1. OKEICES OF JEFFREY M. SMITH
      1. LAW OFFI4
RE
CE
~V
JEi~
CLERTcS
OFFT(F
LAW OFFICES OF JEFFREY M.
SMITH
SEP
12
2003
19782
MACARTHUR
BOULEVARD,
SUITE
260
IRVINE,
CALIFORNIA 926
1
2
STATE
01-
ILLJNOIS
TELEPHONE:
(949) 8 6 3
-
1
8
7
7
PollutIon
Control Board
FAX:(949)724-8504
E-MAIL:
ieffrevmsmith@msn.com
OF COUNSEL TO:
-
SCEAFFER, LAX, McNAUGHTON
&
CHEN
September
12,
2003
Mara S. Georges
Corporation Counsel
City of Chicago Department ofLaw
30 N. LaSalle Street, Suite 900
Chicago, IL 60602
Re:
The City of Chicago v. Purex Industries, Inc.,
Ct
al.
Illinois
Pollution Control Board
Case
No.
PCB 04-29
Dear Ms.
Georges:
On September 8,
2003, my office received, via federal express, the enclosed Notice ofFiling
and Commencement ofEnforcement Proceeding, and Notice ofFiling (motion to consolidate) in the
captioned mafter.
We are returning these documents because your service list identifies my office as
the “authorized agent of
Purex
Industries, Inc.”; and, that the United States Corporation Company is
the “Registered agent ofPurex Industries, Inc.
Neither of the statements is correct; therefore, your
service is improper and defective.
Furthermore, your complaint
alleges that Purex Industries, Inc.’s (Purex) principal place of
business
is located at
535
E. Alondra Boulevard, Gardena, California 90248.
This also is
incorrect.
Purex doesnot ownthe propertylocatedat
535
E. Alondra Boulevard, Gardena, California, and neither
that property nor any other property is the “principal place ofbusiness” ofPurex, because Purex is
a
dissolved corporation and has no principal place ofbusiness.
In
February
1985,
Purex
began
its
complete
dissolution.
Since
Purex
was
a
Delaware
corporation, a Certificate of Dissolution was filed with the Delaware Secretary ofState on April
5,
2000, and Purex completed its dissolution on April 4, 2003.
Purex
no longerexists
-
it is a dead and
buried corporate entity.
PurexCrspO3
LAW
OKEICES OF JEFFREY M.
SMITH
Mara S.
Georges
Corporation Counsel
City of Chicago Department ofLaw
Re:
The City ofChicago
v. Purex
Industries, Inc., et
aL
Illinois Pollution ControlBoard Case No. PCB 04-29
September
12, 2003
Page -2-
Underpenalty ofperjury, and under the lawsofthe State ofCalifornia, I do affirmthat the facts
stated herein are true, and if called as a witness, could and would competently testify thereto.
JMS:sc
Enclosures
By
cc:
Office ofthe Clerk
Illinois Pollution Control Board
SMITH
Best
regards,
LAW OFFI4
PurexCrspO3

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