BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF TI-IE STATE OF ILLINOIS,
Complainant,
vs.
EDWARD
PRUIM and ROBERT PRUIM,
Respondents.
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
vs.
COMMUNITY LANDFILL COMPANY,
INC.,
Respondent.
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PCB No. 04-207
(Enforcement - Land)
PCB No. 97-193
(Enforcement - Land)
( consolidated)
NOTICE OF FILING
TO:
Christopher Grant
Jennifer Van Wie
Environmental Bureau
Assistant Attorney General
69 W. Washington, 18th Floor
Chicago, Illinois
60602
cgrantialatg.
state.
iI.
us
j
vanwieialatg.state. il. us
Bradley Halloran
Hearing
Officer
Illinois Pollution Control Board
100 West Randolph, Suite 11-500
Chicago, Illinois 60601
hallorabialipcb.state.i
I.
us
PLEASE TAKE NOTICE
that on
MARCH 19,2009,
the undersigned caused to be
electronically filed with Mr. John Therriault, of the Illinois Pollution Control Board, 100 West
Randolph Street, Suite
11-500, Chicago, Illinois 60601, the
RESPONDENTS COMMUNITY
LANDFILL COMPANY, INC., ROBERT PRUIM AND EDWARD PRUIM'S MOTION
FOR
EXTENSION OF TIME TO FILE POST-HEARING BRIEF,
a copy of which is
attached and hereby served upon you.
lsi
Mark A. LaRose
One of the Attorneys for Respondents
THIS FILING IS SUBMITTED ON RECYCLED PAPER.
Mark
A.
LaRose
LaRose
&
Bosco, Ltd.
Attorney No. 37346
200 N. LaSalle Street, Suite 28 I 0
Chicago IL 6060 I
(312) 642-4414
Fax (312) 642-0434
Clarissa Y. Cutler
Attorney at Law
Attorney No. 44745
155 N. Michigan Avenue,
Suite 375
Chicago IL
6060 I
(3 I 2) 729-5067
Fax (312) 729-5056
THIS FILING IS SUBMITTED ON RECYCLED PAPER.
Electronic Filing - Received, Clerk's Office, March 19, 2009
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
Complainant,
vs.
)
)
)
)
)
PCB No. 04-207
(Enforcement - Land)
EDWARD
PRUIM and ROBERT PRUIM,
)
)
Respondents.
)
PEOPLE OF THE STATE OF ILLINOIS,
)
)
Complainant,
)
)
vs.
)
)
COMMUNITY LANDFILL COMPANY,
)
PCB No. 97-193
(Enforcement - Land)
(consolidated)
INC.,
)
)
Respondent.
)
RESPONDENTS COMMUNITY LANDFILL COMPANY, INC.,
EDWARD
PRUIM AND ROBERT PRUIM'S MOTION
FOR EXTENSION OF TIME TO FILE POST-HEARING BRIEF
Respondents, Community Landfill Company, Inc., Edward Pmim and Robert Pmim, by and
through their attorneys LaRose
&
Bosco, Ltd., and pursuant to 35 IIl.Adm. Code 101.502(a) and
101.522 hereby move Hearing Officer Bradley Halloran for an extension
of time to file their Post-
Hearing Brief, and in support thereof, state as follows:
1.
On January 22, 2009, Hearing Officer Bradley Halloran entered an order setting a
briefing schedule wherein Respondents are to file their
Post-Hearing Brief on or before April 6,
2009, and Complainant is to file its Reply, if any, on or before April 20, 2009.
1
Electronic Filing - Received, Clerk's Office, March 19, 2009
2.
Respondents have been and are continuing to work diligently on their Post-Hearing
Brief.
3.
Attorney Clarissa
Y. Cutler is a lead attorney in the case primarily responsible for
preparing the
Post-Hearing Brief.
4.
During the week
of March 16,2009, Attorney Cutler had two deaths in her immediate
family, and has personal business that needs to be attended to
as a result thereof.
5.
On March 19, 2009, counsel for Respondents, Mark
A.
LaRose, contacted counsel for
Complainant, Christopher Grant, to seek his concurrence
in this motion. Attorney Grant agrees with
this motion.
6.
Counsel for tlle parties agree to Complainant being granted a commensurate extension
of time to file its Reply Brief.
7.
Respondents respectfully request an extension, until May 4,2009, to file their Post-
hearing Brief, and for Complainant to file its Reply Brief by May 18,2009.
8.
This motion is made in good faith and not for the purposes of delay.
9.
Granting this extension of time will not result in prejudice to any of the parties
involved in this litigation.
WHEREFORE,
Respondents respectfully request that Hearing
Officer Bradley Halloran
grant Respondents' Motion for an Extension
of Time to File Their Post-Hearing Brief until May
4,2009, and allow a commensurate extension of time for Complainant to file its Reply Brief,
until May 18,
2009.
2
Mark A. LaRose
LaRose
&
Bosco, Ltd.
Attorney
No.3 7346
200 N. LaSalle Street
Suite
2810
Chicago Illinois
60601
(312) 642-4414
Fax (312) 642-0434
Clarissa Y. Cutler
Attorney at Law
Attorney No. 44745
155 N. Michigan Avenue
Suite 375
Chicago, IL
60601
(312) 729-5067
Fax (312) 729-5056
3
Respectfully submitted,
lsi
Mark
A.
LaRose
Attorneys for Respondents
Electronic Filing - Received, Clerk's Office, March 19, 2009
CERTIFICATE OF SERVICE
I, Clarissa
Y.
Cutler, an attorney, hereby certify that I caused to be served a copy of the
foregoing
RESPONDENTS COMMUNITY LANDFILL COMPANY, INC., ROBERT
PRUIM AND EDWARD PRUIM'S MOTION FOR EXTENSION OF TIME TO FILE
POST -HEARING BRIEF,
by electronic filing, emailing, and by placing same in first-class
postage prepaid envelopes and depositing same in the U.S. Mail Box located at 200 North
LaSalle Street, Chicago, Illinois, this
19
th
day of MARCH,
2009,
addressed as follows:
By
U.S. Mail and email
Christopher Grant
Jennifer Van Wie
Environmental Bureau
Assistant Attorney General
69 W. Washington, 18th Floor
Chicago, Illinois 60602
cgrant@atg.state.il.us
ivan
wieialatg.state.i I. us
Mark A. LaRose
LaRose
&
Bosco, Ltd.
Attorney No. 37346
200 N. LaSalle Street
Suite
2810
Chicago Illinois 60601
(312) 642-4414
Fax (312) 642-0434
Clarissa
Y. Cutler
Attorney at Law
Attorney No. 44745
155 N. Michigan Avenue
Suite 375
Chicago, IL 60601
(312) 729-5067
Fax (312) 729-5056
By U.S. Mail and email
Bradley Halloran
Hearing Officer
Illinois Pollution Control Board
100 West Randolph, Suite 11-500
Chicago, Illinois 6060 I
hall ora
biali pc b .state. i I. us
lsi
Mark A. LaRose
One of the Attorneys for Respondents
THIS FILING
IS SUBMITTED ON RECYCLED PAPER.
Electronic Filing - Received, Clerk's Office, March 19, 2009