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