BEFORE THE ILLINOIS POLLUTION CONTROL
BO~CE!VED
CLERK’S OFFICE
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
AUG13
2003
Complainant,
STATE OF
ILLINOIS
v.
)
PCB
97
-
9
PollutiOn
Control
Board
(Enforcement
-
Land)
C
&
S
RECYCLING,
INC.,
an
Illinois
corporation,
FLOOD
BROTHERS
DISPOSAL COMPANY,
INC.,
an
Illinois Corporation,
WILLIAM
FLOOD,
Individually,
and as
treasurer of C &
S Recycling,
and
BRIAN
FLOOD,
Individually,
and as president of.C
&
S
Recycling,
Respondents.
NOTICE OF FILING
TO:
See
Attached
Service
List
PLEASE
TAKE
NOTICE
that
today
I
have
filed
with
the
Pollution Control Board the following Motion to Dismiss William
Flood and Brian Flood and Certificate of Service on behalf of the
People of the State of Illinois,
a copy of which is attached and
hereby served upon you.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA
MADIGAN
Attorney General
State of 1111
BY:
~JO~
-.
JOEL J.
STERNSTEIN
Assistant Attorney General
Environmental Bureau
188 W. Randolph St.,
20th Floor
Chicago,
Illinois
60601
(312)
814-6986
DATE: August
13,
2003
THIS FILING IS SUBMITTED ON RECYCLED PAPER
SERVICE LIST
Mr. Brad Halloran,
Esq.
Hearing
Officer
Illinois
Pollution
Control
Board
James
R.
Thompson
Center
100 W. Randolph Street,
Suite 11-500
Chicago,
IL 60601
Mr. Peter Orlinsky,
Esq..
Illinois
Environmental
Protection
Agency
9511
Har~ison
Street
Des Plaines,
IL
60016
Mr. Harvey Sheldon,
Esq.
Hinshaw
&
Culbertson
222
N.
LaSalle
Street,
Suite
300
Chicago,
IL 60601-1801
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVED
PEOPLE OF THE STATE OF ILLINOIS,
)
CLERK’S OFFICE
Complainant,
)
AUG
132003
V.
)
PCB
97
-
9
STATE
OF ILLINOIS
(Enforcement
PoIti~i~rontroI
Board
C
&
S
RECYCLING,
INC.,
an
Illinois
corporation,
FLOOD BROTHERS
DISPOSAL COMPANY,
INC.,
an
Illinois Corporation,
WILLIAM
FLOOD,
Individually,
and as
treasurer of C & S Recycling,
and BRIAN FLOOD,
Individually,
and as president of C & S
Recycling,
Respondents.
MOTION TO DISMISS WILLIAM FLOOD AND
BRIAN FLOOD
Complainant,
PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General
of the State of Illinois,
hereby
requests that the Illinois Pollution Control Board
(“Board”)
dismiss William Flood and Brian Flood as Respondents
in this
matter only if William Flood and Brian Flood are dismissed
without prejudice and only if the Board approves of the
Stipulation and Proposal for Settlement in this matter filed on
July 30,
2003
(“Settlement”)
.
In support of this motion,
Complainant states as follows:
1.
The Settlement
in this matter will not be affected by
the dismissal
of William Flood and Brian Flood without prejudice.
2.
The parties in this matter have both agreed to the
dismissal of William Flood and Brian Flood without prejudice.
WHEREFORE, Complainant,
PEOPLE OF THE STATE OF ILLINOIS,
hereby requests that the Board grant this motion to dismiss
William Flood and Brian Flood as Respondents in this matter only
if William Flood and Brian Flood are dismissed without prejudice
and only if the Board approves the Settlement.
Respectfully submitted,
PEOPLE.
OF THE STATE OF ILLINOIS
LISA
MADIGAN
Attorney
General
State
of
Ill’nois
BY:
__________
JOEL J.
STERNSTEIN
Assistant Attorney General
Environmental
Bureau
188
W.
Randolph
St.,
20th
Floor
Chicago,
Illinois
60601
(312)
814-6986
DATE:
August
13, 2003
CERTIFICATE OF SERVICE
I,
JOEL J.
STERNSTEIN,
an Assistant Attorney General,
certify that on the ~
day of August,
2003,
I caused to be
served by First Class Mail the foregoing Motion to Dismiss
William Flood and Brian Flood and Notice of Filing
to the parties
named on the attached Service list, by depositing the same in
postage prepaid envelopes with the United States Postal Service
located at 100 West Randolph Street,
Chicago,
Illinois 60601.
Jo’c2~
~
JOEL J. ,STERNSTEIN
H:\COtflmQIl\EflViroflmefltal\JOEL\CaSe Documents\C&S
-
Flood\motion dismiss Brian Williarn.wpd