1. CERTIFICATE OF SERVICE
In re: Prairie-Materials Sales,
Inc.’s
Petition for an Adjusted Standard
from 35
Ill. Adm. Code Parts
811
and 814.
RECEIVED.
CLERK’S OFFICE
NOTICE OF FILNG
TO:
Michael
F. Dolan
Jane K. Murphy
Jones, Day, Reavis & Pogue
77 West Wacker Drive
Chicago, IL 60601-1692
Paul Jagiello
Associate Counsel
Illindis EPA
9511
West Harrison
Des Plaines, IL 60016
Bradley P. Halloran
Hearing Officer
Pollution Control Board
James R. Thompson Center
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
PLEASE TAKE NOTICE that I have today filed the Illinois Attorney General’s Office’s
Motion for Leave to File an Amicus Curiae Briefand to be Included on Service List with the
Office of the Clerk of the Illinois Pollution Control Board, a true and correct copy of which is
herewith served upon you.
PEOPLE OF THE
STATE OF ILLINOIS,
by LISA MADIGAN, Attorney General
ofthe State of Illinois
BY:
7~74~V
B9z~ard/Murphy/r.,Asst. Chief
~KssistantAttorne~
General
/Environmental Bureau/North
188 West Randolph Street, Suite 2001
Chicago, Illinois
60601
Tel:
(312)814-3908
Fax:
(312)814-2347
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
)
)
)
No.: AS 01-10
)
)
MAYO32OO4~
STATE OF ILUNCIS
PoIIut~on
Control
Board
This Filing is Printed on Recycled Paper
CERTIFICATE OF SERVICE
I, the undersigned, certify that I caused to be served the attached Illinois Attorney
General’s Office’s Motion for Leave to File an Amicus
Curiae Briefand to be Included on
Service List by First Class Mail, postage prepaid upon each ofthe persons listed on the Notice of
Filing on May 3, 2004.
BY:
________
7~ard/MurPh~4
I, the undersigned, also
certify that I caused to be served the Illinois Attorney General’s
Office’s Motion for Leave to File an Amicus
Curiae Brief and to be Included on Service List
plus nine (9) copies ofthe same by hand-delivery upon the following person on May 3, 2004:
Pollution Control Board, Attention: Clerk
James R.
Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois
60601
BY:
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Inre: Prairie-Materials Sales, Inc.’s
)
MAY 032004
Petition for an Adjusted Standard
)
AT
from 35 Ill.
Adm. Code Parts 811
)
No.:
AS
0 1-10
PoIiuflc~Control
Boa~cJ
and8l4.
)
)
Illinois Attorney General’s Office’s Motion for Leave to
File
an Amicus Curiae Briefand to be Included on Service List
NOW COMES Movant, ILLINOIS ATTORNEY GENERAL’S OFFICE, and pursuant to
35 Ill.
Adrn. Code
Section 101.110(c), moves the Illinois Pollution Control Board (“Board”)
to
grant it leave to file an
amicus curiae brief in connection with these adjusted standard
proceedings and to be included on the proceedings’ service list.
In support ofthis
Motion,
Movant
states as follows:
The Illinois Attorney General’s Office is an interested person in connection with these
proceedings by virtue ofthe fact that it is prosecuting a civil enforcement action against
petitioner in Lee County Circuit Court, styled People v. Dixon-Marquette Cement,
et al.,
case no.
00 CH 68. That civil
enforcement action concerns the same site that
is the subject ofthese
proceedings.
The relief requested by petitioner in these proceedings may affect the relief the
State
is seeking in that circuit court action.
By virtue ofthose facts, the Illinois Attorney
General’s Office has a vested interest in the outcome ofthese proceedings and
is thus an
interestedperson as that term is used in
35111. Adm. Code 101.110(c).
WHEREFORE, Movant, Illinois Attorney General’s Office, respectfully requests that the
Board issue an order granting it leave to file an amicus brief in the adjusted standard proceedings
within 90 days and directing the hearing officer to include Assistant Attorney General Bernard J.
Murphy, Jr. of the Illinois Attorney General’s Office’s
Environmental Bureau North,
188 W.
Randolph Street, 20th Floor, Chicago, Illinois
60601,
on the Service List for any and all
orders,
notices or other pleadings that are hereafter filed in this matter or issued by the Board to the
parties herein.
Respectfully submitted,
PEOPLE
OF THE STATE OF ILLINOIS,
ex rel.
LISA MADIGAN, Attorney
General ofthe State ofIllinois
MATTHEW J. DUNN, Chief
Environmental Enforcement! Asbestos
Litigation Division
ROSEMARIE CAZEAU, Chief
Environmental Bureau
By:
__________________________
B~nar~,4~’
MurpK4r., Assistant Chief
)~ssistantAttoi$y General
/
Environmental Bureau
188 West Randolph Street, 20th Floor
Chicago, IL 60601
(312) 814-3908
DATE: May 3, 2004
l:\MyFiles\WPDOCS\DiXOfl-Marq\bdmOtiOflamiCUSbrfl .wpd

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