BEFORE
    THE ILLINOIS POLLUTION CONTROL BOARD
    PEOPLE OF THE STATE OF ILLINOIS
    )
    ex rel. GARY W. PACK,
    )
    McHenry County State’s Attorney,
    )
    ~
    ~
    Complainant,
    )
    ~
    vs.
    )
    PCB 01-43
    )
    (RCRA Enforcement)
    ERI(’S
    ~
    MICHAEL STRIINGINI,
    )
    AUG
    i~
    )
    Respondent.
    )
    OF ILLl~.
    Litfon
    Cont,~I
    ~
    REPLY TO
    JUNE
    29TH
    RESPONSE OF RESPONDENT
    Now comes the Complainant and in reply to the Response ofRespondent apparently filed
    on July
    1, 2004 (two days beyond date ofextension), a copy ofwhich was faxed to
    Complainant
    on July
    19, 2004 and appears to
    have been faxed to the Board on June 29, 2004 (all in violation
    ofprocedural rules) the following is noted in reply:
    1.
    To
    the extent that the Response attempts to
    introduce new evidence, Complainant
    respectfully requests the board to ignore such evidentiary statements about his current
    business activities because Complainant was not afforded the opportunity ofcross
    examination. The hearing transcript speaks for itself.
    2.
    The implication that the State’s Attorney (Stone) has,a conflict ofinterest is not
    responsive to the briefof Complainant or in summary ofthe evidence and could only be
    addressed by motion made prior to
    this point of the proceedings. Therefore,
    Complainant
    respectfully requests
    the Board to disregard those comments by respondent.
    Respectfully submitted,
    GARY W. PAC
    McHenry
    ty St
    e’s Attorney
    By
    David N. ~
    Assistant
    State’s Attorney
    CERTIFICATE OF SERVICE
    I, David N. Stone, an Assistant State’s Attorney in this case, do certify that I caused to
    be
    mailed this
    16TF1
    day ofAugust, 2004, the foregoing REPLY TO JUNE
    29T~~
    RESPONSE
    OF
    RESPONDENT upon the persons listed on the attached service list by certified mail in an

    envelope bearing sufficient postage with the United States Postal Service located at
    1050
    Country Club Road,
    Woodstock, Illinois 60098.
    David N. Stone
    SERVICE LIST
    Case
    No.
    FOB
    01-43
    NAME:
    INTEREST:
    POLLUTION CONTROL BOARD
    CLERK
    ORIGINAL PLUS
    NINE COPIES
    JAMES R THOMPSON CENTER STE
    11-500
    .100 W RANDOLPH STREET
    CHICAGO IL 60601
    MR
    MICHAEL
    STRINGIINI
    Defendant
    1108
    S WESTOVER LANE
    SCHAUMBURG IL 60193
    PAUL JAGIELLO
    Non record Attorney for IEFA
    ILLiNOIS EPA
    951
    1WEST HARRISON ST
    DESPLAINES IL 60016
    DATE:
    August 16, 2004
    Gary W. Pack, Mdllenry County State’s Attorney
    David N. Stone, Assistant State’s Attorney
    McHenry County Government Center
    2200 N. SeminaryAve.
    Woodstock, IL.
    60098
    815 3344159
    2

    Back to top