RECEIVED
CLERK’S OFFICE
SEP
13
2004
STATE OF ILLINOIS
OFFICE
OF THE ATTORNEY GENERAL
Pollution Control
Board
STATE
OF ILLINOIS
Lisa Madigan
ATTORNEY
GENERAL
September 8,
2004
The Honorable
Dorothy Gunn
Illinois Pollution
Control
Board
James
R.
Thompson Center, Ste.
1 1-500
100 West
Randolph
Chicago,
Illinois 60601
Re:
People
v.
John Prior
PCB
No. 02-1 77
Dear Clerk Gunn:
Enclosed for filing please
find
the original
and
ten copies of a
NOTICE
OF
FILING
and
PEOPLE’S RESPONSE TO RESPONDENT’S MOTION TO STAY in regard to the above-captioned
matter.
Please file the originals
and
return
file-stamped
copies of the documents to our office
in
the enclosed
self-addressed, stamped
envelope.
Thank you for your cooperation and consideration.
Very truly yours,
Thomas
Davis,
Chief
Environmental Bureau
•
500
South
Second Street
Springfield,
Illinois
62706
(217)
782-9031
TD/pp
Enclosures
500
South Second
Street,
Springfield,
Illinois
62706
.(217)~782-l090
i’ll:
1217)
785-2771
•
l’~ax:
(217)
782-7046
100
West
Rsndolph
Sneer, (~liic~tgo,
Illinois
60601
•
(312)
814—31)0))
•
‘I’FY:
(312)
814—3374
•
FL~x:
(312)
814—3806
1001
F.~isi\lajn,
(~irbond~tlc,
Illinois
629(11
•
(618)
329—6401)
•
1”I’Y: (618)
529—6403
•
Fi~x:(618)
529—6416
BEFORE THE
ILLINOIS POLLUTION
CONTROL
BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
SEP
132004
Complainant,
Pt~I~~d
•
V.
)
PCB
NO.
02-177
)
(Enforcement)
JOHN
PRIOR,
dlbla
PRIOR
OIL COMPANY,
)
and
JAMES MEZO,
dlbla
MEZO OIL
)
COMPANY,
)
Respondents.
)
NOTICE OF FILING
To:
Robert
B.
Holtsclaw
Hodge Dwyer Zeman
3150 Roland
Avenue
P.O.
Box 5776
Springfield,
IL 62705-5776
PLEASE TAKE
NOTICE
that on this
date
I
mailed for filing, with the Clerk of the Pollution
Control
Board
of the State of Illinois,
PEOPLE’S RESPONSE TO
RESPONDENT’S
MOTION
TO STAY,
a copy
of which is attached
hereto and herewith
served
upon you.
Respectfully submitted,
PEOPLE OF THE
STATE OF ILLINOIS
LISA MADIGAN
Attorney General of the
State
of Illinois
MATTHEW
J.
DUNN, Chief
Environmental Enforcement/Asbestos
Litigation
Division
BY:_____________________
THOMAS
DAVIS,
Chief
Assistant Attorney General
Environmental Bureau
500 South
Second Street
Springfield,
Illinois
62706
217/782-9031
Dated:
September 8,
2004
CERTIFICATE OF SERVICE
I
hereby certify that
I did
on September 8,
2004, send
by
First Class
Mail,
with
postage
thereon fully prepaid,
by depositing
in the United
States
Post Office
Box a true
and
correct copy
of the following
instruments entitled
NOTICE OF FILING and
PEOPLE’S RESPONSE TO
RESPONDENT’S MOTION T STAY
To:
Robert
B.
Holtsclaw
Hodge Dwyer Zeman
3150
Roland Avenue
•
P.O.
Box 5776
Springfield,
IL 62705-5776
and
the original and ten copies by First
Class
Mail with
postage thereon fully
prepaid of the
same foregoing
instrument(s)
To:
Dorothy Gunn,
Clerk
Pollution
Control
Board
100 West
Randolph, Suite
11-500
Chicago,
Illinois 60601
A true
and correct copy was also
sent to:
Carol
Sudman
Hearing
Officer
Pollution
Control Board
1021
North
Grand Avenue East
Springfield,
Illinois 62794
THOMAS
DAVIS,
Chief
Assistant Attorney General
This filing
is submitted on
recycled paper.
BEFORE THE
ILLINOIS POLLUTION
CONTROL
BOARD
PEOPLE OF THE
STATE OF ILLINOIS,
)
.
,
SEP
132004
•
Complainant,
)
STATE
OF
ILUNOIS
Jtion
Control
Board
vs.
)
No.
02-177
)
(Enforcement)
)
JOHN
PRIOR,
)
)
Respondent.
PEOPLE’S
RESPONSE TO RESPONDENT’S
MOTION TO STAY
Complainant, PEOPLE
OF THE STATE
OF ILLINOIS,
by
Lisa
Madigan, Attorney
General of the State of Illinois, respectfully responds to the Respondent’s
Motion
to
Stay and
states as follows:
1.
The motion seeks
merely to stay the payment of civil penalties and
attorney’s
fees pending appeal.
Complainant does not object.
Respectfully submitted,
PEOPLE
OF THE STATE OF ILLINOIS,
LISA MAD IGAN
Attorney General
State
of Illinois
MATTHEW
J.
DUNN, Chief
Environmental Enforcement Division
BY_______________________
THOMAS DAVIS,
Chief
Environmental
Bureau
Assistant Attorney General
500 South
Second Street
Springfield,
Illinois 62706
217/782-9031
Dated:
September 8, 2004
