STATE OF ILLINOIS
POLUTION
CONTROL BOARD
JAMES
R.
THOMPSON CENTER
100 W. RANDOLPH STREET, SUITE 11-500
CHICAGO, IL 60601
PETER ARENDOVICH
)
)
Complainant,
)
)
v.
)
PCB 2009-102
)
ILLINOIS STATE TOLL
)
HIGHWAY AUTHORITY,
)
)
Respondent.
)
NOTICE OF FILING
To:
Mr. Peter Arendovich
1388 Gordon Lane
Lemont, Illinois
60439
Please
take notice that on the 27th day of May, 2009, Respondent, Illinois State
Toll Highway Authority's APPEARANCE and MOTION FOR EXTENSION OF TIME
were filed with the Clerk
of the Pollution control Board, James R. Thompson Center, 100
W. Randolph Street, Suite 11-500, Chicago, IL 60601 via electronic filing.
LISA MADIGAN,
Attorney General
of Illinois
Assistant Attorney General
Illinois Toll Highway Authority
2700 Ogden Avenue
Downers Grove,
IL 60515
(630) 241-6800
(xI530)
Electronic Filing - Received, Clerk's Office, May 27, 2009
STATE
OF ILLINOIS
POLUTION CONTROL BOARD
JAMES
R. THOMPSON CENTER
100 W.
RANDOLPH STREET, SUITE 11-500
CHICAGO, IL 60601
PETER ARENDOVICH
)
)
Complainant,
)
)
v.
)
PCB 2009-102
)
ILLINOIS STATE TOLL
)
HIGHWAY AUTHORITY,
)
)
Defendant.
)
ILLINOIS STATE TOLL HIGHWAY AUTHORITY'S
MOTION FOR EXTENSION OF
TIME
Defendant, Illinois State Toll Highway Authority "Tollway", pursuant to 415 ILCS
5/31(d) and 35 Ill.Admn.Code 103.212, by and through its attorney, LISA MADIGAN, moves
the Pollution Control Board for an extension
of time to research and file a motion pursuant to
415
ILCS 5/31(d) and 35 ILCS 101.202. In support of its motion, the defendant Tollway states
as follows:
1.
I am an Assistant Attorney General and have been assigned to represent the
Tollway in this matter.
2.
The underlying Complaint was received by the Tollway on April 29, 2009.
3.
This is the first Pollution Control Board matter that counsel has been assigned and
previous to this point, has not had occasion to research this area of the law.
4.
That the Tollway is required to submit its motion pursuant to 415 ILCS 5/31 (d)
and 35
ILCS 101.202 on or before June 1,2009.
5.
While it has not completed its research, the Tollway believes it may have a
Electronic Filing - Received, Clerk's Office, May 27, 2009
meritorious defense that would require dismissal of this matter.
6.
That counsel assigned to this case is confident that it will be able to file its motion
pursuant to 415
ILCS 5/31 (d) and 35 ILCS 101.202 within 45 days, or on or before July 15,
2009.
7.
That the Complainant will not be prejudiced if this motion for extension of time is
granted.
8.
That this motion is not intended to unnecessarily delay this matter.
WHEREFORE, the Tollway respectfully moves this
HONORABLE BOARD to grant its
motion and allow it an additional
45 days, or until July 15, 2009, to file its Motion to Dismiss
pursuant to 415
ILCS 5/31(d) and 35 ILCS 101.202.
By:
2
LISA MADIGAN
Attorney General
of lllinois
~TT.LANE
&;~·t
-
Senior Assistant Attorney General
lll. Toll Highway Authority
2700 W. Ogden Avenue
(630) 241-6800 x1530
Electronic Filing - Received, Clerk's Office, May 27, 2009
CERTIFICATE OF SERVICE
The undersigned, being first duly sworn upon oath, deposes and states that a copy
of this notice and Respondent's APPEARANCE and MOTION FOR EXTENSION OF
TIME were served upon the above named at the above address by depositing the same in
the United States mail chute located at 2700 Ogden Avenue, Downers Grove, lllinois
60515 on the 27th day of May, 2009 with proper postage prepaid. I, Robert T. Lane,
hereby certify to the foregoing subject to penalty for perjury
in
accordance with Section
1-109
of the lllinois Civil Practice Act.
Electronic Filing - Received, Clerk's Office, May 27, 2009
STATE OF ILLINOIS
POL UTI ON CONTROL BOARD
JAMES
R.
THOMPSON CENTER
100 W. RANDOLPH STREET, SUITE 11-500
CHICAGO, IL 60601
PETER ARENDOVICH,
Complainant,
v.
ILLINOIS STATE TOLL HIGHWAY
AUTHORITY,
Respondent,
)
)
)
)
)
)
)
)
)
)
PCB 2009-102
APPEARANCE
TO:
Mr. Peter Arendovich
1388 Gordon Lane
Lemont, IL
60439
I, ROBERT T. LANE, Assistant Attorney General, hereby enter my Appearance in the
above matter on behalf
of THE ILLINOIS STATE TOLL HIGHWAY AUTHORITY.
LISA MADIGAN,
Attorney General
of Illinois
R
TT. LANE
Assistant Attorney General
Illinois Toll Highway Authority
2700 Ogden Avenue
Downers Grove, IL
60515
(630) 241-6800
- Ext. 1530
Electronic Filing - Received, Clerk's Office, May 27, 2009
