THIS FILING SUBMITTED ON RECYCLED PAPER
     
    ILLINOIS POLLUTION CONTROL BOARD
     
    PEOPLE OF THE STATE OF ILLINOIS, )
     
      
      
      
      
      
    )
    Complainant, )
     
      
      
      
      
      
    )
    v. ) PCB 06-8
    ) (Enforcement – Air)
    BRIDGEPORT GRAIN, INC., )
     
      
      
      
      
      
    )
    Respondent. )
     
    NOTICE OF FILING
     
    TO: Ms. Dorothy M. Gunn Carol Webb, Esq.
    Clerk of the Board Hearing Officer
    Illinois Pollution Control Board
    Illinois Pollution Control Board
    100 West Randolph Street 1021 North Grand Avenue East
    Suite 11-500 Post Office Box 19274
    Chicago, Illinois 60601 Springfield, Illinois 62794-9274
     
    (VIA ELECTRONIC MAIL) (VIA FIRST CLASS MAIL)
     
    (SEE PERSONS ON ATTACHED SERVICE LIST)
     
    PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the
    Illinois Pollution Control Board Respondent Bridgeport Grain, Inc.’s
    AGREED
    MOTION FOR EXTENSION OF TIME,
    a copy of which is herewith served upon you.
     
    Respectfully submitted,
     
    BRIDGEPORT GRAIN, INC.,
    Respondent.
     
     
    By: /s/ Thomas G. Safley
      
    Dated: February 10, 2006 One of Its Attorneys
     
    Katherine D. Hodge
    Thomas G. Safley
    HODGE DWYER ZEMAN
    3150 Roland Avenue
    Post Office Box 5776
    Springfield, Illinois 62705-5776
    (217) 523-4900
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, FEBRUARY 10, 2006
    CERTIFICATE OF SERVICE
     
    I, Thomas G. Safley, the undersigned, certify that I have served the attached
    AGREED 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
     
    via electronic mail on February 10, 2006, and upon:
     
    Carol Webb, Esq. Phillip McQuillan, Esq.
    Hearing Officer Senior Assistant Attorney General
    Illinois Pollution Control Board
    Office of the Attorney General
    1021 North Grand Avenue East 500 South Second Street
    Post Office Box 19274 Springfield, Illinois 62706
    Springfield, Illinois 62794-9274
     
    by depositing said documents in the United States Mail, postage prepaid, in Springfield,
    Illinois, on February 10, 2006.
     
      
    /s/ Thomas G. Safley
      
    Thomas G. Safley
     
    BPGI:001/Fil/COS – MET02
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, FEBRUARY 10, 2006
     
     
    ILLINOIS POLLUTION CONTROL BOARD
     
    PEOPLE OF THE STATE OF ILLINOIS, )
     
      
      
      
      
      
    )
    Complainant, )
     
      
      
      
      
      
    )
    v. ) PCB 06-8
    ) (Enforcement – Air)
    BRIDGEPORT GRAIN, INC., )
     
      
      
      
      
      
    )
    Respondent. )
     
    AGREED MOTION FOR EXTENSION OF TIME
     
    NOW COMES Respondent, BRIDGEPORT GRAIN, INC. (“Bridgeport”), by its
    attorneys, HODGE DWYER ZEMAN, and, pursuant to 35 Ill. Admin. Code § 101.522,
    moves the Hearing Officer or Illinois Pollution Control Board (“Board”) to enter an
    Order granting Respondent an extension of time for forty-five (45) days, to and including
    April 2, 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 within a limited
    period, either before or after the expiration of time.” 35 Ill. Admin. Code § 101.522.
    2. On July 19, 2005, the People of the State of Illinois (“the State”) filed a
    Complaint against Bridgeport in this matter.
    3. The law firm of HODGE DWYER ZEMAN was retained by Bridgeport to
    represent it in this matter, and filed its Entry of Appearance on September 29, 2005.
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, FEBRUARY 10, 2006
     
     
    2
    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 requested an additional 60 days from December 18, 2006, until
    February 16, 2006, and was granted the extension.
    6. Bridgeport is now requesting an extension of time for forty-five (45) days,
    or until April 2, 2006, to answer Complainant’s Complaint so that the parties may
    continue to discuss possible settlement of the issues involved in this matter.
    7. Counsel for Complainant has indicated that Complainant no objection to
    this Motion.
    WHEREFORE, Respondent, BRIDGEPORT GRAIN, INC., respectfully moves
    the Hearing Officer or the Board to enter an Order granting its request for an extension of
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, FEBRUARY 10, 2006
     
     
    3
    time for forty-five (45) days, to and including April 2, 2006, in which to file its Answer
    or other response to Complainant’s Complaint.
    Respectfully submitted,
     
    BRIDGEPORT GRAIN, INC.,
    Respondent,
     
     
    Dated: February 10, 2006 By:/s/ Thomas G. Safley
      
    One of Its Attorneys
    Katherine D. Hodge
    Thomas G. Safley
    HODGE DWYER ZEMAN
    3150 Roland Avenue
    Post Office Box 5776
    Springfield, Illinois 62705-5776
    (217) 523-4900
     
    BPGI:001/Fil/Motion for Extension02
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, FEBRUARY 10, 2006

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