1. ANSWER
      1. COUNT II
RECEIVED
C~
~R~SOFFTr~
IN THE CIRCUIT COURT. OF COOK COUNTY, ILLINOIS SEP 0 8 2003
COUNTY DEPARTMENT, CIVIL DIVISION
STATE 01-ILLINOIS
PEOPLE OF THE STATE OF ILLINOIS
Pollution
control
Board
Complainant,
v.
No. 04-07
(Enforcement-Air)
4832 S. VINCENNES, L.P., an flhinois Limited
Partnership and BATTEAST CONSTRUCTION
COMPANY, an Illinois Corporation,
Respondents.
ANSWER
NOW COMES, Respondent, 4832 S. VINCENNES, L.P., by and through its attorneys,
MILLER & FERGUSON and answers Complainant’s Complaint as follows:
1.
Respondent admits the allegations ofParagraph One.
2.
Respondent admits the allegations ofParagraph Two.
3.
Respondent admits the allegations of Paragraph Three.
4.
Respondent admits the allegations of Paragraph Four.
5.
Respondentadmits the allegations of Paragraph Five.
6.
Respondentneither admits nor denies the allegations of Paragraph Six, but
demands strict proof thereof.
7.
Respondent admits the allegations of Paragraph Seven.
8.
Respondent denies the allegations of Paragraph Eight.
9.
Respondent neither admits nor denies the allegations of Paragraph Nine, but
demands strict proof thereof.
10.
Respondent neither admits nor denies the allegations of Paragraph Ten,but
demands strict proof thereof.
11.
Respondent neither admits nor denies the allegations of Paragraph Eleven, but
demands strict proof thereof.
12..
Respondent denies the allegations of Paragraph Twelve.
13.
Respondent neither admits nor denies the allegations of Paragraph Thirteen, but
demands strict proofthereof.
14.
Respondent neither admits nor denies the allegations of Paragraph Fourteen, but
demands strict proof thereof.
15.
Respondent admits the allegations of Paragraph Fifteen.
16.
Respondent admits the allegations of Paragraph Sixteen.
17.
Respondent admits the allegations of Paragraph Seventeen.
18.
The referenced statute speaks foritself.
19.
The referenced statute speaks for itself.
20.
The referenced statute speaks for itself.
21.
The referenced statute speaks for itself.
22.
The referenced statute speaks for itself.
23.
Respondent admits the allegations of Paragraph Twenty-Three.
24.
Respondentadmits the allegations of Paragraph Twenty-Four.
25.
Respondentdenies the allegations of Paragraph Twenty-Five.
26.
Respondentdenies the allegations of Paragraph Twenty-Six.
27.
Respondent neither admits nor denies the allegations of Paragraph Twenty-
Seven, but demands strict proof thereof.
28.
Respondent denies the allegations of Paragraph Twenty-Eight.
WHEREFORE, the Respondent, 4832 5. Vincennes, L.P., respectfully requests that the
Board deny the relief sought by Complainant.
COUNT II
FAILURE
TO INSPECT AND TO FOLLOW
PROPER EMISSION CONTROL PROCEDURES
1-22.
Respondent restates and incorporates herein by reference Paragraphs 1 through 17 and 20
through 24 of Count I as Paragraphs I through 22 of this Count II.
23.
The referenced statute speaks for itself.
24.
The referenced statute speaks foritself.
25.
The referenced statute speaks for itself.
26.
The referenced statute speaks for itself.
27.
The referenced statute speaks for itself.
28.
The referenced statute speaks for itself.
29.
The referenced statute speaks foritself
30.
Respondent neither admits nor denies the allegations ofParagraph Thirty, but demands
strict proof thereof
31.
Respondent admits the allegations of Paragraph Thirty-One.
32.
Respondent neither admits nor denies the allegations ofParagraph Thirty-Two, but
demands strict proof thereof
33.
The referenced statute speaks for itself
34.
The referenced statute speaks foritself
35.
The referenced statute speaks foritself
36.
Respondentdenies the allegations of Paragraph Thirty-Six.
37.
Respondent denies the allegations of Paragraph Thirty-Seven.
38.
Respondent denies the allegations of Paragraph Thirty-Eight.
39.
Respondent denies the allegations of Paragraph Thirty-Nine.
WHEREFORE, Respondent, 4832 5. Vincennes, L.P.,by its attorneys respectfully
requests that the Board denies the relief sought by Complainant.
Respectfully submitted,
Miller & Ferguson
By:________________________
Miller & Ferguson, #9 1662
9415 South State Street
Chicago, Illinois 60619
(773) 660-4300
CLF~ç~ç Fi(p
Verification
PoJ/~t,STATE
SEP
0~
Ui-
Con
0
ILUNOIS
8
troj
2003
Board
I,
being first duly sworn on oath, deposes and states pursuant to
735 ILCS
5/1-109
that he is the above and foregoing Respondent and certifies that the statements
set forth in this instrument are true and correct, except as to matters therein stated to be on
information andbelief and as to such matters the undersigned certifies as aforesaid that he verily
believes the same to be true.
Miller & Ferguson, #9 1662
9415 South State Street
Chicago, Illinois 60619
(773) 660-4300

Back to top