BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
RED ROOSTER CORPORATION
)
RkFV
(f/k/a CLARK RETAIL ENTERPRISES,
)
INC.) (CLARK OIL #2086),
)
JUN 272005
Petitioner,
)
PCB No.
05-125
)
PCBNo.05-126
V.
)
(UST Appeal)
)
(Consolidated)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Respondent.
)
NOTICE TO APPEAR
AND
PRODUCE
TO:
John Kim
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 N. Grand Ave. East
P.O. Box 19276
Springfield, IL 62794-9276
YOU AND EACH OF YOU WILL HEREBY TAKE NOTICE that on June 29,
2005,
beginning at 10:00 a.m., at the Illinois Pollution Control Board hearing Room, Springfield,
Illinois, Petitioner, RED ROOSTER CORPORATION, by Stephen F. Hedinger, its attorney, will
appear before Carol Webb, hearing officer, at the above time and date, for hearing, at which time
‘and place the following agents and employees of Respondent must appear for testimony and
must produce the following certain described documents, pursuant to Supreme Court Rule
237(b) and
35
Ill. Adm. Code 101.100(b).
1.
Douglas E. Oakley
Manager, LUST Claims Unit
Planning & Reporting Section
Bureau of Land
2.
Jason Donnelly
Project Manager, LUST Section
Land Pollution Control
Bureau of Land
3.
Harry A. Chappel
Unit Manager, LUST Claims Unit, LUST Section
Division of Remediation Management
Bureau of Land
4.
Diana Gobelman
LUST Claims Unit
Planning & Reporting Section
Bureau ofLand
5.
Bill Richards
LUST Claims Unit
Planning and Reporting Section
Bureau of Land
YOU ARE HEREBY DIRECTED TO PRODUCE, at the same time and place and for
purposes of inspection, copying, and questioning, the following documents:
1.
Any documents not already in the Record in this case which support, explain or
justify the final decision expressed in your letter dated December 6, 2004.
2.
Any documents not already in the Record in this case which support, explain or
justify the final decision expressed in your letter dated December 30, 2004.
3.
The originals of all documents included in the Record.
4.
Any documents not already in the Record in this case which support, explain or
justify the determination to disqualify payment as to items marked in handwriting “tech cut” on
the June
25,
2004 letter from Craig S. Gocker to Doug Oakley, which is included in the Record
in this case.
5.
Any and all documents relating to the reimbursement decision reflected in the
December 6, 2004 letter, including but not limited to notes, correspondence, memoranda, email
messages, etc.
6.
Any and all documents relating to the reimbursement decision reflected in the
December 30, 2004 letter, including but not limited to notes, correspondence, memoranda, email
messages, etc.
Respectfully submitted,
RED ROOSTER CORPORATION f/k/a
CLARK RETAIL ENTERPRISES, INC.
Petitioner,
Byits
By:
Hedinger Law Office
2601 South Fifth Street
Springfield, IL 62703
tel:
(217)523-2753
fax:
(217)523-4366
hedinger1aw~cityscape.net
BEFORE THE POLLUTION CONTROL BOARD
JUN 272005
OF THE STATE OF ILLINOIS
RED ROOSTER CORPORATION
(f/k/a CLARK RETAIL ENTERPRISES,
INC.) (CLARK OIL #2086),
)
)
Petitioner,
)
)
)
)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
Respondent.
NOTICE OF FILING AND PROOF OF SERVICE
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100W. Randolph St., Suite 11-500
Chicago, IL 60601
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East, P.O. Box 19274
Springfield, IL 62796-9274
John J. Kim
Assistant Counsel
Special Assistant Attorney General
Division ofLegal Counsel
1021 North Grand Avenue, East
P.O. Box 19276
Springfield, IL 62794-9276
The undersigned certifies that an original and nine copies of Petitioner’s Notice to
Appear and Produce was served upon the Clerk of the Illinois Pollution Control Board, and one
copy was served upon the hearing officer in this case by enclosing same in envelopes with
postage fully prepaid, and by depositing said envelopes in a U.S. Post Office Mail Box in
Springfield, Illinois, and one copy was serve~upon the above party of record in this case via
hand-delivery at the above address, on the~2~’dayof June, 2004.
Hedinger Law Office
2601 South Fifth Street
Springfield, IL 62703
(217) 523-2753 phone
(217) 523-4366 fax
RE CE VED
CLERK’S OFFICE
)
)
STATE OFILLINO~S
Pollution Control Board
vi.
PCB No. 05-126
)
)
)
edi~~7~~
This document prepared on recycled paper
