R!~
    CLERK’S OFflCE
    OCT
    2
    9
    2003
    PEOPLE OF THE STATE OF ILLINOIS,
    STATE OFfljINo~~
    PO!Iutgofl Control Board
    -vs-
    No.
    PCB
    03
    -
    73
    (Enforcement)
    RIVERDALE RECYCLING,
    INC.,
    an Illinois corporation,
    and
    TRI-STATE DISPOSAL,
    INC.,
    an Illinois corporation,
    Respondents.
    TO:
    Mr. Mark La Rose
    Mr.
    Brad Halloran
    Ms.
    Clarissa C.
    Grayson
    Hearing Officer
    Attorneys
    at Law
    Pollution Control Board
    734 North Wells Street
    100
    W. Randolph,
    Ste.
    11-500
    Chicago,
    IL
    60610
    Chicago,
    IL 60601
    Ms. Dorothy Gunn,
    Clerk,
    Illinois Pollution Control Board
    100 W.
    Randolph,
    Ste.
    11-500,
    Chicago,
    IL 60601
    NOTICE OF FILING
    PLEASE TAKE NOTICE that we have
    today, October
    29,
    2003 filed an
    original and nine copies of COMPLAINANT’S RESPONSE TO AFFIRMATIVE
    DEFENSES with Ms.
    Dorothy Gunn,
    Clerk of the Illinois Pollution
    Control Board,
    100
    W.
    Randolph,
    Suite 11-500,
    Chicago,
    IL.
    60601,
    a
    copy of which is attached herewith and served upon you.
    Respectfully submitted,
    PEOPLE OF THE STATE OF ILLINOIS
    LISA MADIGAN
    Attorney General
    of the
    State
    of Illinois
    BY:
    ~
    PAULA BECK~RWHEELER
    Assistant Attorney General
    Environmental Bureau
    188 W.
    Randolph ~
    20~’Flr.
    Chicago,
    IL 60601
    (312)
    814-1511
    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    Complainant,
    R~CWVF~D
    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    CLERK’SOFFICE
    PEOPLE OF THE STATE
    OF ILLINOIS,
    )
    OCT 2 9 2003
    Complainant,
    )
    STATE OF ILLINOIS
    Pollution
    Control Board
    -vs-
    )
    No.
    PCB
    03
    -
    73
    (Enforcement)
    RIVERDALE RECYCLING,
    INC.,
    an Illinois corporation,
    and
    TRI-STATE DISPOSAL,
    INC.,
    an Illinois corporation,
    Respondents.
    RESPONSE TO AFFIRMATIVE
    DEFENSE.S
    Complainant,
    PEOPLE OF THE STATE OF ILLINOIS,
    by LISA MADIGAN,
    Attorney General of the State of Illinois,
    hereby responds
    to the
    First Affirmative
    Defense and Second Affirmative Defense
    set forth in
    the Supplemental Answer of Respondents,
    RIVERDALE RECYCLING,
    INC.
    and
    TRI-STATE DISPOSAL,
    INC.,
    as follows:
    1ST
    GENERAL
    AFFIRMATIVE
    DEFENSE
    RESPONSE:
    Denied,
    and Complainant demands strict proof thereof.
    2~AFFIRMATIVE DEFENSE TO COUNT II
    RESPONSE:
    Denied,
    and Complainant demands strict proof thereof.
    Respectfully submitted,
    LISA MADIGAN
    Attorney General
    State of Illinois
    By:___________________
    PAULA
    BECKER
    WHEELER
    Assistant
    Attorney
    General
    Environmental Bureau
    188
    W.
    Randolph St.,
    20th
    Fl.
    Chicago,
    Illinois
    60601
    (312)
    814-1511
    1
    CERTIFICATE OF SERVICE
    I, PAULA BECKER WHEELER,
    an attorney,
    do certify that I caused to
    be served this 29th day Qf October,
    2003,
    the foregoing Complainant’s
    Response to Affirmative Defenses and Notice of Filing upon the persons
    listed on said Notice, by placing the same in the U.S. Mail, postage
    prepaid,
    at 188
    W.
    Randolph,
    Chicago,
    IL 60601.
    PAULA BECKER WHEELER

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