STATE OF ILLINOIS
POLLUTION CONTROL
BOARD
JAMES R. THOMPSON CENTER
100 WEST RANDOLPH STREET, SUITE 11-500
.;
.
CHICAGO, ILLINOIS 60601
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BEFORETHE
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ILLINOIS POLLUTION CONTROL BOARD
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L. ERICKSON
)
Complainant,
)
)
v.
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PCB04-26
)
CHARLESTON CLASSIC HOMES,
)
INC., and LAWRENCE E. VAN
)
SOMEREN, JR.
Respondent.
.
)
RESPONDENT’S FIRST SET OF INTERROGATORIES
Now Comes Respondents CHARLESTON CLASSIC HOMES and LAWRENCE E. VAN
SOMEREN, JR. (hereinafterreferredto as “Respondent”), by and through their attorneys,THOMAS
A. APPEL and APPEL & APPEL, LTD., and pursuant to Section 10 1.620 requestthat you produce
the documents listed below for inspection, copying, and production within twenty-eight (28) days
ofthe date ofthis Requestat the offices ofAPPEL & APPEL, LTD., 18607 Torrence Avenue
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Suite
2A; Lansing, Illinois 60438.
INTERROGATORY NO. 1
Identify all persons who will testify in support of any of the allegations made in
Complainant’s Formal Complaint, and with respect to each such person state the subject matter of
their testimony and any opinion which may be given by such person.
ANSWER
INTERROGATORY NO. 2
Identify all neighbors, including name, ‘address and telephone whom Complainant believes
have been adversely affected by any noise generated by the Respondent.
ANSWER
INTERROGATORY NO. 3
Identify any equipment used by Complainant to create any sound recordings of noise
generated by Respondent.
ANSWER
INTERROGATORY NO. 4
Identifyany equipment usedby Complainant to track or log the days ofthe week or the hours
worked by Respondent or any ofits subcontractors.
ANSWER
‘
INTERROGATORY NO. 5
Identify all persons residingat 317 East Hawthorne Boulevard in Wheaton, Illinois between
July 16, 2003 and November 30, 2003, and with respect to each such person state their current
address and telephone number.
ANSWER
INTERROGATORY NO. 6
Identify any physicians, therapists orhealth care providers of any kind seen by Complainant
as a result of any purported noise generated by the Respondent, and with respect to each suchperson
state their current address and telephone number, and with respect to each such person state:
a) the date ofsuch visit;
b) any diagnosis;
c) any medication prescribed as a result of such visit.
ANSWER
INTERROGATORY NO. 7
Identify the dates that Complainant alleges she was forced to move out ofher home as a
result ofany purported noise generated by Respondent, and with respect to each such date state:
a) the duration of which she left her home;
b) any alleged cost incurred by Complainant in moving out of her home;
ANSWER
INTERROGATORY
NO. 8
State the name, address and telephone number of your employer and with respect to your
employment state:
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a) your occupation;
b) your annual income earned from your occupation for years 2001, 2002 and 2003;
c) identify the amount of income which you contend you lost as a result of any purported
noise generated by Respondent
ANSWER
INTERROGATORY NO. 9
Describe how any noise generated by Respondent resulted in a loss ofincome to you.
ANSWER
CHARLESTO~ASSIC~OM~S, ~C.
LAWRENçE~.VANSO~(ER7~~R.
,
BY
________
E5n~&ftthèir a &n~y~7
~U.
CERTIFICATE OF SERVICE
I, the undersigned, certify that I have served the attached Interrogatories by regularU.S. Mail,
upon the following persons:
Clerk, Illinois Pollution Control Board
100 West Randolph Street
James R. Thompson Center
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Suite 11-500
Chicago, Illinois 60601-3218
Carol Sudman
Hearing Officer
ILLINOIS POLLUTION CONTROL BOARD
1021 N. GrandAve. E
P.O. Box 19274
Springfield IL 62794-9274
Lynn Erickson
317 East Hawthorne Boulevard
Wheaton, Illinois 60187
Thomas A. Appel
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APPEL & APPEL, LTD. #9 1575
18607 Torrence Avenue
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Suite 2A
Lansing, Illinois 60438
708-474-8800