THIS FILING PRINTED ON RECYCLED PAPER
ILLINOIS POLLUTION CONTROL BOARD
VILLAGE OF LAKE BARRINGTON, )
CUBA TOWNSHIP, PRAIRIE RIVERS )
NETWORK, SIERRA CLUB, BETH )
WENTZEL and CYNTHIA SKRUKRUD, )
)
Petitioners, )
)
v. ) PCB 05-55
) (Third-Party NPDES Permit Appeal
ILLINOIS ENVIRONMENTAL ) Water)
PROTECTION AGENCY and )
VILLAGE OF WAUCONDA, )
)
Respondents. )
__________________________________ )
)
SLOCUM DRAINAGE DISTRICT OF )
LAKE COUNTY, ILLINOIS )
)
Petitioner, )
)
v. ) PCB 05-58
) (Third-Party NPDES Permit Appeal
ILLINOIS ENVIRONMENTAL ) Water)
PROTECTION AGENCY and )
VILLAGE OF WAUCONDA, )
)
Respondents. )
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 7, 2005
THIS FILING PRINTED ON RECYCLED PAPER
AL PHILLIPS, VERN MEYER, GAYLE )
DEMARCO, GABRIELLE MEYER, LISA )
O’DELL, JOAN LESLIE, MICHAEL )
DAVEY, NANCY DOBNER, MIKE )
POLITO, WILLIAMS PARK )
IMPROVEMENT ASSOCIATION, )
MAT SCHLUETER, MYLITH PARK LOT )
OWNERS ASSOCIATION, DONALD )
KREBS, DON BERKSHIRE, JUDY )
BRUMME, TWIN POND HOMEOWNERS)
ASSOCIATION, JULIA TUDOR and )
CHRISTINE DEVINEY. )
)
Petitioners, )
) PCB 05-59
v. ) (Third-Party NPDES Permit Appeal
) Water)
ILLINOIS ENVIRONMENTAL )
PROTECTION AGENCY and )
VILLAGE OF WAUCONDA, )
)
Respondent. )
NOTICE OF FILING
Dorothy Gunn, Clerk Bradley P. Halloran
Illinois Pollution Control Board
Illinois Pollution Control Board
James R. Thompson Center, Suite 11-500 James R. Thompson Center, Suite 11-500
100 West Randolph Street
100 West Randolph Street
Chicago, Illinois 60601 Chicago, Illinois 60601
PLEASE TAKE NOTICE that I have this 7
th
day of March, 2005 electronically filed
with the Office of the Clerk of the Pollution Control Board the Resident Group RESPONSE TO
MOTION OF VILLAGE OF WAUCONDA TO DISMISS AND/OR MOTION FOR
SUMMARY JUDGMENT, a copy of which is herewith served upon you.
______________________
Jay J. Glenn
Attorney for Resident Group
Jay J. Glenn, Attorney at Law
2275 Half Day Road, Suite 350
Bannockburn, Illinois 60015
(847) 526-9202
(847) 526-9207 Fax
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 7, 2005
THIS FILING PRINTED ON RECYCLED PAPER
STATE OF ILLINOIS )
) ss.
COUNTY OF LAKE )
Jay J. Glenn, an attorney, hereby certifies that a copy of the foregoing Notice of
Filing, Certificate of Service and RESPONSE TO MOTION OF VILLAGE OF
WAUCONDA TO DISMISS AND/OR MOTION FOR SUMMARY JUDGMENT, were
served on the persons listed below by electronic transfer on March 7, 2005 and were
further served on the persons listed below by overnight mail on March 7, 2005.
Percy L. Angelo
Attorney at Law
Mayer, Brown, Rowe & Maw, L.L.P.
190 S. LaSalle Street
Chicago, Illinois 60603
William D. Seith
Attorney at Law
Total Environmental Solutions, P.C.
631 E. Butterfield Road, Suite 314
Lombard, Illinois 60148
Albert Ettinger
Environmental Law and Policy Center
35 East Wacker Drive, Suite 1300
Chicago, Illinois 60601
Sanjay K. Sofat, Asst. Counsel
James Allen Day
Illinois Environmental Protection Agency
1021 North Grand Avenue, East
P.O. Box 19276
Springfield, Illinois 62794-9276
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 7, 2005
THIS FILING PRINTED ON RECYCLED PAPER
ILLINOIS POLLUTION CONTROL BOARD
VILLAGE OF LAKE BARRINGTON, )
CUBA TOWNSHIP, PRAIRIE RIVERS )
NETWORK, SIERRA CLUB, BETH )
WENTZEL and CYNTHIA SKRUKRUD, )
)
Petitioners, )
)
v. ) PCB 05-55
) (Third-Party NPDES Permit Appeal
ILLINOIS ENVIRONMENTAL ) Water)
PROTECTION AGENCY and )
VILLAGE OF WAUCONDA, )
)
Respondents. )
__________________________________ )
)
SLOCUM DRAINAGE DISTRICT OF )
LAKE COUNTY, ILLINOIS )
)
Petitioner, )
)
v. ) PCB 05-58
) (Third-Party NPDES Permit Appeal
ILLINOIS ENVIRONMENTAL ) Water)
PROTECTION AGENCY and )
VILLAGE OF WAUCONDA, )
)
Respondents. )
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 7, 2005
THIS FILING PRINTED ON RECYCLED PAPER
AL PHILLIPS, VERN MEYER, GAYLE )
DEMARCO, GABRIELLE MEYER, LISA )
O’DELL, JOAN LESLIE, MICHAEL )
DAVEY, NANCY DOBNER, MIKE )
POLITO, WILLIAMS PARK )
IMPROVEMENT ASSOCIATION, )
MAT SCHLUETER, MYLITH PARK LOT )
OWNERS ASSOCIATION, DONALD )
KREBS, DON BERKSHIRE, JUDY )
BRUMME, TWIN POND HOMEOWNERS)
ASSOCIATION, JULIA TUDOR and )
CHRISTINE DEVINEY. )
)
Petitioners, )
) PCB 05-59
vi. ) (Third-Party NPDES Permit Appeal
) Water)
ILLINOIS ENVIRONMENTAL )
PROTECTION AGENCY and )
VILLAGE OF WAUCONDA, )
)
Respondent. )
RESPONSE TO MOTION OF VILLAGE OF WAUCONDA
TO DISMISS AND/OR MOTION FOR SUMMARY
JUDGMENT
Now Comes the Resident Group, by and through their attorney JAY J. GLENN,
and for their RESPONSE TO MOTION OF VILLAGE OF WAUCONDA TO DISMISS
AND/OR MOTION FOR SUMMARY JUDGMENT, states as follows:
1. That the Resident Group has filed signed original pleadings with the
Illinois Pollution Control Board, except one pleading which was filed electronically.
2. That the staff of the Illinois Pollution Control Board spent one entire
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 7, 2005
THIS FILING PRINTED ON RECYCLED PAPER
afternoon working on the electronic certification necessary to file electronically.
3. That the electronic filing was received by the Illinois Pollution Control
Board without objection.
WHEREFORE the Resident Group respectfully requests that the Board deny the
Motion of the Village of Wauconda.
Respectfully Submitted,
_________________________
Jay J. Glenn
Jay J. Glenn
Attorney at Law
2275 Half Day Road
Suite 350
Bannockburn, Illinois 60015
(847) 526-9202
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 7, 2005