CLE~KSE~
APR 26 2004
STATE OF ILLINQJ3
Pollution Control Board
OFFICE OF THE ATI’ORNEY GENERAL
STATE OF ILLINOIS
Lisa Madigan
ATTORNEY GENERAL
April 22, 2004
The Honorable Dorothy Gunn
Illinois Pollution Control Board
James R. Thompson Center, Ste. 11-500
100 West Randolph
Chicago, Illinois 60601
Re:
People v. Medical Waste Management, Inc., a Missouri corporation
PCB No. 04-1 65
Dear Clerk Gunn:
Enclosed for filing please find the original and ten copies of a NOTICE OF FILING and
MOTION FOR VOLUNTARY DISMISSAL in regard to the above-captioned matter. Please file the
originals and return file-stamped copies of the documents to our office in the enclosed self-
addressed, stamped envelope.
Thank you for your cooperation and consideration.
Very truly yours,
Sally A. Carter
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
(217) 782-9031
SAC/pp
Enclosures
500 South Second Street,
Springfield,
Illinois 62706 •
(217) 782-1090
•
1’TY:
(217) 785-2771 • Fax: (217) 782-7046
100 West Randolph Street, Chicago. Illinois 60601 • (312) 814—300() • ~I1’Y: (312) 814—3374 • Fax: (312) 814—3806
1001 1
ist
\I on (
irboiid
ilt. Illinois 62901
(618) ~Z9 6401)
1 I
‘t
(61~)~29640~• 1
i~
(618) ~296416
REC~VED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARDCLERK’S OFFICE
PEOPLE OF THE STATE OF
)
APR
262004
ILLINOIS,
)
STATE
OF ILL!NOIS
)
Pollution Control Board
Complainant,
vs.
)
PCB No. 04-1 65
MEDICAL WASTE MANAGEMENT, INC.,
)
a Missouri corporation,
)
Respondent.
NOTICE OF FILING
To:
Wally El-Beck
Wally El-Beck
394 Summitt
136 East Hazel Dell Lane
Blytheville, AR 72315
Springfield, IL 62707
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
Control Board of the State of Illinois, a MOTION FOR VOLUNTARY DISMISSAL, a copy of which
is attached hereto and herewith served upon you.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN,
Attorney General of the
State of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/Asbestos
Litigation Division
BY:____________
SA~YA. CARTER
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: April 22, 2004
1
CERTIFICATE OF SERVICE
I hereby certify that I did on April 22, 2004, send by First Class Mail, with postage thereon
fully prepaid, by depositing in a United States Post Office Box a true and correct copy of the
following instruments entitled NOTICE OF FILING and MOTION FOR VOLUNTARY
DISMISSAL
To:
WaIIy El-Beck
Wally El-Beck
394 Summitt
136 East Hazel Dell Lane
Blytheville, AR 72315
Springfield, IL 62707
and the original and ten copies by First Class Mail with postage thereon fully prepaid of the
same foregoing instrument(s):
To:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
Suite 11-500
100 West Randolph
Chicago, Illinois 60601
A copy was also sent to:
Carol Sudman
Hearing Officer
Illinois Pollution Control Board
1021 N. Grand Avenue East
Springfield, IL 62794
Sally A~arter
Assistant Attorney General
This filing is submitted on recycled paper.
RECEIVED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
APR
262004
PEOPLE OF THE STATE OF ILLINOIS,
)
-
POULItIOn COntrOl Board
Complainant,
-vs-
)
PCB No. 04-165
MEDICAL WASTE MANAGEMENT, INC., a
)
Missouri Corporation,
)
Respondent.
MOTION FOR VOLUNTARY DISMISSAL
NOW COMES the Complainant, PEOPLE OF THE STATE OF ILLINOIS, by its attorney,
LISA MAD IGAN, Attorney General of the State of Illinois, and pursuant to Section 2-1009 of the
Illinois Code of Civil Procedure, 735 ILCS 5/2-1 009 (2002), and 35 III. Admin. Code 101 .500,
moves this Board to voluntary dismiss this action without prejudice. In support of this Motion for
Voluntary Dismissal, the Complainant states as follows:
1.
A Complaint was filed March 22, 2004.
2.
On March 25, 2004, Medical Waste Management, Inc. filed a Chapter 7
Bankruptcy case in the United States Bankruptcy Court, Eastern District of Arkansas. The
Complainant received notice of the bankruptcy filing on April 19, 2004. The Automatic Stay
prohibits the continuation of an action seeking the imposition of any monetary judgment against
the debtor, the Complainant respectfully requests that this Board grant this Motion for Voluntary
Dismissal.
WHEREFORE, Complainant respectfully prays that this Board grant the Motion for
Voluntary Dismissal.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
ex rel. LISA MAD IGAN
Attorney General of the
State of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/Asbestos
Litigation Division
BY:____________________
THOMAS DAVIS, Chief
Environmental Bureau
Assistant Attorney General
Of Counsel
SALLY A. CARTER
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated:
~.-//2~2/o~/
2
