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)
NOTICE OF FILING
TO: All counsel of
record.
PLEASE TAK NOTICE that on the ih day of February 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: February 7,2006
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, FEBRUARY 8, 2006
CERTIFICATE OF SERVICE
I, Matthew E. Cohn, an attorney, certify that on February 7,2006, 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. Gunn, Clerk
Ilinois Pollution Control Board
James R. Thompson Center
1 00 West Randolph Street, Suite 11-500
Chicago,IL 60601
Via U.S. Mail
Lake County Department of Public Works
650 West Winchester Road
Libertyville, 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 03.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 of
the 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
1 00 West Randolph Street
Chicago,IL 60601
Fax: (312) 814-3669
Isl Matthew E. Cohn
Matthew E. Cohn
2
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, FEBRUARY 8, 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 COMPANY'S
REQUEST FOR VARIANCE. 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., Brett D. Heinrich, 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
February 7,2006. Due to the ongoing settlement discussions between Lake
County and Petitioner, and including other interested parties Village of Lake Villa and
the Village of Fox Lake, Petitioner requested from Counsel for Respondents to have an
additional two weeks beyond February 10, 2006, or until February 24, 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 Villa and Vilage of Fox Lake may be filed on or
before February 24,2006.
This document has been printed on recycled paper.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, FEBRUARY 8, 2006
Petitioner therefore requests that the Hearing Offcer Bradley P. Halloran enter an
order extending the time for Petitioner to respond to IEPA'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 Village of
Fox Lake to February 24,2006.
Respectfully submitted,
Isl Matthew E. Cohn
Matthew E. Cohn
Dated: February 7,2006
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(êmbtlaw. com
matthew.cohn(êmbtlaw.com
N:\2333\pleading\Ilinois Pollution Control Board\Third Motion for Extention of
Time to Respond.doc
This document has been printed on recycled paper.
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, FEBRUARY 8, 2006