1. Economy Plating, Inc., an Illinois
    2. Corporation,
    3. Respondent.
    4. NOTICE OF FILING
      1. CERTIFICATE OF SERVICE BY MAIL
    5. People of the State of Illinois,
    6. Complainant,
    7. MOTION FOR LEAVE TO FILE ANSWERTO SECOND AMENDED COMPLAINT INSTANTER
    8. Economy Plating, Inc.
    9. ANSWER OF ECONOMY PLATING, INC.TO SECOND AMENDED COMPLAINT
    10. attorneys, Stone, Pogrund & Korey, and for its answer alleges as follows:
    11. COUNT I
    12. OPERATING WITHOUT A PERMIT
    13. 1. That Respondent has insufficient information or knowledge to respond to
    14. 6. That the allegations of paragraph 6 of the Count I of Complainant’s
    15. COUNT Ill
    16. FAILURE TO FILE ANNUAL REPORTS
    17. 1-9. The Respondent realleges and reaffirms its answers for paragraphs 1
    18. COUNT IV
    19.  
    20. 16 of the Count IV of Complainant’s
    21. 26. That Respondent denies each and every allegation contained in
    22. Wherefore, the Respondent, Economy Plating, Inc. asks the Illinois Pollution
    23. CERTIFICATION VIOLATION
    24. 1-13. The Respondent realleges and reaffirms its answers for paragraphs I
    25. 19. That Respondent denies each and every allegation contained in
    26. 20. That Respondent denies each and every allegation contained in
    27. paragraph 20 of Count V of Complainant’s Complaint.
    28. Wherefore, the Respondent, Economy Plating, Inc. asks the Illinois Pollution
    29. Economy Plating, Inc.
    30. One of its Attorneys
vs.
Economy Plating,
Inc., an
Illinois
Corporation,
Respondent.
)
)
)
)
No. PCB 97.69
)
(Enforcement
-
Air)
)
)
)
)
RECEIV~EL~
CLERT’c
~
JUN
3
2C03
NOTICE OF
FILING
TO:
Bradley
P.
Halloran
Hearing Officer
Illinois Pollution Control Board
100 W. Randolph
St, Ste
11-500
Chicago, IL 60601
Zemeheret Bereket-AB
Office of The Attorney General
State of Illinois
188 West Randolph Street
-
20th Floor
Chicago,
Illinois
60601
Please take notice that the Respondent,
Economy Plating,
Inc., filed with the Illinois
Pollution Control Board,
its
Motion for Leave to File, a true and correct copy of which
is
attached
hereto and
is hereby served
upon you.
By:
Christopher
One of its Attorneys
CERTIFICATE OF SERVICE BY MAIL
I, CHRISTOPHER T. NOWOTARSKI,
the attorney,
certify that I served this Motion
for Leave to File by mailing a copy to the above named parties at the above named address and
depositing the same in the U.S.
mail at 221
North LaSalle Street, Chicago, Illinois at
4:45
P.M.,
on June
~?
,
2003, with proper postage prepaid.
c~
~
Christopher T. Nowotarski
STATE OF ILLINOIS
)
)SS
COUNTY OF COOK
)
STAft
U~
~
BEFORE
THE
ILLINOIS POLLUTION CONTROL BOa~~tjon
Control Boa
rc~
People of the State of Illinois,
Complainant,
STATE OF ILLINOIS
)
)SS
~
COUNTY OF COOK
)
CLT~RT’~OFrICE
JUN
~ 2003
BEFORE THE
ILLINOIS POLLUTION CONTROL BOARI~TATE
OF ILLINOIS
Pollution
Control
Board
People of the State of Illinois,
)
)
)
Complainant,
vs.
)
No.
PCB 97-69
)
(Enforcement
-
Air)
Economy Plating, Inc.,
an Illinois
)
Corporation,
)
)
Respondent.
MOTION FOR LEAVE TO FILE ANSWER
TO SECOND AMENDED COMPLAINT INSTANTER
NOW COMES the Respondent, Economy Plating, Inc., (“Respondent”) by
its
attorneys, Stone, Pogrund
& Korey, and
asks the Illinois
Pollution Control
Board for
leave to file its answer to Complainant’s Second Amended Complaint and alleges
as
follows:
I
That Respondent did receive a copy of Complainant’s Second Amended
Complaint on or about November 14, 2002.
2
That Respondent did prepare a answer to said Second Amended Complaintand
inadvertently, failed to file the answer as required.
3
That Respondent has attached hereto a copy of it’s answer.
4
That no prejudice will occur to Complainant by allowing the Respondent to file
its
answer at this time.
Wherefore,
Respondent,
Economy Plating, Inc.,
requests that the
Board allow
it to file it’s answer instanter.
Respectfully Submitted,
Economy Plating, Inc.
By:
CLLIkJ~1
Christophe
owotarski
One of its Attorneys
Christopher T. Nowotarski
Stone, Pogrund & Korey
Attorney for Respondent
221
North LaSalle Street, #3200
Chicago,
Illinois
60601
(312) 782-3636
STATE OF ILLINOIS
)
liVED
)SS
CLERI’S
OFFICE
COUNTY OF COOK
)
JUN
~9
2003
STATE OF ILUNOIS
BEFORE THE
ILLINOIS POLLUTION CONTROL ~hIARD
Control Board
People of the State of Illinois,
)
)
)
Complainant,
)
vs.
)
No. PCB 97-69
)
(Enforcement
-
Air)
Economy Plating, Inc., an Illinois
)
Corporation,
)
)
Respondent.
)
ANSWER OF
ECONOMY PLATING, INC.
TO SECOND AMENDED COMPLAINT
NOW COMES the Respondent,
Economy Plating, Inc., (“Respondent”) by
its
attorneys,
Stone, Pogrund & Korey, and for its answer alleges as follows:
COUNT
I
OPERATING WITHOUT A PERMIT
1.
That Respondent has
insufficient information or
knowledge to
respond to
the allegations contained in paragraph I of Count I ofComplainant’s complaint and
neither admits
nor denies same but demands strict proofthereof.
2.
That Respondent
admits each
and
every allegation contained
in
paragraph 2 of Count
I of Complainant’s complaint.
3.
That Respondent
admits each
and
every allegation contained in
paragraph 3 of Count I of Complainant’s complaint.
4.
That Respondent admits
each and every allegation contained in
paragraph 4 of Count
I of Complainant’s Complaint.
5.
That the allegations of paragraph
5 of the Count
I of Complainant’s
Complaint recite
language of a statute which speaks for itself and
Respondent therefore
does not need to respond to said allegations.
6.
That the allegations of paragraph 6 of the Count I
of Complainant’s
Complaint
recite language of a statute which speaks for itself and Respondent therefore
does not need to respond to said allegations.
7.
That Respondent admits the emitting of chromium could pose a danger to
the environment, but Respondent denies that such a emitting occurred.
For further
affirmative answer of the paragraph 7 of the Count
I
of Complainant’s Complaint recite
language of a statute which speaks for itself and
Respondent therefore refuses to
respond to said
allegations.
8.
That Respondent admits the emitting of chromium could pose a danger to
the environment, but Respondent denies that such a emitting occurred.
For further
affirmative answer ofthe paragraph
8 of the Count
I of Complainant’s Complaint recite
language of a statute which speaks for itself and Respondent therefore refuses to
respond to said allegations.
9.
That Respondent admits
each
and every allegation contained
in
paragraph 9 of Count I of Complainant’s Complaint.
10.
That Respondent admits each and every allegation contained in
paragraph 10 of Count I of Complainant’s Complaint.
2
11.
That the allegations of paragraph
11
of the Count
I of Complainant’s
Complaint recite
language of a statute which speaks for itself and Respondent therefore
does not need to respond to said
allegations.
12.
That the allegations of paragraph 12 ofthe Count I of Complainant’s
Complaint recite
language of a statute which speaks for itself and
Respondent therefore
does not need to respond to said allegations.
13.
That Respondent admits each and every allegation contained in
paragraph 13 of Count I of Complainant’s Complaint.
14.
That Respondent denies each and every allegation contained in
paragraph
14 of Count
I of Complainant’s Complaint.
15.
That Respondent denies each and every allegation
contained in
paragraph 15 of Count
I of Complainant’s Complaint
16.
That Respondent denies each and every allegation contained in
paragraph
16 of Count
I of Complainant’s Complaint.
Wherefore, the Respondent, Economy Plating,
Inc. asks the Illinois
Pollution Control Board to Dismiss the above captioned matter with prejudice and
without costs.
3
COUNT
II
CONSTRUCTION WITHOUT PERMIT
1-6.
The
Respondent
realleges and reaffirms its answers for paragraphs
1
through 6 inclusive of Count
I
of Complainant’s Complaint as its answer to paragraphs
I
through 6 inclusive of Count II of Complainant’s Complaint.
7.
That
Respondent admits each
and every allegation contained
in
paragraph 7 of Count II of Complainant’s Complaint.
8.
That
Respondent admits each
and every allegation contained in
paragraph
8 of Count
II of Complainant’s Complaint.
9.
That the allegations of paragraph
9 of the Count
II of Complainant’s
Complaint recite language of a statute which speaks for itselfand
Respondent therefore
does
not need to respond to said allegations.
10.
That the
allegations of paragraph
10 of the Count
II of Complainant’s
Complaint recite language of a statute which speaks for itself and Respondent therefore
does
not need to respond to said allegations.
11.
That
Respondent has insufficient information or knowledge to respond to
the allegations contained
in paragraph
11
of Count II of Complainant’s
complaint and
neither admits nor denies same but demands strict proof thereof.
12.
That
Respondent denies each and every allegation contained in
paragraph
12 of Count
II of Complainant’s
Complaint.
13.
That
Respondent denies
each
and every allegation
contained
in
paragraph
13 of Count II of Complainant’s
Complaint.
4
Wherefore,
the Respondent,
Economy Plating, Inc. asks the
Illinois
Poflution
Control
Board to Dismiss the above captioned matter with prejudice and without
costs.
COUNT Ill
FAILURE TO
FILE ANNUAL REPORTS
1-9.
The Respondent
realleges and reaffirms
its answers for paragraphs
1
through 9 inclusive of Count
I of Complainant’s Complaint as
its answer to paragraphs I
through 9 inclusive of Count III of Complainant’s Complaint.
10.
That the
allegations of paragraph 10 of the Count Ill of Complainant’s
Complaint recite language of a statute which speaks for itself and
Respondent therefore
does
not need to respond to said allegations.
11.
That the allegations of paragraph
II
of the Count Ill of Complainant’s
Complaint recite language of a statute which speaks for itself and Respondent therefore
does not need to respond to said allegations.
12.
That
Respondent admits each and every allegation contained in
paragraph 12 of Count Ill of Complainant’s Complaint.
13.
That Respondent denies each and
every
allegation contained in
paragraph
13 of Count III of Complainant’s Complaint.
14.
That
Respondent denies each
and every allegation contained in
paragraph
14 of Count Ill of Complainant’s Complaint.
5
Wherefore, the Respondent,
Economy Plating, Inc. asks the Illinois
Pollution
Control
Board to Dismiss the above captioned matter with prejudice and without
costs.
COUNT IV
VIOLATION OF SPECIAL OPERATING PERMIT CONDITIONS
1-10.
The Respondent
realleges and
reaffirms
its answers for paragraphs
1
through 10 inclusive of Count I of Complainant’s Complaint as its answer to paragraphs
I through
10 inclusive of Count IV of Complainant’s Complaint.
11.
That Respondent admits each
and every allegation contained in
paragraph
11
of Count IV of Complainant’s Complaint.
12.
That the allegations of paragraph 12 of the Count
IV of Complainant’s
Complaint recite
language of a statute
which speaks for itself and Respondent therefore
does not need to respond to said allegations.
13.
That the allegations of paragraph 13 of the Count IV of Complainant’s
Complaint recite
language of a statute which speaks for itself and Respondent therefore
does not need to respond to said allegations.
14.
That the allegations of paragraph 14 ofthe Count IV of Complainant’s
Complaint recite
language of a statute which speaks for itself and Respondent therefore
does
not need to respond to said allegations.
15.
That the allegations of paragraph 15 ofthe Count IV of Complainant’s
Complaint recite
language of a statute which speaks for itself and Respondent therefore
does not need to respond to said
allegations.
6
16.
That the allegations of paragraph
16 of the
Count
IV of Complainant’s
Complaint recite language of a statute which speaks for itself and Respondent therefore
does not need to respond to said allegations.
17.
That the allegations of paragraph 17 of the Count
IV of Complainant’s
Complaint recite
language of a statute
which speaks for itself and Respondent therefore
does not need to respond to said allegations.
18.
That Respondent denies
each and every allegation contained in
paragraph 18 of Count IV of Complainant’s Complaint.
19.
That Respondent denies each and every allegation contained in
paragraph 19 of Count IV of Complainant’s Complaint.
20.
That Respondent denies each and every allegation contained in
paragraph 20 of Count IV of Complainant’s Complaint.
21.
That the allegations of paragraph 21
of the Count IV of Complainant’s
Complaint recite language of a statute which speaks for itself and Respondent therefore
does not need to respond to said allegations.
22.
That the allegations of paragraph 22 of the Count IV of Complainant’s
Complaint recite language of a statute which speaks for itselfand Respondent therefore
does not need to respond to said allegations.
23.
That Respondent denies each and every allegation contained
in
paragraph 23 of Count IV of Complainant’s Complaint.
24.
That Respondent denies each and every allegation contained in
paragraph 24 of Count IV of Complainant’s Complaint.
7
25.
That Respondent denies each
and every allegation contained
in
paragraph 25 of Count IV of Complainant’s Complaint.
26.
That Respondent denies each and every allegation
contained
in
paragraph 26 of Count IV of Complainant’s Complaint.
Wherefore, the
Respondent,
Economy Plating, Inc. asks the
Illinois Pollution
Control
Board to Dismiss the above captioned matter with prejudice and without
costs.
COUNT V
CERTIFICATION VIOLATION
1-13.
The
Respondent
realleges and
reaffirms
its answers for paragraphs I
through
13 inclusive of Count IV of Complainant’s Complaint as its answer to
paragraphs I through 13 inclusive of Count V of Complainant’s Complaint.
14.
That the allegations of paragraph 14 of the Count V of Complainant’s
Complaint recite language of a statute which speaks for itself and Respondent therefore
does not need to respond to said allegations.
15.
That the allegations of paragraph 15 of the Count V of Complainant’s
Complaint recite language of a statute which speaks for itself and Respondent therefore
does
not need to respond to said allegations.
16.
That Respondent admits each and every allegation contained in
paragraph
16 of Count V of Complainant’s Complaint.
17.
That Respondent denies each and every allegation contained
in
8
paragraph
17 of Count V of Complainant’s Complaint.
18.
That
Respondent denies each and every allegation contained in
paragraph
18 of Count V of Complainant’s Complaint.
19.
That Respondent denies each and every allegation contained
in
paragraph
19 of Count V ofComplainant’s Complaint.
20.
That Respondent denies each and
every allegation contained
in
paragraph 20
of Count V
of Complainant’s Complaint.
Wherefore, the Respondent, Economy Plating, Inc. asks the
Illinois Pollution
Control
Board to Dismiss the above captioned matter with prejudice and without costs.
Respectfully Submitted,
Economy Plating, Inc.
By:
~
Chri
pher T.
wotarski
One of its Attorneys
Christopher T. Nowotarski
Stone, Pogrund & Korey
Attorney for Economy
Plating, Inc.
221
North
LaSalle Street,
Suite 3200
Chicago, Illinois 60601
(312)
782-3636
Attorney’s
No. 90803
9

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