BEFORE THE POLLUTION CONTROL BOARD
OF THE
STATE
OF ILLINOIS
PEOPLE OF THE STATE OF ILLINOIS
ex rel.
LISA MADIGAN, Attorney General
of the State of Illinois
Complainant,
vs.
UNION PACIFIC RAILROAD COMPANY,
a Delaware corporation,
Respondent.
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PCB 2008-007
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VIA ELECTRONIC FILING
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NOTICE OF FILING
John Therriault
Zemeheret Bereket-Ab
Illinois Pollution Control Board
Assistant Attorney General
James
R.
Thompson Center
Environmental Bureau North
100 West Randolph Street
69 West Washington Street, Suite 1800
Suite 11-500
Chicago, Illinois 60602
Chicago, IL 60601
Bradley P. Halloran
W. Lee Hammond
Hearing Officer
Union Pacific Railroad Company
James
R.
Thompson Center
1400 Douglas Street
100 West Randolph Street
Stop 1080
Suite 11-500
Omaha, NE 68179
Chicago, IL 60601
Please take notice that today, August 15, 2007, I have filed with the Office
of the Clerk of
the Illinois Pollution Control Board by electronic filing the Unopposed Motion for Extension of
Time to Respond or Answer on behalf of Union Pacific Railroad Company, along with Notice of
Filing and Certificate of Service, a copy of which is attached hereto and served upon you.
Respectfully submitted,
SONNENSCHEIN NATH
&
ROSENTHAL LLP
By:
/'h.!-~
Attorn~\;ondent
Union Pacific Railroad Company
Thomas
A.
Andreoli
Sonnenschein Nath
&
Rosenthal LLP
233 South Wacker Drive
Chicago, Illinois 60606
312.876.8000
tandreoli@sonnenschein.com
Electronic Filing, Received, Clerk's Office, August 15, 2007
BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
PEOPLE OF THE STATE OF ILLINOIS
ex reI.
LISA MADIGAN, Attorney General
of the State of Illinois
Complainant,
vs.
UNION PACIFIC RAILROAD COMPANY,
a Delaware corporation,
Respondent.
)
)
)
)
PCB 2008-007
)
)
)
VIA
ELECTRONIC FILING
)
)
)
)
)
UNOPPOSED MOTION FOR EXTENSION OF TIME
TO RESPOND OR ANSWER
Union Pacific Railroad Company ("Union Pacific") respectfully moves, pursuant to
35 Ill. Adm. Code § 101.522, that the Illinois Pollution Control Board (the "Board") grant a
60-day extension for Union Pacific to respond or answer the Complaint
of the People ofthe State
of Illinois ("AG"). In support of this motion, Union Pacific states, as follows:
1.
Union Pacific was served on July
19,2007.
2.
The current due date for Union Pacific to respond or answer is August 20,2007 or
September
17,2007, respectively.
3.
Counsel for Union Pacific has discussed an extension
oftime with counsel for the
AG for the purpose
of settlement discussions, and counsel for the AG has no objection to the
requested extension.
Electronic Filing, Received, Clerk's Office, August 15, 2007
WHEREFORE. Union Pacific Railroad Company respectfully requests that the Illinois
Pollution Control Board grant this motion and extend the date in which to respond or answer the
Complaint of the People of the State of Illinois.
Dated: August
15,2007
Respectfully submitted,
SONNENSCHEIN NATH
&
ROSENTHAL LLP
By:
-----fJI41-~===----
Attorney: for e pondent
Union Pacific Railroad Company
Thomas
A.
Andreoli
Sonnenschein Nath
&
Rosenthal LLP
233 South Wacker Drive
Chicago, Illinois 60606
312.876.8000
tandreoli@sonnenschein.com
-2-
Electronic Filing, Received, Clerk's Office, August 15, 2007
CERTIFICATE OF SERVICE
I, Thomas
A.
Andreoli, an attorney, hereby certify that I caused a copy of the Unopposed
Motion for Extension
of Time to Respond
or
Answer of Union Pacific Railroad Company, along
with Notice of Filing and Certificate of Service, to be served upon the service list on August 15,
2007, by electronic mail and regular mail.
ThoIllilS
7:i£~li~~-------
Electronic Filing, Received, Clerk's Office, August 15, 2007
