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
    (W ater- Variance)
    NOTICE OF FILING
    TO: All counsel of record.
    PLEASE TAK NOTICE that on the 1ih day of January 2006, we have electronically
    fied with the Ilinois Pollution Control Board, MOTION FOR EXTENSION OF TIME TO
    RESPOND TO MOTION TO DISMISS OF RESPONDENT ILLINOIS
    ENVIRONMENTAL PROTECTION AGENCY, RESPONDENT COUNTY OF LAKE'S
    COMBINED MOTION TO DISMISS AND OBJECTION TO C&F PACKING
    COMPAN'S REQUEST FOR VARANCE, AND RESPONDENT COUNTY OF
    LAKE'S MOTION FOR JOINDER OF VILLAGE OF LAKE VILLA AND VILLAGE OF
    FOX LAKE, a copy of
    which is hereby served upon you.
    Dated: January 12, 2006
    Respectfully submitted,
    C&F PACKING COMPANY, INC.
    By:
    /s/ Matthew E. Cohn
    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, JANUARY 12, 2006
    CERTIFICATE OF SERVICE
    I, Matthew E. Cohn, an attorney, certify that on January 12, 2006, I served the foregoing
    MOTION FOR EXTENSION OF TIME TO RESPOND TO MOTION TO DISMISS OF
    RESPONDENT ILLINOIS ENVIRONMENTAL PROTECTION AGENCY,
    RESPONDENT COUNTY OF LAKE'S COMBINED MOTION TO DISMISS AND
    OBJECTION TO C&F PACKING COMPANY'S REQUEST FOR VARANCE, AND
    RESPONDENT COUNTY OF LAKE'S MOTION FOR JOINDER OF VILLAGE OF
    LAKE VILLA AND VILLAGE OF FOX LAKE by causing true and correct copies of same to
    be sent as stated below:
    Via U.S. Mail
    Dorothy M. Gun, Clerk
    Ilinois Pollution Control Board
    James R. Thompson Center
    100 West Randolph Street, Suite 11-500
    Chicago,IL 60601
    Via U.S. Mail
    Lake County Department of Public Works
    650 West Winchester Road
    Libertyvile, IL 60048
    Via U.S. Mail
    Victor Filippini, Esq.
    Holland & Knight LLC
    131 South Dearborn, 30th Floor
    Chicago, IL 60603
    N:\2333\pleading\Illinois Pollution Control Board\Notice of
    Filing 02.doc
    Via U.S. Mail
    Charles W. Gunnarson
    Ilinois Environmental Protection Agency
    1021 North Grand Avenue East
    P. O. Box 19276
    Springfield, IL 62794-9276
    Via U.S. Mail
    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
    Via Facsimile and U.S. Mail
    Bradley P. Halloran, Hearing Officer
    Ilinois Pollution Control Board
    James R. Thompson Center, Suite 11-500
    100 West Randolph Street
    Chicago,IL 60601
    Fax: (312) 814-3669
    Isl Matthew E. Cohn
    Matthew E. Cohn
    2
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 12, 2006
    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. RESPONDENT COUNTY OF LAKE'S COMBINED
    MOTION TO DISMISS AND OBJECTION TO C&F PACKING COMPAN'S
    REQUEST FOR VARANCE. AND RESPONDENT COUNTY OF LAKE'S
    MOTION FOR JOINDER OF VILLAGE OF LAKE VILLA
    AND VILLAGE OF FOX LAKE
    Counsel for Petitioner C&F Packing Company, Inc., 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 January 11, 2006. Due to the ongoing settlement discussions between Lake
    County and Petitioner, and including other interested parties Vilage of Lake Villa and
    the Vilage of Fox Lake, Petitioner requested from Counsel for Respondents to have an
    additional three weeks beyond January 20, 2006, or until February 10, 2006, to respond
    to both the IEPA's Motion to Dismiss and Lake County's Combined Motion to Dismiss
    and Objection. Counsel for Respondents did not oppose this request. In addition, Lake
    County does not oppose C&F Packing's request that any response to Lake County's
    Motion for Joinder of Village of Lake Vila and Village of Fox Lake may be filed on or
    before February 10, 2006.
    This document has been printed on recycled paper.
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 12, 2006
    Petitioner therefore requests that the Hearing Offcer Bradley P. Halloran enter an
    order extending the time for Petitioner to respond to IEP A's Motion to Dismiss, Lake
    County's Combined Motion to Dismiss and Objection, and Lake County's Motion for
    Joinder of
    Village of
    Lake Villa and Vilage of
    Fox Lake to February 10, 2006.
    Respectfully submitted,
    ~\lL
    Matthew E. Cohn
    Dated: January 12, 2006
    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.heinrch(fmbtlaw.com
    matthew.cohn(fmbtlaw.com
    N:\2333\pleading\Illinois Pollution Control Board\Second Motion for Extention of
    Time to Respond.doc
    This document has been printed on recycled paper.
    - 2 -
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 12, 2006

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