THE ILLINOIS POLLUTION CONTROL BOARD
PAUL and DONNA FREDRICKSON
husband and wife
Complainants
NOTICE OF ALING
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the Pollution
Control Board Respondent’s Request for Admission of Fact and Notice to Produce in this
matter.
GedI~geW. Tinkham
attorney for Respondent
ARDC reg. #2836149
1119 ~• 6th Street
Springfield, IL 62703
(217) 523-8300
CERTIFICATE OF SERVICE
I, the undersigned, certify that I have this day served the attached Request for Admission of
Fact and the attached Notice to Produce by mailing first class upon the following persons:
Illinois Pollution Control Board
Attention: Clerk
100 W. Randolph Street
James R. Thompson Center
Suite 11-500
Chicago, Illinois 60601
Jeremy W. Shaw, Esq.
40 Brink Street
Crystal Lake, Illinois 60014
Date: 6 February 2004
Illinois Pollution Control Board
Attention: Bradley P. Halloran, Hrg. Officer
100 W. Randolph Street
James R. Thompson Center
Suite 11-500
Chicago, Illinois 60601
)
)
)
)
RECEIVED
CLERK’S OFFICE
FEB 1 02004
STATE OF ILLINOIS
Pollution Control Board
v.
)
)
Jeff Grelyak,
)
Respondent.
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PCB 04-19
G~orgeW.Tinkham
RECEIVED
CLERKS OFFIC
THE ILLINOIS POLLUTION CONTI~~~9A~
OFControlILL~MO~oard19
REQUEST FOR ADMISSION OF FACT
COMES NOW, JEFFREY S. GRELYAK, Respondent herein, by counsel and requests that
Complainants admit certain facts listed below. Failure to respond to the following requests to
admit within 28 days may have severe consequences. Failure to respond to the following
requests will result in all the facts requested being deemed admitted as true for this proceeding.
If you have any questions about this procedure, you should contact the hearing officer assigned
to this proceeding or an attorney.
1.
Please admit that the complained-of motorcycles and ATVs do not operate on
Respondent’s property during morning hours.
2.
Please admit that the complained-of motorcycles and ATVs do not operate on
Respondent’s property on Mondays and Tuesdays.
3.
Please admit that, if said motorcycles and AT\Js do operate in the morning or on Monday
or Tuesday, such operation is infrequent.
4.
Please admit that there are other sources of noise or dust or fumes which impact
Complainants’ property and their use of that property.
Respectfully submitted,
Jeffrey S. Grelyak, Respondent
Date: 6 February 2004
By: _______________________
~
Geo~’eW. Tinkham
his attorney
ARDC reg. # 2836149
George W. Tinkham
1119 S. 6th Street
Springfield, Illinois 62703
(217) 523-8300
PAUL and DONNA FREDRICKSON,
husband and wife
V.
Jeff Grelyak,
Complainants
Respondent.
)
)
)
)
)
)
)
PCB 04-19
THE ILLINOIS POLLUTION CONTROL BOARD
PAUL and D
husband and
ONNA FREDRICKSON,
wife
Complainants
)
)
)
V.
Jeff Grelyak,
Respondent.
)
)
)
PCBO4-19
RECEIVED
CLERK’S OFFICE
FEB 102004
STATE OF ILLINOIS
Pollution Control Board
NOTICE TO PRODUCE
COMES NOW, JEFFREY S. GRELYAK, Respondent herein, by counsel and requests that
Complainants produce all documents, recordings, photos (whether digital or on film or slide),
notes, journal entries, communications, reports or statements (whether from experts or other-
wise), marked calendars, and other records pertaining to the activities or conditions complained
about in the Complaint in this matter.
Respectfully submitted,
Jeffrey S. Grelyak, Respondent
By:
his attorney
ARDC reg. #2836149
Date: 6 February 2004
George W. Tinkham
1119 S. 6th Street
Springfield, Illinois 62703
(217) 523-8300