Complainant,
Respondent.
NOV
24
2008
Si
(Utio
OF
Control
ILLINOIS
8
°ard
PCB
2000-2
11
)
(Enforcement)
)
)
)
)
)
)
NOTICE
OF
FILING
TO:
Christopher
Grant
Assistant Attorney
General
Environmental
Bureau
69
West Washington
Street,
18
th
Floor
Chicago,
IL 60602
John
Therriault,
Assistant
Clerk
Illinois
Pollution
Control
Board
100 West Randolph
Street
Suite
11-500
Chicago,
IL
60601
Bradley
P.
Halloran
Hearing
Officer
Illinois
Pollution
Control
Board
James
R.
Thompson
Center,
Suite
11-500
100
W. Randolph
Street
Chicago,
IL
60601
PLEASE TAKE
NOTICE
that
on
Friday,
November
21,
2008,
we
filed
the
attached
Witness
List and
Motion
Requesting
Additional
Time
to
Submit
Exhibit
List
with
the
Hearing
Officer,
a
copy
of
which
is
herewith
served
upon you.
Respectfully
submitted,
TOYAL
AMERICA,
INC.
Roy
M.
Harsch
Lawrence
W.
Falbe
Yesenia
Villasenor-Rodriguez
DRINKER
BIDDLE
&
REATH
LLP
191
N.
Wacker
Drive
Suite
3700
Chicago,
IL 60606-1698
Telephone:
(312) 569-1000
Facsimile:
(312) 569-3000
By:
its
attorneys
-
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOA1iEvEb
OF
THE
STATE
OF
ILLINOIS
)
)
PEOPLE
OF THE STATE
OF
ILLINOIS
V.
TOYAL
AMERICA,
TNC.
,
formerly
known
as
ALCAN-TOYO
AMERICA,
INC.,
a
foreign
corporation,
THIS
FILING
IS
SUBMITTED
ON
RECYCLED
PAPER
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOA1OivE
OF
THE
STATE
OF
ILLINOIS
OFFICE
tny
.
‘2UO
OF
)
°ntrol
Board
)
)
PCB2000-211
•
WITNESS
LIST
Toyal America,
Inc.,
(“Respondent”)
by
and
through
its
attorneys,
Yesenia
Villasenor
Rodriguez
and
Drinker Biddle
&
Reath LLP,
submit
this
witness
list
in
accordance
with
the
Illinois
Pollution
Control Board’s
directive.
1.
Barry
VanHoose,
Toyal
2.
Dennis
Dobrodt,
Toyal
Plant
Manager
3.
Raymond
Malmgren,
Toyal
Health
&
Safety Engineer
4.
Steve
Anderson,
Admiral
Environmental
Services
5.
Christopher
McClure,
Navigant
Consulting
By:
Dated: November
21,
2008
Roy
M.
Harsch
Lawrence
W.
Falbe
Yesenia
Villasenor-Rodriguez
DRINKER
BIDDLE
&
REATH
LLP
191
N.
Wacker
Drive
Suite
3700
Chicago, IL
60606-1698
Telephone:
(312)
569-1000
Facsimile:
(312)
569-3000
THIS
FILING
IS
SUBMITTED
ON
RECYCLED
PAPER
CHOI/
25265416.1
PEOPLE OF
THE
STATE
OF
ILLINOIS
Complainant,
v.
)
)
TOYAL
AMERICA,
INC.,
formerly
known
)
as
ALCAN-TOYO AMERICA,
INC.,
a
)
foreign corporation,
)
)
Respondent.
)
of
its
attorneys
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARWLEb
OF
THE
STATE
OF
ILLINOIS
LV
21
2008
S(F
OF
j
3
Oitut
ControjI8
PEOPLE
OF
THE STATE
OF
ILLINOIS
)
ard
)
Complainant,
)
)
PCB2000-211
v.
)
)
TOYAL
AMERICA,
INC.,
formerly
known
)
as ALCAN-TOYO
AMERICA,
INC.,
a
)
foreign
corporation,
)
)
Respondent.
)
MOTION
REQUESTING
ADDITIONAL
TIME
TO
SUBMIT
EXHIBIT
LIST
Toyal
America,
Inc.,
(“Respondent”)
by
and
through
its
attorneys,
Yesenia
Villasenor
Rodriguez
and
Drinker
Biddle
&
Reath
LLP,
hereby, request
additional
time
for
submittal
of
its
exhibit
list
pursuant
to
the
Illinois
Pollution
Control
Board’s
directive.
In
suppcrt,
Respondent
states
as
follows:
1.
Respondent
will
be
presenting
five
witnesses
at
the
hearing.
2.
Respondent
requires
additional
time
to
collaborate
the
exhibits
as
relate
to
each
of
its
five
witnesses.
3.
Specifically,
Respondent
will
submit
its
exhibit
list
on
or
before,
Tuesday
November
25,
2008.
4.
Respondent
has
confirmed
with
Assistant
Attorney
General,
Christopher
Grant,
that
it
requires
additional
time
for
completing
its
exhibit
list.
5.
Assistant
Attorney
General
Grant
has
no
objections
to
this
request
as
provided
above.
THIS
FILING
IS
SUBMITTED
ON
RECYCLED
PAPER
WHEREFORE,
for all
the
foregoing
reasons,
Respondent respectfully
requests
that
the
hearing
officer approve
its request for
additional
time
to submit its exhibit
list in
this matter.
By:
-
ne
of its
attorneys
Dated:
November
21, 2008
Roy M.
Harsch
Lawrence
W.
Falbe
Yesenia
Villasenor-Rodriguez
DRINKER
BIDDLE
&
REATH
LLP
191
N.
Wacker
Drive Suite 3700
Chicago,
IL
60606-1698
Telephone:
(312)
569-1000
Facsimile:
(312)
569-3000
CERTIFICATE
OF SERVICE
The
undersigned
certifies that a copy
of the foregoing Notice
of Filing
and Witness
List
and
Motion Requesting
Additional
Time
to Submit Exhibit
List were filed by
hand
delivery
with
the
Hearing
Officer and served upon
the parties
to
whom
said Notice is
directed
by first
class mail,
postage
prepaid,
by
depositing
in the U.S. Mail at 191
North Wacker
Drive, Chicago, Illinois
on Friday,
November 21, 2008.
THIS
FILING IS
SUBMITTED ON
RECYCLED
PAPER
CHOI/ 25265563.1