1. MOTION FOR EXTENSION OF TIME TO RESPOND
      2. CERTIFICATE OF SERVICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
by LISA MADIGAN, Attorney
General of the State of Illinois,
Complainant,
-vs-
EDWARD PRUIM, an individual, and
ROBERT PRUIM, an individual,
Respondents.)
PCB No. 04-207
____
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___PCB
No. 97-193
(Consolidated)
(Enforcement)
People of the State of Illinois,
by LISA MADIGAN, Attorney
General of the State of Illinois,
Complainant,
-vs-
Community Landfill Company, Inc.
Respondent.
NOTICE OF FILING
PLEASE TAKE NOTICE that we have today, January 30, 2006,
filed with the Office of the Clerk of the Illinois Pollution
Control Board, by electronic filing, Complainant's Motion to
Extend Time, a copy of which is attached herewith and served upon
you.
PEOPLE OF THE STATE OF ILLINOIS
BY:
A/A
sistant Attorney General
Environmental Bureau
188 W. Randolph St.,
2 0
oth
Flr.
Chicago, IL 60601
(312) 814-5388
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 30, 2006
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
by LISA MADIGAN, Attorney
General of the State df Illinois,
Complainant,
-vs-
EDWARD PRUIM, an individual, and
ROBERT PRUIM, an individual,
Respondents.)
PCB No. 04-207
____
___
____
___
___
____
___
___PCB
No. 97-193
(Consolidated)
(Enforcement)
People of the State of Illinois,
by LISA MADIGAN, Attorney
General of the State of Illinois,
Complainant,
-vs-
Community Landfill Company, Inc.
Respondent.
MOTION FOR EXTENSION OF TIME TO RESPOND
Now comes Complainant, PEOPLE OF THE STATE OF ILLINOIS, by
LISA MADIGAN, Attorney General of the State of Illinois, and
requests additional time to file its Response to Respondents',
Edward Pruim and Robert Pruim's, Motions for Summary Judgment.
In support thereof, Complainant states, as follows:
1.
On Friday, January 13, 2006, Respbndents Edward Pruim
and Robert Pruim served Complainant with the two Motions for
Summary Judgment.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 30, 2006
2.
On that same date, the undersigned was assigned to an
emergency referral from Illinois EPA, addressing serious landfill
gas odor problems at the Congress Landfill, Hillside, Cook
County, Illinois.
Landfill gas emissions were affecting the
health and welfare of persons in the vicinity, including two
hotels and a nursing home.
3.
Abating the imminent danger from the landfill gas
emissions required immediate and complete dedication to the new
matter. During the following 14 days, the undersigned appeared
on behalf of the State of Illinois in several different courts,
including the United States Bankruptcy Court for the Northern
District of Illinois.
On January 20, 2006, the undersigned filed
its Complaint on behalf of the State in
People v. Congress
Development Company
et
al., 06 CH- 1438 (Cook County).
On the
afternoon of January 26, 2006, following a vigorously contested
hearing, the Court entered a preliminary injunction requiring the
Congress
Defendants to take immediate and effective action to
address the odor problems.
4.
Due to the unexpected emergency matter, and despite
Complainant's best efforts, it is unable to properly respond to
Respondents' Motions within the 14 days allowed by the Board
procedural rules.
However, Complainant will be able to file its
response no later than Friday, February 3, 2006.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 30, 2006
WHEREFORE, Complainant requests that the Board grant an
extension, and leave to file its Response to Respondent Edward
Pruim's and Robert Pruim's Motions for Summary Judgment by
February 3, 2006.
RESPECTFULLY SUBMITTED,
BY:
Assistant Attorney General
188 West Randolph Street,
2 0
th
Floor
Chicago, IL
60601
(312) 814-5388
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 30, 2006
CERTIFICATE OF SERVICE
I, CHRISTOPHER GRANT, an attorney, do certify that I caused
to be served this 30th day of January, 2006, Complainant's Motion
to Extend Time, and Notice of Filing, upon the persons listed
below by placing same in an envelope bearing sufficient postage
with the United States Postal Seriuice located at 100 W. Randolph,
Chicago.
CHRISTOPHER GRANT
SERVICE LIST:
Mr. Mark Larose
Ms. Clarissa Grayson
Larose & Bosco, Ltd.
200 N. La Salle Street, #2810
Chicago, IL 60601
Mr. Bradley P. Halloran
Hearing Officer
Illinois Pollution Control Board
100 W. Randolph
Chicago, Illinois 60601 [via hand delivery]
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 30, 2006

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