PEOPLE OF THE
STATE OF
ILLINOIS
Complainant,
TOYAL
AMERICA, INC. , formerly
known
as ALCAN-TOYO
AMERICA,
INC., a
foreign
corporation,
Respondent.
NOTICE OF FILING
TO:
Christopher
Grant
Assistant
Attorney
General
Environmental
Bureau
69
West Washington
Street
18th
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
1 1-500
100
W.
Randolph
Street
Chicago,
IL
60601
Please
take notice that on Friday
April
3,
2009
we filed
the
attached
Motion
Requesting
Extension for Filing
Respondent’s
Post-Hearing Brief
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:
BEFORE THE
ILLINOIS POLLUTION
CONTROL
BOARD
CLERK
ED
V.
APR03
2009
)
OIlUtj
STATE
OP
ILLINOI
Control
BOar
)
PCB2000-211
)
(Enforcement)
)
)
)
)
)
)
THIS
FILING
IS
SUBMITTED
ON RECYCLED
PAPER
CERTIFICATE
OF SERVICE
The
undersigned
certifies
that
a copy of
the foregoing
Motion
Requesting
Extension
for
Filing
Respondent’s
Post-Hearing
Brief
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,
April
3,
2009.
THIS FILING
IS SUBMITTED
ON RECYCLED
PAPER
CHOI/
25322189.1
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
PEOPLE
OF
THE
STATE
OF
ILLINOIS
)
Complainant,
)
APRIJ3
)
PCB
2000-211
T4’rE
OF
ILLINO,
v.
)
(Enforcement)
‘°n
Control
Bo$d
TOYAL
AMERICA,
INC.
, formerly
known
)
as ALCAN-TOYO AMERICA,
INC.,
a
)
foreign
corporation,
)
)
Respondent.
)
TOYAL’S
MOTION
REQUESTING
AN
EXTENSION
FOR
FILING
POST-HEARING
BRIEF
NOW
COMES,
Respondent,
Toyal
America,
Inc., (hereinafter,
“Toyal”),
by
and
through
its
attorneys,
and
respectfully
requests
that the
Hearing
Officer
grant
this
motion
requesting
an
extension
of time
to
submit
its
Post-Hearing
brief
in
this matter.
In
support
thereof
Toyal
states
as
follows:
1.
Pursuant
to Hearing
Officer’s
order
dated
February
18,
2009,
Complainant
submitted
its
Post-Hearing
brief
on February
20, 2009.
2.
Pursuant
to the
above
order,
Respondent’s
Post-Hearing
brief
is
due on
April
6,
2009.
3.
Respondent
requires
additional
time
to submit
its
brief and
respectfully,
requests
an
extension
until
April
10,
2009.
4.
Further,
Respondent
requests
that
if the
Hearing
Officer
grants
this
order,
that
Complainant’s Reply
brief
due
date be
extended
until
April
24, 2009.
THIS
FILING
IS
BEING
SUBMITTED
ON
RECYCLED
PAPER
5.
Toyal has
confirmed
the
above with
Senior Assistant Attorney Christopher Grant,
attorney for Complainant; and he has indicated that he has no objections to this request.
6.
The parties will
be
not prejudiced
by
extending the due date for
an additional four
days as provided above.
WHEREFORE, for all
the
foregoing
reasons,
Respondent, TOYAL,
respectfully
requests
that the Hearing Officer grant its Motion Requesting an Extension
to submit its Post-Hearing
brief until April 10, 2009.
Respectfully submitted,
Toyal
America, Inc.
By:
Dated:
April 3, 2009
Roy M.
Harsch, Esq.
Yesenia Villasenor-Rodriguez, Esq.
Drinker
Biddle
&
Reath LLP
191 North
Wacker
Drive
- Suite 3700
Chicago,
Illinois 60606
(312)
569-1441
(Direct Dial)
(312)
569-3441
(Facsimile)
UiQ
THIS FILING
SUBMITTED
ON
RECYCLED PAPER