RE 6£
~
V
EL~
CLERK’S OTF’~
AUG 21. 2003
PEOPLE OF THE STATE OF ILLINOIS,
)
Pollution control Board
Complainant,
SKOKIE VALLEY ASPHALT, CO., INC.,
an Illinois corporation,
EJWINL. FREDERICK, JR.,
individually and as owner and
President of Skokie Valley Asphalt
Co., Inc., and
RICHARD J. FREDERICK,
individually and as owner and
Vice President of
Skokie Valley Asphalt Co., Inc.,
Respondents.
NOTICE OF FILING
TO: See Attached Service List
PLEASE TAKE NOTICE that on August 21, 2003, we filed with
the Illinois Pollution Control Board
“EXHIBIT A AND CORRECTION
TO COMPLAINANT’S SECOND MOTION TO COMPEL RESPONDENTS, SKOKIE
VALLEY ASPHALT, CO., INC.,EDWIN L. FREDERICK, JR. AND RICHARD J.
FREDERICK, TO RESPOND TO DISCOVERY REQUESTS”,
a true and correct
copy of which is attached and hereby served upon you.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS,
ex
rel. LISA MADIGAN,
Attorney General of the
State of Illinois,
BY:
________
JOEL J. S ERNSTEIN
Assistant Attorney General
Environmental Bureau
188 W. Randolph St., 20th Floor
Chicago, Illinois 60601
(312) 814-5282
THIS DOC1JNENT IS SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
v.
~ca‘ic,-~
BEFORE THE ILLINOIS POLLUTION CONTROL BOA~~ECEIVED
CLERK’S
OFFICE
PEOPLE OF THE STATE OF ILLINOIS,
)
AUG 21 2003
Complainant,
)
STATE OF IWNOIS
Pollution Control Board
v.
)
No. PCB 96-98
SKOKIE VALLEY ASPHALT, CO., INC.,
an Illinois corporation,
EDWIN L. FREDERICK, JR.,
individually and as owner and
President of Skokie Valley Asphalt
Co., Inc., and
RICHARD J. FREDERICK,
individually and as owner and
Vice President of
Skokie Valley Asphalt Co., Inc.,
Respondents.
EXHIBIT A AND CORRECTION TO
COMPLAINANT’S SECOND MOTION TO COMPEL
RESPONDENTS, SKOKIE VALLEY ASPHALT, CO., INC.,
EDWIN L. FREDERICK, JR. AND RICHARD J. FREDERICK,
TO RESPOND TO DISCOVERY REQUESTS
Complainant, PEOPLE OF THE STATE OF ILLINOIS,
by
LISA
MADIGAN, Attorney General of the State of Illinois, pursuant to a
request from Hearing Officer Carol Sudman, hereby submits Exhibit
A to its Second Motion to Compel Respondents SKOKIE VALLEY
ASPHALT, CO., INC., EDWIN L. FREDERICK, JR. AND RICHARD J.
FREDERICK to Respond to Discovery Requests (“Second Motion to
Compel”). Pursuant to Hearing Officer Sudman’s request, only one
(1) copy of Exhibit A will be filed with the Board’s Clerk’s
Office.
Exhibit A consists of all of the discovery requests that
1
Complainant served on Respondents on or about May 7, 2003. In
order to save paper, Complainant has omitted the instructions,
claims of privilege, and definitions sections from the discovery
requests served on the Fredericks since those instructions,
claims of privilege, and definitions are identical to those in
the discovery requests to Skokie Valley Asphalt Co., Inc.
Exhibit A also contains Respondents’ answers to Complainant’s
discovery requests.
Paragraph 20 of the second Motion to Compel currently reads
as follows:
20. No answers were provided to Complainant’s Second
Request for Production of Documents, Objects, and Tangible Things
on Respondent SVA. Complainant demands that SVA provide those
answers immediately.
The corrected Paragraph 20 should read as follows:
20. No answers were provided to Complainant’s First
Request for Admission of Facts on Respondent Edwin L. Frederick,
Jr. Complainant demands that SVA provide those answers
immediately.
2
PEOPLE OF THE STATE OF ILLINOIS,
ex rél.
LISA MADIGAN,
Attorney General of the
State of Illinois,
By:
MITCHELL L. CO~1EN
JOEL J. STERNSTEIN
Assistant Attorney General
Environmental Bureau
188 W. Randolph St.
-
20th Fl.
Chicago, IL 60601
(312) 814-5282/(312) .814-6986
3
SERVICE LIST
Mr. David O’Neill
Attorney at Law
5487 North Milwaukee
Chicago, Illinois 60630
Ms. Carol Sudman
Hearing Officer
Illinois Pollution Control Board Division
Illinois EPA
1021 N. Grand Ave E.
P0 Box 19276
Springfield, Illinois 62794-9276
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