BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
by LISA MADIGAN, Attorney General
of the State of Illinois,
PCB 96-98
(Enforcement - Water)
Complainant,
Respondents.
v.
)
)
)
)
)
)
)
)
SKOKIE VALLEY ASPHALT CO., INC.,
)
an Illinois Corporation, EDWIN
L. FREDERICK, )
JR., Individually and as Owner and President
of
)
Skokie Valley Asphalt Co., Inc., and
)
RICHARD
J. FREDERICK, Individually
)
and as Owner and Vice President
of Skokie
)
Valley Asphalt Co., Inc.,
)
)
)
NOTICE OF FILING
TO:
Mr. David S. O'Neill, Esq.
Mr. Michael
B.
Jawgiel, Esq.
5487 North Milwaukee Avenue
Chicago, Illinois 60630-1249
Ms. Carol Webb, Hearing Officer
Pollution Control Board
1021 North Grand Avenue East
P.O. Box 19274
Springfield, Illinois 62794-9274
PLEASE TAKE NOTICE that today I caused to be filed electronically
Complainant's
Motion for an Extension of Time
with the Office of the Clerk of the Illinois Pollution Control
Board, a true and correct copy
of which is attached hereto and herewith served upon you.
PEOPLE OF
THE STATE OF ILLINOIS,
LISA MADIGAN, Attorney General
of the State of Illinois
BY:
PAULA BECKER WHEELER
Assistant Attorney General
Environmental Bureau
69 West Washington, Suite 1800
Chicago, Illinois 60602
Tel: 312.814.1511
Dated: December 18, 2007
Electronic Filing - Received, Clerk's Office, December 18, 2007
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
by LISA MADIGAN, Attorney General
of the State of Illinois,
PCB 96-98
(Enforcement - Water)
Respondents.
Complainant,
v.
)
)
)
)
)
)
)
)
SKOKIE VALLEY ASPHALT CO., INC.,
)
an Illinois Corporation, EDWIN
L. FREDERICK, )
JR., Individually and as Owner and President
of
)
Skokie Valley Asphalt Co., Inc., and
)
RICHARD 1. FREDERICK, Individually
)
and as Owner and Vice President
of Skokie
)
Valley Asphalt Co., Inc., ,
)
)
)
COMPLAINANT'SMOTION FOR AN EXTENSION OF TIME
Complainant, PEOPLE OF THE STATE OF ILLINOIS ("People"), by LISA
MADIGAN, Attorney General
of the State of Illinois, hereby moves the Board, pursuant to 35
Ill. Adm. Code 101.500(d), for an Extension
of Time of fourteen days until December 31, 2007,
to file its Response to the Respondents' Motion for Reconsideration and Motion to Stay Date
of
Final Order. In support of this Motion, the People state and allege as follows:
1.
On November 1,2007, the Illinois Pollution Control Board ("Board") issued its
Opinion and Final Order in the case above.
2.
On December
5, 2007, the Respondents filed their Motion for Reconsideration of
the Board's Final Order, which was served on the Complainant on December 6,2007. The
Respondents Motion is forty pages long, and concentrates heavily on the issues presented at the
first hearing by the Board held on October 30 and 31, 2003.
Electronic Filing - Received, Clerk's Office, December 18, 2007
3.
Complainant'sattorney is newly assigned to the case and did not participate in the
Board Hearing in 2003 or the attorneys' fees hearing that was held on December 12,2006. To
respond to the Respondents' Motion appropriately entails investigation into matters long past and
discussions with attorneys
no longer working at the Attorney General's Office. Some necessary
people have been unavailable because
of the holidays or other reasons.
4.
Complainant'sattorney, Paula Wheeler, has been ill and absent from work two of
the last nine working days.
5.
Respondents will not be prejudiced by the granting of additional time to respond.
Wherefore, pursuant to the above reasons, Complainant respectfully requests that the
Board grant its Motion for an extension
of time to respond to Respondents Motion for
Reconsideration and Motion to Stay Date of Final Order.
LISA MADIGAN, Attorney General
of the State of Illinois
BY:
PAULA
~
BECKER
a
IJ.L
WHEELER
~.
-'
Assistant Attorney General
Environmental Bureau
69 West Washington, Suite 1800
Chicago, Illinois 60602
Tel: 312.814.1511
Fax: 312.814.2347
2
Electronic Filing - Received, Clerk's Office, December 18, 2007
CERTIFICATE OF SERVICE
It
is hereby certified that on December 18,2007, true and correct copies of the
Notice of
Filing
and
Complainant's Motion for an Extension of Time,
were sent by overnight UPS
Mail, postage prepaid, to the persons listed on the Notice
of Filing.
PA
-LA
BECKER WHEELER
Assistant Attorney General
BY:
It
is hereby certified that the foregoing were electronically filed with the Clerk of the
Board on December 18, 2007:
Pollution Control Board, Attn: Clerk
James
R.
Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
BY
P~e'
~
AULABE KER
0~
WHEELER
Assistant Attorney General
Electronic Filing - Received, Clerk's Office, December 18, 2007
