REcI~~
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APR
022004
OFF1C~’
THE ILLINOIS POLLUTION CONTROL BOARD
~Oltut~ori
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Contro’1WNJQI~Board
SALINE COUNTY LANDFILL, INC.,
)
)
PETITIONER,
)
)
v.
)
No. PCB 04-117
)
(PERMIT APPEAL)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
RESPONDENT.
)
MOTION TO FILE A CORRECTED BRIEF TO THE MARCH 22. 2004 BRIEF OF
PETITIONER, SALINE COUNTY LANDFILL. INC.
Saline County Landfill, Inc., by their attorneys, Lueders, Robertson & Konzen, moves to
correct typographical errors in the March 22, 2004 brief ofPetitioner Saline County Landfill, Inc.
Attached to this motion is the errata sheet and the corrected brief of petitioner, Saline. County
Landfill, Inc. None ofthe changes contained in the corrected brief are substantive, as reflected in
the errata sheet.
Saline Coun~~dfill.rIne,
Bnan Konzen
//
Leo Konzen
Lueders, Robertson & Konzen
P.O. Box 735
Granite City, IL 62040
(618)
876-8500
45455
REC~!~VED
CLEPK’S OFFICE
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THE ILLINOIS POLLUTION CONTROL BOARD
Pollution
Control Board
SALINE
COUNTY LANDFILL, INC.,
)
)
PETITIONER,
)
)
v.
)
No.
PCB 04-117
)
(PERMIT APPEAL)
ILLINOIS
ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
RESPONDENT.
)
ERRATA TO MARCH 22,2004 BRIEF OF PETITIONER,
SALINE COUNTYLANDFILL, INC.
COMES NOW, Saline County Landfill, Inc., by its attorneys,Lueders, Robertson & Konzen,
and identifies the following errata to the brief ofpetitioner, Saline County Landfill, Inc.:
1.
On the fourth page, in the quote at the bottom ofthe page, in the ninth line ofsaid
quote, the words “and” and “the” should be reversed.
2.
On the sixth page, in the first full paragraph, in the fourth line ofsaid paragraph, the
word “for” should be deleted.
3.
On the sixth page, in the first full paragraph, in the sixth line down, the comma
behind “October” should be moved behind “1999.”
4.
On the sixth page, in the third full paragraph, “415 ILCS 539.2(f)” should be deleted
and “415 ILCS
5/39.2(f)”
inserted in its place.
5.
On the tenth page, in the first full paragraph, in the third line down, the word
“spupra” should be deleted and the word “supra” inserted in its place.
6.
On the tenth page, in the second full paragraph, in the third line down, the word “the”
3hould be inserted in front ofthe word “Act.”
7.
On the twelfth page, in the second line from the bottom ofthe page, the word
“which” should be inserted after the word “upon.”
8.
On the fifteenthpage, in the fourth line down, the word “showed” should be deleted
and the word “should” inserted in its place.
9.
On the fifteenth page, in the ninth line down, the word “filled” should be deleted
and the word “filed” inserted in its place.
10.
On the eighteenth page, in paragraph two ofthe first quote, in the sixth line down,
the word “the” should be deleted.
45443
L
D
CLER’C
OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
A
~
.~ ~
L
SALINE COUNTY LANDFILL, INC.,
)
-.
STATh Or- ILL ~O!S
)
Pollution
Control Board
PETITIONER,
)
)
v.
)
No. PCB 04-117
)
(PERMIT APPEAL)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
RESPONDENT.
)
PROOF OF SERVICE
I, the undersigned, verif~’copies ofthe forgoing Motion to File a Corrected Briefand Errata’
to March 22, 2004 Brief were served by first class mailingupon the following persons on this 29th
day ofMarch, 2004, with first class postage fullyprepaid and the envelopes addressed to:
John Kim, Esq.
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
Carol Sudman, Esq.
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Ave. East
P0 Box 19274
Springfield, Illinois 62794-9274
Rod Wolf
Saline County State’s Attorney
10 E. Poplar
Harrisburg, Illinois 62946
Steve Hedinger
2601 S. Fifth Street
Springfield, Illinois 62703
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45521
Brian ~nzen
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