BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    PEOPLE
    OF THE STATE OF ILLINOIS,
    Petitioner,
    v.
    CROP PRODUCTION SERVICES,
    a Delaware corporation,
    Respondent.
    PCB 09-60
    (Enforcement)
    NOTICE OF FILING
    TO: Mr. John T. Therriault
    Assistant Clerk
    Illinois Pollution Control Board
    100 West Randolph Street
    Suite
    11-500
    Chicago, Illinois 60601
    (VIA ELECTRONIC MAIL)
    Carol Webb, Esq.
    Hearing
    Officer
    Illinois Pollution Control Board
    1021 North Grand Avenue East
    Post Office Box 19276
    Springfield,
    Illinois
    62794-9274
    (VIA FIRST CLASS MAIL)
    (PERSONS ON ATTACHED
    SERVICE LIST)
    PLEASE TAKE NOTICE that I have today filed
    with the Office of the Clerk of
    the Illinois Pollution Control Board a MOTION FOR EXTENSION
    OF TIME on
    behalf of CROP PRODUCTION SERVICES, a copy of which is herewith served upon
    you.
    Respectfully submitted,
    Dated: August 4, 2009
    Edward
    W.
    Dwyer
    Monica T. Rios
    HODGE DWYER & DRIVER
    3150 Roland Avenue
    Post
    Office
    Box
    5776
    Springfield, Illinois 62705-5776
    (217) 523-4900
    CROP PRODUCTION SERVICES,
    Respondent,
    By: /s/ Edward W. Dwyer
    One of Its Attorneys
    THIS FILING SUBMITTED ON RECYCLED PAPER
    Electronic Filing - Received, Clerk's Office, August 4, 2009
    CERTIFICATE
    OF SERVICE
    I, Edward W. Dwyer, the undersigned,
    hereby certify that I have served the
    attached MOTION FOR EXTENSION OF TIME, upon:
    Mr. John T. Therriault
    Assistant Clerk
    Illinois Pollution Control Board
    100
    West
    Randolph
    Street
    Suite 11-500
    Chicago, Illinois 60601
    via electronic mail on August 4, 2009; and upon:
    C arol Webb, Esq.
    Hearing Officer
    Illinois Pollution Control Board
    1021
    North Grand Avenue East
    Post Office Box 19274
    Springfield, Illinois 62794-9274
    Jane
    E.
    McBride, Esq.
    Office of the Attorney
    General
    Environmental Bureau
    500 South Second Street
    Springfield,
    Illinois
    62706
    by depositing said documents in the
    United States
    Mail, in
    Springfield, Illinois on August
    4, 2009.
    /s/ Edward
    W.
    Dwyer
    Edward W. Dwyer
    U APR:002/Fil/NOF-COS
    - MET2
    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    PEOPLE OF THE STATE OF ILLINOIS, )
    Petitioner,
    )
    v.
    )
    PCB 09-60
    (Enforcement)
    CROP PRODUCTION SERVICES,
    )
    a Delaware corporation,
    )
    Respondent.
    )
    MOTION FOR EXTENSION OF TIME
    NOW COMES Respondent, CROP PRODUCTION SERVICES ("CPS"), and
    pursuant
    to 35
    Ill.
    Adm. Code Section 101.522, hereby files its Motion for Extension of
    Time seeking an extension of the date by which its answer or responsive pleading is to be
    filed
    in this matter, stating as follows:
    1.
    On April 6, 2009, People of the State of Illinois (hereinafter
    "Complainant") filed its First Amended Complaint ("Amended Complaint").
    2.
    CPS' Answer or other responsive pleading
    was due by June 8, 2009.
    3.
    On June 8, 2009, CPS filed a Motion for Extension of Time requesting
    until August 7, 2009 to file an Answer
    or otherwise respond. The Hearing Officer
    granted that Motion, allowing CPS until August 7, 2009 to file an Answer or otherwise
    respond.
    4.
    Complainant and Respondent are currently discussing settlement in this
    matter.
    5.
    In light of this fact, CPS wishes to avoid the unnecessary expense of filing
    an Answer or other response to the Amended
    Complaint and focus its resources on
    settlement discussions.
    6.
    The undersigned has conferred with
    counsel
    for
    the Complainant and the
    Complainant supports the Motion.
    7.
    CPS respectfully moves the Illinois Pollution Control Board ("Board") for
    an extension of time of sixty (60) days, to and including October 6, 2009, within which to
    file its Answer,
    in order to give the Parties time to continue settlement discussions in this
    matter.
    8.
    CPS does not file this Motion for purposes of undue delay or for any other
    improper purpose, but rather to engage in good faith settlement discussions and
    by so
    doing, to conserve
    the resources of the parties and the Board.
    WHEREFORE, Respondent,
    CROP
    PRODUCTION
    SERVICES, respectfully
    moves
    the
    Illinois
    Pollution Control Board to grant it an extension of time as set forth
    above, and to award it all other relief just
    and proper
    in
    the premises.
    Respectfully submitted,
    CROP
    PRODUCTION
    SERVICES,
    Respondent,
    By: /s/ Edward W. Dwyer
    One of Its Attorneys
    Dated: August 4, 2009
    Edward W.
    Dwyer
    Monica T. Rios
    HODGE DWYER & DRIVER
    3150
    Roland
    Avenue
    Post
    Office
    Box
    5776
    Springfield, Illinois 62705-5776
    (217) 523-4900
    UAPR:002/Fil/MET2

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