BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
GRAND PIER CENTER LLC
)
AMERICAN INTERNATIONAL
)
SPECIALTY LINES INSURANCE CO.
)
as subrogee of
GRAND PIER CENTER LLC
)
)
Complainants,
) PCB 05-157
) (Citizens Enforcement – Land)
v.
)
)
RIVER EAST LLC
)
CHICAGO DOCK AND CANAL TRUST
)
CHICAGO DOCK AND CANAL COMPANY )
KERR-McGEE CHEMICAL LLC
)
)
Respondents.
)
COMPLAINANTS’ MOTION FOR EXTENSION OF TIME TO FILE RESPONSE
TO KERR-McGEE CHEMICAL’S MOTION FOR SUMMARY JUDGMENT
Complainants Grand Pier LLC and American International Specialty Lines
Insurance Co. request the hearing officer, pursuant to section 101.516 of the Board’s
procedural rules, to grant Complainants an extension of time to respond to the pending
motion for summary judgment.
1.
On March 9, 2006, Kerr-McGee filed its Memorandum of Law in Support
of Tronox LLC’s Motion for Summary Judgment. Service was executed by U.S. Mail.
2.
According to the Board’s procedural rules found in section 101.300 and
101.516, Complainants’ response is due March 27, 2006.
3.
Complainants request an additional 30 days to respond to the pending
motion.
4.
An extension of time is necessary to respond adequately to the motion.
Furthermore, the lead attorney for Complainants, Mr. Murray, has just undergone surgery
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 22, 2006
2
and will be unavailable for a number of days. Moreover, Kerr-McGee will not be
prejudiced by this modest extension of time.
WHEREFORE, Complainants Grand Pier LLC and American International
Specialty Lines Insurance Co. pray the hearing officer grant this motion for extension of
time to allow Complainants to file their response to the pending motion for summary
judgment up to and including April 26, 2006.
March 22, 2006
Respectfully submitted
GRAND PIER CENTER LLC and
AMERICAN INTERNATIONAL
SPECIALITY LINES INSURANCE CO.
By:
__s/Garrett L. Boehm, Jr.____________
One of Complainants’ attorneys
Frederick S. Mueller
Daniel C. Murray
Garrett L. Boehm, Jr.
Johnson & Bell, Ltd.
33 W. Monroe St., Suite 2700
Chicago, IL 60603
(312) 372-0770
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 22, 2006
3
Certificate of Service
The undersigned certifies he caused to be served the foregoing
COMPLAINANTS’
MOTION FOR EXTENSION OF TIME TO FILE RESPONSE TO KERR-McGEE
CHEMICAL’S MOTION FOR SUMMARY JUDGMENT
by U.S. Mail on the 22nd
day of March, 2006, to:
John T. Smith II
COVINGTON & BURLING
1201 Pennsylvania Ave. N.W.
Washington, D.C. 20004-2401
Michael Connelly
C
ONNELLY, ROBERTS
& MCGIVNEY LLC
Suite 1200
One North Franklin St.
Chicago, IL 60606
Donald J. Moran
P
EDERSEN & HOUPT
Suite 3100
161 North Clark Street
Chicago, IL 60601
Bradley P. Halloran
Illinois Pollution Control
Board
James R. Thompson Center
100 West Randolph St.
Suite 11-500
Chicago, Illinois 60601
s/Garrett L. Boehm, Jr._______
Garrett L. Boehm, Jr.
JOHNSON & BELL, LTD.
33 West Monroe Street, Suite 2700
Chicago, IL 60603
(312) 372-0770
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 22, 2006
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