1. RECEIVEDCLERK’S OFFICE
      2. STATE OF ILLINOIS
~1GCEIVED
ILLINOIS POLLUTION CONTROL BOARD
CLERKS OFFICE
PEOPLE OF THE STATE OF ILLINOIS,
)
CCI 14 2005
)
STATE OF ILLINOIS
Complainant,
)
~nhIution
ControlBoard
)
vs.
)
No. PCB 05-117
)
CITY OF CAIRO,
)
)
Respondent.
)
NOTICE OF FILING
To:
Thomas Davis
Office of the Attorney General
Environmental Bureau
500
South Second Street
Springfield, Illinois 62706
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of
the Pollution Control Board ofthe State ofIllinois, its ANSWER TO AMENDED
COMPLAINT, a copy ofwhich is attached hereto and herewith served upon you.
Respectfully submitted,
BY:
CIT-kMichael
P.CO’Shea, Jr.
ft.—
Attorney forrespondent
City ofCairo
BUSiNESS ADDRESS:
Michael P. O’Shea, Jr.
216-10th St., P.O. Box 791
Cairo, Illinois 62914
Tel: (618)734-1199
Fax: (618) 734-1245
ARDCNo: 2122197
CERTIFICATE OF SERVICE
It is hereby certified that the original ofthe foregoing notice offiling was mailed,
first class, for filing, on October 11, 2005, to the following address:
Dorothy M. Gunn, Clerk
Illinois Pollution Control Board
James it Thompson Center
100 W. Randolph St., Ste. 11-500
Chicago, Illinois 60601
and a copy ofthe foregoing motion was mailed, first class, on October 11, 2005, to the
following person:
Thomas Davis
Office ofthe Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
RECEIVED
CLERK’S OFFICE
ILLINOIS POLLUTION CONTROL BOARD
oci 1 ~2005
STATE OF ILLINOIS
PEOPLE OF THE STATE OF ILLINOIS,
)
Pollution Control Board
)
Complainant,
)
)
Vs.
)
No. PCBO5-117
)
CITY OF CAIRO,
)
)
Respondent.
)
ANSWER TO AMENDED COMPLAINT
Now comes respondent, City of Cairo, by its attorney, Michael P. O’Shea, Jr.,
and, for its answer to the amended complaint filed herein, says, as follows:
COUNT I
1-4.
Respondent admits the allegations contained in paragraphs I through 4 of
the amended complaint filed herein.
5.
Respondent neither admits nor denies the allegations contained in
paragraph S of the amended complaint filed herein but demands strict proof thereof
6-7.
Respondent denies the allegations contained in paragraphs 6 and 7 ofthe
amended complaint filed herein.
8.
Respondent neither admits nor denies the allegations contained in
paragraph 8 of the amended complaint filed herein but demands strict proofthereof
9.
Respondent admits the allegations contained in paragraph 9 ofthe
amended complaint filed herein.
10-Il. Respondent denies the allegations contained in paragraphs 10 and 11 of
the amended complaint filed herein.
Wherefore, defendant, City ofCairo, prays forjudgment adverse to plaintiffon
count I and for costs ofsuit.
CITY OF CAIRO
By:
____
Its Attorney
COUNT II
1-4.
Respondent admits the allegations contained in paragraph 1 through 4 of
the amended complaint filed herein.
5.
Respondent neither admits nor denies the allegations contained in
paragraph S ofthe amended complaint filed herein but demands strict proof thereof
6-7.
Respondent denies the allegations contained in paragraphs 6 and 7 of the
amended complaint filed herein.
8.
Respondent neither admits nor denies the allegations contained in
paragraph 8 of the amended complaint filed herein but demands strict proof thereof
9.
Respondent admits the allegations contained in paragraph 9 ofthe
amended complaint filed herein.
10-11. Respondent denies the allegations contained in paragraphs 10 and 11 of
the amended complaint filed herein.
Wherefore, defendant, City ofCairo, prays for judgment adverse to plaintiffon
count II ofits complaint and for costs of suit.
CITY OF CAIRO
By:
Its Attorney
14~
ft,
z
BUSINESS ADDRESS:
Michael P. O’Shea, Jr.
216-10th St., P.O. Box 791
Cairo, Illinois 62914
Tel: (618) 734-1199
Fax: (618)734-1245
ARDCNo: 2122197
CERTIFICATE OF SERVICE
It is hereby certified that the original ofthe foregoing motion was mailed, first
class, for filing, on October 11,2005, to the following address:
Dorothy M. Gunn. Clerk
Illinois Pollution Control Board
James R. Thompson Center
100W. Randolph St., Ste. 11-500
Chicago, Illinois 60601
and a copy of the foregoing motion was mailed, first class, on October 11, 2005, to the
following person:
Thomas Davis
Office ofthe Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706

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