EC.~j’~j~~

BEFORE THE ILLINOIS POLLUTION CONTROL

BOARfl.E~’~

(~rv~

PEOPLE OF THE STATE OF ILLINOIS~

)

~

1

~

2003

)

SlATE

OF ILLINOIS

Complamant,

)

Pollution

Control

Board

)

v.

)

PCB 97-2

)

(Enforcement)

JERSEY SANITATION CORPORATION,

)

an Illinois

corporation,

)

)

Respondent.

)

NOTICE OF FILING

AND

PROOF OF SERVICE

The

undersigned certifies

that

an

original

and

nine

copies of Respondent’s Notice

of

Hearing--Notice to

Appear and Produce for Richard Johnson was served

upon the Clerk of the

Illinois Pollution Control Board, and

one copy was served upon the following party of record and

the Hearing Officer in this cause by enclosing same in envelopes addressed to:

Dorothy Gunn, Clerk

Carol Sudman

Illinois Pollution Control Board

Hearing Officer

James R. Thompson Center

Illinois Pollution Control Board

100 W. Randolph St., Suite 11-500

600

South Second Street, Ste.

402

Chicago, IL

60601

Springfield, IL

62704

Jane McBride

Office of the Attorney General

Environmental Bureau

500

S. Second St.

Springfield, IL 62706

with

postage fully

prepaid, and

by

depositing

said

envelopes before 5:30

p.m.

in

a U.S.

Post

Office Mail Box in Springfield,

Illinois on the~~ay

of September, 2003.

/

SJ~phen

F.’H dinger/

HEDINGER LAW OFFICE

2601 South Fifth Street

Springfield, IL 62703

(217) 523-2753 phone

(217) 523-4366 fax

This Pleading is being submitted on recycledpaper.

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOAR1~

E C E ~V ED

PEOPLE OF THE STATE OF ILLINOIS,

)

CLt~RR’SOFFICE

)

S~P

17

2003

Complainant,

)

STATE OF ILLINOIS

v.

)

PCB

97-2

Pollution

Control Board

)

(Enforcement)

JERSEY SANITATION CORPORATION,

)

an Illinois corporation,

)

)

Respondent.

)

NOTICE OF HEARING--NOTICE TO

APPEAR AND

PRODUCE

TO:

Richard Johnson

do His Attorney

Jane McBride, Assistant Attorney General

Attorney General’s Office

Environmental Bureau

500

S. Second St.

Springfield, IL 62701

YOU AND EACH OF YOU WILL HEREBY TAKE NOTICE that on September 23,

2003, beginning at

10:00 a.m., at the Jerseyville City Council Chambers,

115 E. Prairie,

Jerseyville, Illinois, Respondent, JERSEY SANITATION CORPORATION, by Stephen F.

Hedinger, its attorney, will appear before Carol Sudman, hearing officer, at the above time and

date, for hearing, at which time and place you must appear and produce the following certain

described documents, pursuant to Supreme Court Rule 237(b) and

35 Ill. Adm. Code 101.100(b).

YOU ARE HEREBY DIRECTED

TO PRODUCE, at the same time and place and for

purposes of inspection, copying, and questioning, the following documents:

1.

Any and all documents including, but not limited

to notes, correspondence,

memoranda, telephone conversation logs or slips, and inspection reports relating to or regarding

Jersey Sanitation Landfill’s inspections and/or the violations alleged by Complainant.

---

2.

Any and all documents including, but not limited to notes, correspondence,

memoranda, telephone conversation logs or slips, permits, and permit applications relating to or

regarding Jersey Sanitation Landfill’s

site history and/or permit background.

3.

Any and

all documents including, but not limited to, notes, correspondence,

memoranda, and

telephone conversation logs or slips relating to or regarding Jersey Sanitation

Landfill and any and all conversations with Respondent’s employees and agents.

Respectfully submitted,

Jersey Sanitation Corporation,

Respondent,

By its attorney,

HEDIN~

Hedinger Law Office

2601 S. Fifth St.

Springfield,

IL 62703

(217) 523-2753 phone

(217) 523-4366 fax

2