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