BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
RECEVED
N THE
MATTER
OF:
CLERKS
OFFICE
PETITION OF
MAXIMUM
iNVESTMENTS,
LLC
)
AS-09-02
JUN
012009
FOR AN ADJUSTED
STANDARD
FROM
)
35 ILL
TNOIS ADMiNISTRATIVE
CODE
)
STATE
OF
ILLINOIS
740.2 10(A)3 FOR
THE
STONEY CREEK
)
Pollution
Control
Board
LANDFILL
N PALOS
HILLS,
IL
)
MOTION
TO EXPEDITE
NOW COMES
the
Petitioner,
Maximum
Investments,
LLC,
by
and through its attorneys,
WElL & ASSOCIATES,
P.C., pursuant to
35 IL Admin Code
§101.512 (through
11/21/2007), and
states as follows:
Briefs
have been
filed by both Petitioner
and the Illinois EPA
in this matter. Petitioner
is the
holder of
a tax lien on the subject
property
and
is required under Illinois
statutes
to file a
Petition
for
Tax
Deed before the redemption
period
expires on December
21, 2010.
In
order for Petitioner to
be
able to file said
petition timely, the
limit
of liability
under 5/22.2b must
be resolved not less
than 3
months before the redemption
period
expires. Resolving
the limit of liability under
5/22.2b
entails
the IEPA
completing
an updated investigation
of the site
and an inquiry
on its own ruling
on the
5/22.2b
waiver.
Before this investigation
and
inquiry
can
occur, the Board must
make a ruling
on the
present
Petition to
allow sufficient time
for
the IEPA investigation.
WHEREFORE,
Petitioner
respectfully
requests the Board
to expedite
a ruling in this matter.
WElL & ASSOCIATES,
P.C.
An Attorney/6r
}ØioneL.
WElL
&
ASSOCIATES,
P.C.
60
Revere Drive
Suite
888
North brook IL
60062
847-509-0015
(Telephone)
847-509-0021
(Facsimile)
Atty.No.
16362
[LA5/81O9.\Offlonpt.r\,h.rd
do,’Moto
Exp,te.do
Affidavit
of
Richard
Rosenbaum
The
undersigned
does
swear
under
oath
that
the
facts
contained
in
the
Motion
to Expedite
are
true
and
accurate.
‘kichrd
‘kosenaum
WElL
&
ASSOCIATES,
P.C.
60
Revere
Drive
Suite
888
Northbrook
IL
60062
847-509-0015
(Telephone)
847-509-0021
(Facsimile)
Atty.
No.
16362
L4K)5/2d.v9-&ornc.ccmptI&shar.d
docsViotioo
ExV&edc
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
TN THE
MATTER
OF:
PETITION
OF
MAXIMUM
INVESTMENTS,
LLC)
AS-09-02
FOR
AN
ADJUSTED
STANDARD
FROM
)
35
ILL 1NOIS
ADMINISTRATIVE
CODE
)
740.2 10(A)3
FOR
THE STONEY
CREEK
)
LANDFILL
IN
PALOS
HILLS,
IL
)
Certificate
of
Service
I, the
undersigned,
certify
that
I have
served the
attached Mtion
to
Expedite,
by
depositing
in
the
US
Postal
Service first
class
postage
prepaid
on
May24’,
2009,
upon
the
following
persons:
Pollution
Control
Board,
Clerk
Division
of
Legal Counsel
100 W Randolph
Illinois
EPA
Thompson
Center,
Suite
1 1-500
1021
N Grand Ave
East
Chicago,
IL
60601-3218
P0
Box 19276
Springfield,
IL 6
1794-9276
Mr. Brad
Halloran
Pollution
Control
Board
100
W Randolph
Thompson
Center, Suite
11-500
Chicago,
IL
60601-3218
/
/
74
Richard
Rosenbaum
WElL
& ASSOCIATES,
P.C.
60
Revere
Drive
Suite
888
Northbrook
IL 60062
847-509-0015
(Telephone)
847-509-0021
(Facsimile)
AttyNo.
16362