RECEIVCD
CLERKS OFFICE
DEC 022005
STATE OF ILLINOIS
Pollution Control Board
OFFICE OF THE ATTORNEY GENERAL
STATE OF ILLINOIS
Lisa Madigan
AFIORNEY GENERAL
November 30, 2005
The Honorable Dorothy Gunn
Illinois Pollution Control Board
James R. Thompson Center, Ste. 11-500
100 West Randolph
Chicago, Illinois 60601
Re:
People v. J & S Companies, Inc., et at
PCB 06-33
Dear Clerk Gunn:
Enclosed for filing please find the original and ten copies of a Requestfor Admission of Fact
Directed Towards J & S Companies, Inc., in regard to the above-captioned matter. Please file the
original and return a file-stamped copy to me in the enclosed, self-addressed envelope.
Thank you for your cooperation and consideration.
Very tru~yyours,
/ Kris~e~V~ughrJçigI
Env~r6nmenMfBureau
500 South Second Street
Springfield, Illinois 62706
(217) 782-9031
KL/pp
Enclosures
500 South Second Strect, Springflcld, Illinois 62706 •
(217)
782-1090 • TTY: (217) 785-2771 • Fax: (217) 782-7046
100 Wcst Randolph Strcct, Chicago, Illinois 60601 • (312) 814-3000 • ITY: (312) 814-3374 • Fax: (312) 814-3806
1001 East Main, Carbnndale, Illinois 62901 • (618) 529-6400 • FlY: (618) 529-6403 • Fax: (618) 529-6416
PCB No. 06-33
(Enforcement)
)
RECEIVED
CLERK’S OFFICE
DEC 022005
STATE OF ILLINOIS
Pollution Control Board
To:
J & S Companies, Inc
do C T Corporation System, R.A
208 5. LaSalle St., Ste. 814
Chicago, IL 60604-1101
NOTICE OF FILING
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
Control Board of the State of Illinois, a REQUEST FOR ADMISSION OF FACT DIRECTED
TOWARDS J & S COMPANIES, INC., a copy of which is attached hereto and herewith served
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN,
Attorney General of the
State of Illinois
MATTHEW J. DUNN, Chief
Environmental EnforcementlAsbestos
Litigatio5.Division
PEOPLE OF THE STATE OF
ILLINOIS,
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
vs.
)
Complainant,
J & S COMPANIES, INC., a Missouri
corporation,
and FIRST CHOICE
CONSTRUCTION, INC., an Illinois
corporation,
Respondents.
upon you.
BY: C..’
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Environmental Bureau
Dated: November 30, 2005
CERTIFICATE OF SERVICE
I hereby certify that I did on July 11,2005, send by First Class Mail, with postage thereon
fully prepaid, by depositing in a United States Post Office Box a true and correct copy of the
following instruments entitled NOTICE OF FILING and REQUEST FOR ADMISSION OF FACT
DIRECTED TOWARDS J & S COMPANIES, INC.:
To:
J & S Companies, Inc.
c/o C T Corporation System, R.A.
208 S. LaSalle St., Ste. 814
Chicago, IL 60604-1101
and the original and ten copies by First Class Mail with postage thereon fully prepaid of the
same foregoing instrument(s):
To:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
Suite 11-500
100 West Randolph
Chicago, Illinois 60601
A copy was also sent by First Class Mail with postage thereon fully prepaid to:
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
Springfield, IL 62794
..-KRlSTENLAUGH~
— Assisthr1tAttornp~’Gei
This filing is submitted on recycled paper.
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVED
CLERK’S OFFICE
PEOPLE OF THE STATE OF ILLINOIS,
DEC 02 2005
Complainant,
)
STATE OF ILLINOIS
Pollution Control Board
vs.
)
No. PCB 06-33
(Enforcement-Land)
J & S COMPANIES, INC., a Missouri
corporation, and FIRST CHOICE
CONSTRUCTION, INC., an Illinois
corporation,
Respondent.
REQUEST FOR ADMISSION OF FACT DIRECTED
TOWARDS J & S COMPANIES, INC.
The PEOPLE OF THE STATE OF ILLINOIS,
ex ret
LISA MADIGAN, Attorney General
of the State of Illinois, pursuant to Supreme Court Rule 216 submits this request for the
admission of the truth of the following specified relevant facts within 28 days after service
hereof:
1.
On February 6, 2003, J & S Companies, Inc. signed a contract with Board of
Education-School District 189 for demolition of the Landsdowne Jr. High School located in East
St. Louis, St. Clair County, Illinois.
2.
In 2003, J & S Companies, Inc. demolished the Landsdowne Jr. High School.
3.
J & S Companies, Inc. hired First Choice Construction, Inc. to haul the
construction and demolition debris from the school demolition site.
4.
Starting on or about February 6, 2003 until about December 3, 2003, First
Choice Construction hauled approximately 92 truckloads of construction and demolition debris
from the school demolition site to 7401 Bunkum Road, East St. Louis, St Clair County, Illinois
(‘disposal site”).
5.
J & S Companies, Inc. knew that the construction and demolition debris from the
school demolition site was disposed of at the demolition site.
6.
The construction and demolition debris disposed at the disposal site consisted of
brick, metal, plaster, paper, wood, pipe insulation, wire, and rebar.
7.
The disposal site is not permitted by the Illinois Environmental Protection Agency
(Illinois EPA) as a sanitary landfill.
Respectfully Submitted,
PEOPLE OF THE STATE OF ILLINOIS,
ex ret
LISA MADIGAN,
Attorney General of the State of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement
Asbestos Litigation Division
By
KRISTEN’ LAUGHRIQÔE,Y
64~
AssistariLAtforneyZ’en9~f
Environmental Bureau
500 South Second Street
Springfield, Illinois 62076
217/782-9031
Dated:
3
