CLERK’S OFFiCE
    BEFORE
    THE ILLINOIS POLLUTION CONTROL BOARD
    FEB 022005
    PEOPLE
    OF THE STATE OF ILLINOIS,
    )
    by LISA MADIGAN, Attorney
    General of the State of Illinois,
    Complainant,
    -vs-
    )
    PCB No.
    04-207
    (Enforcement)
    EDWARD PRUIM,
    an individual, and
    ROBERT PRUIM, an individual,
    Respondents.
    NOTICE
    OF FILING
    PLEASE TAKE NOTICE that
    I have today, February
    2,
    2005,
    2004,
    filed with the Clerk of the Illinois Pollution Control
    Board,
    Complainant’s Response to Motion to Consolidate,
    a copy
    of which is attached and herewith served upon you.
    Respectfully Submitted,
    LISA MADIGAN
    )~tto~neyGen~ra1of the
    (S~~’eof Il/inois
    By:
    ~
    ./~
    (~/~
    t~
    ,~ristopher
    Grant
    (~sistantAttorney General
    Environmental Bureau
    188 West Randolph,
    #2001
    Chicago,
    IL 60601
    312-814-5388
    R~C~ivED
    CLERK’S OFRCE
    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    FEB
    02
    2005
    PEOPLE OF THE STATE OF ILLINOIS,
    by LISA MADIGAN, Attorney
    )
    STATE OF ftLINOIS
    General
    of the State of Illinois,
    )
    Pot~0~~0r00
    Complainant,
    -vs-
    )
    PCB No. 04-207
    (Enforcement)
    EDWARD PRUIM,
    an individual,
    and
    ROBERT PRUIM,
    an individual,
    Respondents.
    RESPONSE TO MOTION TO CONSOLIDATE
    Now comes Complainant,
    PEOPLE OF THE STATE OF ILLINOIS, by
    LISA MADIGAN, Attorney General of the State of Illinois,
    and in
    response to Respondents’ Motion to Consolidate,
    states as
    follows:
    1.
    Respondents seek consolidation of this matter with
    People
    v.
    Community Landfill Company,
    PCB 97-193.
    Complainant
    does not object to this motion because
    it believes that
    consolidation would avoid duplication of both the parties’ and
    Board resources,
    and will aid in the complete determination of
    the claims in both cases.
    2.
    Complainant believes that discovery of facts relating
    to both matters is complete
    or
    nearly complete,
    and that no
    undue delay will result from consolidation.
    3.
    Complainant does not believe that prejudice to any
    party will result from consolidation.
    1
    WHEREFORE,
    Complainant,
    PEOPLE OF THE STATE OF ILLINOIS,
    respectfully requests that this Court grant Respondents’ Motion
    to Consolidate,
    and order such other relief the Board deems
    appropriate and just.
    RESPECTFULLY SUBMITTED,
    BY:
    4
    A
    ~RYSTOPHE~
    GRJ~NT
    ~vironmental
    Bureau
    k~sistantAttorney General
    188 West Randolph Street,
    20th
    Floor
    Chicago,
    IL
    60601
    (312)
    814-5388
    2
    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    PEOPLE OF THE STATE OF ILLINOIS,
    by LISA MADIGAN, Attorney
    General of the State of Illinois,
    Complainant,
    -vs-
    )
    PCB No. 04-207
    (Enforcement)
    EDWARD PRUIM,
    an individual,
    and
    ROBERT PRUIM,
    an individual,
    Respondents.
    CERTIFICATE
    OF SERVICE
    I,
    CHRISTOPHER
    GRANT,
    an attorney,
    do certify that
    I caused
    to be served this 2d day of February,
    2005,
    Complainant’s
    Response to Motion to Consolidate and Notice of Filing,
    upon the
    persons listed below by placing same in an envelope bearing
    sufficient postage with the United States Postal Service located
    at 100 W. Randolph,
    Chicago.
    I
    •
    2~
    CHRISTOPHER GRANT
    SERVICE LIST:
    Mr. Mark Larose
    Ms. Clarissa Grayson
    Larose
    & Bosco,
    Ltd.
    200 N.
    La Salle Street,
    #2810
    Chicago,
    IL
    60601
    Mr. Bradley
    P.
    Halloran
    Hearing Officer
    Illinois Pollution Control Board
    100
    W.
    Randolph
    Chicago,
    Illinois
    60601
    via
    hand
    delivery

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