BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVED
CLERK’S
OCT 212005
OFFICE
PEOPLE OF THE STATE OF ILLINOIS,
STATE OF ILLINOIS
Complainant,
)
Pollution Control Board
)
-vs-
)
No. PCB 05-181
PATTISON ASSOCIATES LLC, an
)
(Enforcement
—
Air)
Illinois limited liability company,
and 5701 SOUTH CALUMET LLC, an
Illinois limited liability company,
)
)
Respondents.
)
NOTICE
OF
FILING
PLEASE TAKE NOTICE that we have today, October21, 2005, filed with the
Office of the Clerk of the Illinois Pollution Control Board an original and fourteen (14)
copies of the attached Respondents’ Request to Produce to Plaintiff, a true and correct
copy of which is hereby served upon you.
DATED: October 21, 2005
Respectfully submitted,
PATTISON ASSOCIATES, LLC and
5701 SOUTH CALUMET, LLC
By:_______________________
One ofTheir Attorneys
Neal H. Weinfield, Esq.
Allyson L. Wilcox, Esq.
Bell, Boyd & Lloyd LLC
70 West Madison Street
Suite 3100
Chicago, IL 60602
312.372.1121
40K1 S4/l1I
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVED
PEOPLE OF THE STATE OF ILLINOIS
)
CLERK’S OFFICE
Complainant,
)
OCT
212005
STATE OF ILLINOIS
vs
)
Pollution Control Board
PATTISON ASSOCIATES LLC, an
)
No. PCB 05-181
Illinois limited liability company,
)
(Enforcement— Air)
and 5701 SOUTH CALUIVIET LLC, an
)
Illinois limited liability company,
)
)
Respondents.
)
RESPONDENTS’ REQUEST
TO PRODUCE TO PLAINTIFF
Pursuant to Illinois Supreme Court Rule 214, you are requested to produce within twenty-
eight (28) days at the offices of Bell, Boyd & Lloyd LLC, 70W. Madison, Suite 3100, Chicago,
Illinois, 60602, attorneys for respondents, the following documents, objects and tangible things
within your possession or control for inspection, copying, reproduction, photographing, testing
or sampling:
a. the statement of any party, including hut not limited to written
transcripts or summaries of oral statements or conversations and
rccordings of oral statements or conversations;
b. the statement or report of any other witness or knowledgeable person,
including but not limited to written transcripts or summaries of oral
statements or conversations and recordings of oral statements or
conversations;
c. all photographs, slides or motion pictures of the parties, of the subject
property and/or the inspection or subsequent testing which were taken
at any time;
cI. all incident, investigative and inspection reports pertaining to the
alleged occurrence(s) alleged in your complaint at law;
e. any and all notes, diaries, memoranda, correspondence or other
documents prepared you or any person on yo or behalf regarding the
events alleged in the complaint;
4 i
S2
()5./ ~
f. any and all data
and/or reports pertaining to any
testing preformed at
the subject site;
g. a privilege log of all documents withheld pursuant to privilege as
required under the local rules.
Respectfully submitted,
PATTISON ASSOCIATES, LLC
and
5701 SOUTH CALLIMET, LLC
By__
One of Their Attorneys
Neal H. Weinfield, Esq.
Allyson L. Wilcox, Esq.
Bell, Boyd & Lloyd LLC
70 West Madison Street
Suite 3100
Chicago, IL 60602
312.372.1121
Firm Number: 90100
408208/F/I
2
CERTIFICATE OF SERVICE
Allyson L. Wilcox, an attorney, hereby certifies that she caused a copy of the
attached Respondents’ Request to Produce to Plaintiff to be served upon:
Paula Becker Wheeler
Office of the Attorney General
188 West Randolph, 2010 Floor
Chicago, IL 60601
Bradley P. Halloran
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center, Ste. 11-500
100 W. Randolph Street
Chicago, Illinois 60601
via regular U.S. Mail, postage pre-paid, on October 21, 2005.
Aliyson L, Wilcox
4081
84/F/I
