offcer,
    Bradley P. Halloran, Ilinois Pollution Control Board and then and there present the attached
    MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTION TO DISMISS OF
    RESPONDENT ILLINOIS ENVIRONMENTAL PROTECTION AGENCY AND TO
    RESPONDENT COUNTY OF LAKE'S COMBINED MOTION TO DISMISS AND
    OBJECTION TO C&F PACKING COMPANY'S REQUEST FOR VARANCE, a copy of
    which is attached hereto.
    Dated: December 16, 2005 Respectfully submitted,
    C&F PACKING COMPANY, INC.
    By: ~~
    One of its Attorneys
    Brett D. Heinrch
    Matthew E. Cohn
    MECKLER BULGER & TILSON LLP
    123 N. Wacker Drive
    Suite 1800
    Chicago, IL 60606
    Tel: (312) 474-7900
    Fax: (312) 474-7898
    Attorneys for Plaintiff
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 16, 2005
    BEFORE THE ILLINOIS POLLUTION CONTROL BOAR
    C&F PACKIG COMPAN, INC., an
    Ilinois corporation,
    Petitioner,
    v.
    ILLINOIS ENVIRONMENTAL
    PROTECTION AGENCY and LAK
    COUNTY,
    Respondents.
    )
    )
    )
    )
    )
    )
    )
    )
    )
    )
    )
    )
    PCB 06-053
    (Water -Variance)
    MOTION FOR EXTENSION OF TIME TO RESPOND
    TO MOTION TO DISMISS OF RESPONDENT ILLINOIS ENVIRONMENTAL
    PROTECTION AGENCY AND TO RESPONDENT COUNTY OF LAKE'S
    COMBINED MOTION TO DISMISS AND OBJECTION TO C&F PACKING
    COMPANY'S REQUEST FOR VARANCE
    Counsel for Petitioner C&F Packing Company, Inc., Brett D. Heinrch and
    Matthew E. Cohn, contacted Counsel for Respondent Lake County, Daniel L. J asica, and
    Counsel for Respondent Ilinois Environmental Protection Agency ("IEP A"), Charles
    Gunnarson, on the afternoon of December 15, 2005. Since the status hearing on
    December 8, 2005, there has been significant progress in settlement discussions of the
    connection fee dispute between Lake County and Petitioner. Those discussions included
    the participation of interested paries Vilage of Lake Villa and the Village of Fox Lake.
    Consequently, Petitioner requested from Counsel for Respondents to have until January
    20, 2006 to respond to both the IEP A's Motion to Dismiss and Lake County's Combined
    Motion to Dismiss and Obj ection. Counsel for Respondents did not oppose this request.
    This document has been printed on recycled paper.
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 16, 2005
    Petitioner therefore requests that the Board enter an order extending the time for
    Petitioner to respond to both the IEPA's Motion to Dismiss and Lake County's
    Combined Motion to Dismiss and Objection to January 20,2006.
    Respectfully submitted,
    ~ GÝ
    Matthew E. Cohn
    Dated: December 16, 2005
    Brett D. Heinrch
    Matthew E. Cohn
    Meckler Bulger & Tilson LLP
    123 North Wacker Drive, Suite 1800
    Chicago, Ilinois 60606
    Phone: (312) 474-7900
    Fax: (312) 474-7898
    brett.heinrchctmbtlaw.com
    matthew.
    cohnctmbtlaw.
    com
    N:\2333\pleading\IlIinois Pollution Control Board\Motion for Extention of
    Time to Respond.doc
    This document has been printed on recycled paper.
    - 2 -
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 16, 2005
    CERTIFICATE OF SERVICE
    I, Matthew E. Cohn, an attorney, certify that on December 16, 2005, I served the
    foregoing MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTION TO
    DISMISS OF RESPONDENT ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
    AND TO RESPONDENT COUNTY OF LAKE'S COMBINED MOTION TO DISMISS
    AND OBJECTION TO C&F PACKING COMPAN'S REQUEST FOR VARIANCE by
    causing true and correct copies of same to be sent via U.S. MaiL.
    Dorothy M. Gunn, Clerk
    Ilinois Pollution Control Board
    James R. Thompson Center
    100 West Randolph Street, Suite 11-500
    Chicago,IL 60601
    Lake County Department of
    Public Works
    650 West Winchester Road
    Libertyville, IL 60048
    Victor Filippini, Esq.
    Holland & Knight LLC
    131 South Dearborn, 30th Floor
    Chicago, IL 60603
    N:\2333\pleading\IIinois Pollution Control Board\Notice or
    Motion Ol.doc
    Charles W. Gunnarson
    Ilinois Environmental Protection Agency
    1021 North Grand Avenue East
    P. O. Box 19276
    Springfield,IL 62794-9276
    Dan Jasica, Assistant State's Attorney
    Civil Division
    Office ofthe State's Attorney of
    Lake County
    18 North County Street, 4th Floor
    Waukegan, IL 60085
    Bradley P. Halloran, Hearing Offcer
    Ilinois Pollution Control Board
    James R. Thompson Center, Suite 11-500
    100 West Randolph Street
    Chicago, IL 60601
    ~~
    Matthew E. Cohn
    2
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 16, 2005

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