BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Commonwealth Edison Company,
)
4
Petitioner
)
PCB
04-215
)
Trade Secret Appeal
v.
)
)
Illinois Environmental Protection Agency,
)
Respondent
)
NOTICE OF FILING
To:
Dorothy
Gunn, Clerk
Byron F. Taylor
Illinois Pollution Control Board
Roshna Balasubramanian
100 West Randolph
Sidley Austin Brown
&
Wood LLP
Suite 1 1
-500
One South Dearborn Street
Chicago,
1llinois 60601
Chicago, Illinois 60603
Brad
Halloran
Hearing Officer
Illinois Pollution Control Board
100 West Randolph
Suite 1 1
-500
Chicago, Illinois 6060 1
Please take notice that today we have filed with the Office of the Clerk of the
Pollution Control Board via electronic filing a Motion for an Extension of Time to
Respond to Petitioner's Motion for an Interlocutory Appeal of Order denying Motions to
Compel. A copy is herewith served upon the assigned Hearing Officer and the attorneys
for the Petitioner, Commonwealth Edison.
Dated: Chicago, Illinois
June 14,2007
LISA
MADIGAN, Attorney General of the
State of Illinois
MATTHEW
DUNN, Chief, Environmental Enforcement1
Asbestos Litigation Division
BY:
P&b
IclL
Paula Becker Wheeler, Assistant Attorney General
69 West Washington Street, Suite 1800
Chicago, Illinois 60602
312
-814-151 1
Electronic Filing, Received, Clerk's Office, June 14, 2007
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Commonwealth Edison Company,
)
Petitioner
) .
PCB 04-215
1
Trade Secret Appeal
v.
)
)
Illinois Environmental Protection Agency,
)
Respondent
1
RESPONDENT'S MOTION FOR AN EXTENSION OF TIME TO RESPOND TO
PETITIONER'S MOTION FOR AN INTERLOCUTORY APPEAL
Now comes Respondent Illinois Environmental Protection Agency (IEPA or the
"Agency")
,
by LISA MADIGAN, Attorney General of the State of Illinois, pursuant to
Section
101.500(d) of the Illinois Pollution Control Board's Procedural Regulations, and
moves for an extension of time to respond to Petitioner's Motion for an Interlocutory
Appeal of Order Denying Motions to Compel Discovery, and in support thereof states as
follows:
1. Assistant Attorney General Ann Alexander is leaving the Attorney General's
Office effective today's date. Assistant Attorney General Paula Wheeler is assisting on
the case.
2. In addition to her own caseload, Ms. Wheeler is also handling, at this time, the
other two related Trade Secret Appeals filed before the Board, PCB 04
-216, PCB 04-1 85.
3.
A Response will be filed on today's date to a similar Motion on the related
case of PCB 04
-2 16.
Electronic Filing, Received, Clerk's Office, June 14, 2007
4. Due to a heavy caseload and Ms. Alexander's departure, Respondent is asking
for an additional fourteen days to respond to this Petitioner's Motion for an Interlocutory
Appeal of Order Denying Motions to Compel.
Conclusion
For the foregoing reasons, Respondent respectfully moves for additional time to
respond to Petitioner's Motion for Interlocutory Appeal of Order denying Motions to
Compel.
Dated: Chicago, Illinois
June 14,2007
2
Respectfully submitted,
LISA
MADIGAN, Attorney General of the
State of Illinois
MATTHEW
DUNN, Chief, Environmental
Enforcement1
Asbestos Litigation Division
BY:
24k&!&b
W
b
Paula Becker Wheeler, Assistant
Attorney General
69 West Washington Street, Suite 1800
Chicago, Illinois 60602
312
-814-151 1
3 12
-8 14-2347 (fax)
Electronic Filing, Received, Clerk's Office, June 14, 2007
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Commonwealth Edison Company,
)
Petitioner
)
PCB 04-215
)
Trade Secret Appeal
v.
)
)
Illinois Environmental Protection Agency,
)
Respondent
)
CERTIFICATE OF SERVICE
I hereby certify that I did on the
14'~
day of June, 2007 send by United States mail
a copy of Respondent's Motion for an Extension of Time to Respond to Petitioner's
Motion for an Interlocutory Appeal, to:
Byron
F. Taylor
Roshna Balasubramanian
Sidley Austin Brown
&
Wood LLP
One South
Dearborn Street
Chicago, Illinois 60603
Dated:' Chicago, Illinois
June 14,2007
LISA
MADIGAN, Attorney General of the
State of Illinois
MATTHEW
DUNN, Chief, Environmental Enforcement1
Asbestos
~ada
~ecker&heeler,
Litigation Division
Assistant
-
Attorney General
69 West Washington Street, Suite 1800
Chicago, Illinois 60602
312
-814-151 1
3 12-8 14-2347 (fax)
Electronic Filing, Received, Clerk's Office, June 14, 2007
