1. NOTICE OF FILING
  1. SERVICE LIST
  2. MOTION FOR ORDER TO PRODUCE AT HEARINGPURSUANT TO PCB 101.614
  3. TO: Bradley P. Halloran, Hearing Officer
  4. BY: DavidN. Stone
No.2625
P
2
Vs.
Respondent.
)
)
)
)
)
)
Nov.
5
2003
3:23PM
BEFORE THE ILLiNOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS
)
ox rel. GARY W. PACK,
)
McHenry County State’s Attorney,
)
)
Complainant,
PCB 01-43
(RCRA Enforcement)
MICHAEL STRINGINI,
NOTICE OF FILING
TO:
SEE ATTACHED
SERVICE LIST
On
the date
indicated below, the Plaintiff mailed its
MOTION FOR ORDER
TO PRODUCE AT
HEARJNG PURSUANT TO PCB
101.614,, a copy
you,
~~~istant
Stat&s
Attorney,
Gary
W.
Pack,
McHenry
Cotmty
State’s
Attorney
CERTiFICATE OF SERVICE
I, David N. Ston; an Assistant State’s Attorney in this case, do
certify
that
I caused to be
mailed this 5h day ofNovember, 2003, the foregoing NOTICE OF FILING upon the persons
listed
on the attached service list by certified mail in an envelope bearing sufftcient postage with
the United States Postal Service located at 1050
Illinois 60098,
CLERK’S
OPF~(~r~
NOV
5
2003
STATE
OF ILLINOIS
Pollution
Control
Board
Nov
5.
2003
3:24PM
No2625
~.
3

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SERVICE LIST
Case
No.
PCB
01-43
NAME~
INTEREST:
POLLUTION
CONTROL
BOARD CLERK
ORIGINAL
PLUS
FOUR
COPIES
JAMES
R THOMPSON
CENTER STE
11-500
100W RANDOLPH
STREET
CHICAGO IL
60601
MR
MICHAEL STRINGINT
Defendant
437SPRUCE CT
SCHAUMBIJR.G IL 60193
PATJLJAGIELLO
Non
record
Attorney
for
ILLiNOIS
EPA
IEPA
95I1WEST HARRISON ST
DESPLAINES
IL 60016
Gary
W.
Pack,
McHeriry
County
State’s
Attorney
David
N.
Stone,
Aseistant
State’s Attorney
McHenry County Government Center
2200
N.
Seminary
Ave.
Woodstock,
IL.
60098
815
334
4159
Atty
No.
02744309
\w~s~cum~a\-
sToN~\L259QsTgINGIN!\PL~D\NoT
FILING
MOT
~‘RQD 1J.O5O~.doc
2
NOV.
5
2003
3:24PM
No.2625
P.
4
BEFORE
THE ILLiNOIS POLLUTION CONTROL
BOARD
PEOPLE OF THE STATE OF ILLINOIS
)
ex rel.
GARY W.
PACK,
)
McHenry County State’s Attorney,
)
)
Complainant,
)
vs.
)
PCBO1-43
)
(~RCRA
Enforcement)
MICHAEL STRING1NI,
)
Respondent.
)

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MOTION FOR ORDER TO PRODUCE AT HEARING
PURSUANT TO PCB 101.614
Now comes the Complainant
and moves the Hearing Officer
pursuant to PCB 101.614
to
order the Defendant, Michael StringinI
to produce
the
following materials at the hearing on civil
penalty~
-
a. All records of receipts ofmoney from Sloan Valve Company during the
caiendar
years
1980 through
1984 for Defendant’s receiving foundry sand from Sloan Valve that was delivered
to the Zimmerman
Property in Union, Illinois,
b. Defendant’s individual state
and
federal income
tax
returns for the calendar years
1980
through 1984
and
the calendar years 2001
and
2002.
c. A
current
financial statement listing Defendant’s current assets
and
liabilities,
This
infonnatlon is relevant to the matter
under consideration being the amount
ofcivil
penalty that should be assessed and
is information that the Pollution Control Board in its
INTERtM
OPINION AND ORDER dated October 16, 2003
specifically directed
the
parties
to
address at the
hearing
on the penalty phase ofthe
proceeding.
This
information was not specifically requested during the
discovery and
discovery in
this case is closed, The Complainant would not normally be interested
in providing this
information since it tends to
go, in
large
part, to mitigation.
Since
the
Defendant is pro so,
he
should be ordered to provide this information so that the evidence
adduced at the hearing will be
inclusive ofwhat theBoards iNTERIMORDER
deemed necessary to impose a civil penalty.
Nov.
5.
2003
3:24P1vI
No.2625
P
5
Respectfully submitted,
GARY W. PACK
Mcli
~2o
y State’s Attorney
Assistant
State’s Attorney
DATE:
November
5,
2003
Gary
W. Pack, MeHenry County State’s Attorney
David N. Stone, Assistant State’s Attorney
McHenry County Govermnent Center
2200 N. Seminary
Ave.
Woodstock,
IL. 60098
8153344159
AttyNo. 02744309
o~\wPsacuRE\-STQW5\L2~O ~T
N~INr\l’L~D\M~T
ORDER TO PRODtJCE 11Q5O~.do~
2
~OV
.
0.
LUU~
~
Office of the State’s Attorney
McHENRY COUNTY
NINETEENTH JUDICIAL
CIRCUIT OF ILLINOIS
CLERK’S
OFFICE
NOV
5
.2003
STATE OFILLINOIS
Pollution
Control
Board
GARY W.
PACK
MCHENRY
COUNTY GOVERNMENT
CENTER
STATE’S ATTORNEY
2200 NORTH
SEMiNARYAVENUE
WoonsTocir, ILLINoIS 60098
PHONE;
(815) 334-4159
Fax~
(815)
337-0872
Date~November
5,
2003
FACSIMILE
TRANSMITTAL
SHEET

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TO:
Bradley P. Halloran, Hearing Officer
FAX#:
312 8143669~~2~
FROM:
Mcflenry County State’s Attorney
—
Civil Division

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BY:
DavidN. Stone
2200 North
Seminary
Avenue
Woodstock, IL 60098
(815) 334-4159/FAX
(815)
337-0872
This
transmission consists
of the following number of pages
(including
this
cover sheet): 5
In Re:
People v, Stringini
Original transmitted document to follow by mall~
**
Dear Mr.
Halloran:
Per your instructions
you will find a copy ofmy motion to
produce.
This is being mailed with
four copies to
the
PCB
clerk and also to Mr.
Stringini.
I have also
mailed a
motion to non-suit Counts
V
& VII
to
the
clerk with
nine
copies
for the
Board. I assume
you do not need that faxed to you.
The Information contained in
this facsimile message is attorney
privileged and
confidential information intended
only
for
the
use of the
individual
or
entity
named above.
If
the
reader of
this
message Is not
the
intended
recipient, or
the employee
or
agent responsible
to
deliver
it
to
the
intended
recipient,
you
are
hereby
notified
that
any dissemination,
distribution
or
copying of this communication
Is stdctly prohibited.
If you have
received this communication In
error, please immediately
notify
us by telephone
and
return
the
orLginal message to
us at the
above address
via
the US Postal Service.
Thank you.
0 \W~5EctJRE\-S’I’ONE\L2S90 sT?.~OIN~\CORR\HALL~0R~N
~AX ~.1O5O3.doe

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