BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    LERK’S
    OFFICE
    NOV
    2 6
    2003
    PEOPLE
    OF THE STATE OF ILLINOIS
    )
    ex
    rel. GARY W. PACK,
    )
    p
    STATE
    OF
    ILLINOIS
    McFlenry County State’s Attorney,
    )
    0
    L~tIonCOntrol
    Board
    )
    Complainant,
    )
    Vs.
    )
    PCB01-43
    )
    (RCRA Enforcement)
    MICHAEL STRINGINI,
    )
    )
    Respondent.
    )
    AMENDED NOTICE OF FILING
    TO:
    SEE ATTACHED
    SERVICE LIST
    On the date indicated below, the Plaintiff mailed its
    MOTION FOR
    ORDER TO PRODUCE AT
    HEARING PURSUANT TO PCB
    101.614,, a copy ofsame being attached hereto and served upon
    you.
    COMPLAINANT
    STIPULATES
    THAT
    RESPONDENT
    MAY
    RESPONSE
    TO
    THIS
    MOTION BY DECEMBER
    8.
    2003
    WITHOUT
    THE
    NEED FOR ADDITIONAL ORDERS BY
    THE
    HEARING
    OFFICER BASED
    -ON
    COMPL’AIN~T’SORIGINAL NOTICE ~
    MO-TIQN BEING SENT
    TO THE WRONG ADDRESS.
    David
    N.
    Stone,
    Assistant
    State’s
    Attorney,
    Gary
    W.
    Pack,
    Mdllenry
    County
    State’s
    Attorney
    CERTIFICATE OF SERVICE
    I, David N. Stone, an Assistant State’s Attorney in this case, do certify that I caused to be
    mailed this
    24TH
    day ofNovember, 2003, the foregoingNOTICE OF FILING upon the persons
    listed on the attached service list by certified mail in an envelope bearing sufficient postage with
    the United States Postal Service located at 1050 Country Club Road, Woodstock,
    Illinois 60098.
    Davi~N.Stone
    SERVICE LIST
    Case No.
    PCB 01-43
    NAME:
    INTEREST:
    POLLUTION CONTROLBOARD CLERK
    ORIGINAL
    PLUS
    FOUR
    COPIES
    JAMES R THOMPSON CENTER STE
    11-500
    100 WRANDOLPH STREET
    CHICAGO IL 60601
    MR
    MICHAEL STRINGINE
    Defendant
    1108
    WESTOVER LANE APT 2A
    SCHAUMBURG IL 60193
    RAUL.JAGI~ELLO
    Icon
    record
    Attorney
    for
    4LLINOIS EPA
    •.
    ..
    .
    ,,
    -
    ,
    ,•
    .
    ..
    9511WEST HARRISON ST
    DESPLAINES IL 60016
    Gary
    W.
    Pack,
    McHenry
    County
    State’s
    Attorney
    David
    N.
    Stone,
    Assistant
    State’s
    Attorney
    McHenry
    County
    Government
    Center
    2200
    N.
    Seminary
    Ave.
    Woodstock,
    IL.
    60098
    815
    334
    4159
    Atty
    No.
    02744309
    O~\wpSEcuRE\- STONE\L2590
    STRINGINI\PLEAD\NOT FILING MOT PROD AMENDED 112403
    .doc
    2
    BEFORE
    THE ILLINOIS POLLUTION CONTROL BOARDR~C~
    ~
    CLERR’S OFFICE
    PEOPLE
    OF THE STATE
    OF ILLINOIS
    )
    ,
    NO
    V
    2
    6
    2003
    ~e1.
    GARY W. PACK,
    )
    McHenry County State’s Attorney,
    )
    STATE OF
    ILLINOIS
    ollutIon
    Con troj Board
    Complainant,
    )
    vs.
    )
    PCBO1-43
    )
    (RCRA
    Enforcement)
    MICHAEL STR1NGINI,
    )
    )
    Respondent.
    )
    MOTION FOR ORDER TO PRODUCE AT
    HEARING
    PURSUANT TO PCB 101.614
    Now comes the Complainant
    and
    moves the
    Hearing Officer pursuant to PCB
    101.614 to
    order theDefendant, Michael
    Stringini to produce the following materials at the hearing on civil
    penalty:
    a. All records. ofreceipts of money from Sloan Valve Company during the calendar years
    1980 through 1984 for Defendant’s receiving foundry sand from Sloan Valve that was delivered
    to the Zimmerman Property in Union,
    Illinois.
    b.
    Defendant’s individual state and federal income tax
    returns for
    the calendar years
    1980
    through
    1984 and the calendar years 2001
    and 2002.
    .
    ..
    c. A current
    financial statement listing Defendant’s
    current
    assets
    and liabilities.
    Thisinformation is relevant to thematter under considerationbeing the
    amount ofcivil
    penalty that should be assessed and is information that the Pollution ControlBoard in its
    1NTERI1IVI OPINION AND ORDER dated October 16, 2003
    specifically directed the parties to
    address at the
    hearing on the
    penalty phase ofthe proceeding.
    This
    information was not specifically requested during the discovery and discovery in
    this case is ëlosed. The Complainant would not normally be interested in providing this
    information since it tends
    to go, in large
    part, to
    mitigation. Since the Defendant is pro se, he
    shouldbe ordered to provide
    this information so that the evidence adduced at the hearing will be
    inclusive ofwhat the
    Boards
    INTERIM ORDER
    deemed necessaryto impose
    a
    civil penalty.
    Respectfully submitted,
    DATE:
    November
    5,
    2003
    GaryW. Pack, McHenry County State’s Attorney
    David
    N.
    Stone, Assistant State’s Attorney
    McHenry County Government
    Center
    2200N. SeminaryAve.
    Woodstock, IL. 60098
    8153344159
    AttyNo. 02744309
    GARYW.PACK
    State’s Attorney
    By:
    Assistant State’s Attorney
    o \wpsEctiRE\- STONE\L2590
    STRINGINI\PLEAD\NOT ORDER TO PRODUCE 110503 .doc
    2

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