Lisa Madigan
Al"I ORNEY GENERAL
Dorothy Gunn, Clerk
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601-3286
Dear Clerk Gunn
:
Enclosed for filing please find the original and ten copies of a REPLY TO AFFIRMATIVE
DEFENSES and NOTICE OF FILING in regard to the above captioned matter. Please file the
original and return a file-stamped copy to our office in the enclosed, self-addressed, stamped
envelope .
Thank you for your cooperation and consideration
.
OFFICE OF THE ATTORNEY GENERAL
STATE OF ILLINOIS
December 21, 2005
Re :
People v.
North American Lighting, Inc., a Michigan corporation
PCB No. 06-78
Raymond J . Gallery
Assistant Attorney General
500 South Second Street
Springfield, Illinois 62706
RECEIVED
CLERK'S OFFICE
DEC 2 7 2005
STATE OF ILLINOIS
Pollution Control Board
1001 East Main, Carbondale, Illinois 62901
•
(618) 529-6400
•
'CFY: (618) 529-6403
•
Fax: (618) 529-6416
RJC/pp
Enclosures
500 South Second Street, Springfield, Illinois 62706
•
(217) 782-1090
•
'CFY: (217) 785-2771
•
Fax: (217) 782-7046
100 West Randolph Street, Chicago, Illinois 60601
•
(312) 814-3000
•
'CFY: (312) 814-3374
•
Fax: (312) 814-3806
PEOPLE OF THE STATE OF ILLINOIS,
)
Complainant,
)
-Vs-
NORTH AMERICAN LIGHTING, INC .,
)
a Michigan corporation,
)
Respondent .
)
To :
James L. Curtis
Seyfarth Shaw LLP
55 East Monroe Street
Suite 4200
Chicago, IL 60603
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 Reply to Affirmative Defenses, a copy of which is attached
hereto and herewith served upon you
.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN,
Attorney General of the
State of Illinois
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: December 21, 2005
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
NOTICE OF FILING
PCB No. 06-78
(Enforcement)
RECEIVED
CLERK'S
OFFICE
DEC 2 7 2005
STATE OF ILLINOIS
Pollution Control Board
MATTHE J. DUNN, Chief
Environsm ntal Enforcement/Asbes
Litiga for
vis
BY :
RA
ON
GALLERY
Assistant Attorney General
Environmental Bureau
CERTIFICATE OF SERVICE
I hereby certify that I did on December 21, 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 REPLY TO AFFIRMATIVE DEFENSES
To :
James L. Curtis
Seyfarth Shaw LLP
55 East Monroe Street
Suite 4200
Chicago, IL 60603
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
This filing is submitted on recycled paper
.
aymond J. Gallery
Assistant Attorney General
RECEIVED
CLERK'S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
DEC 2 7 2005
PEOPLE OF THE STATE OF ILLINOIS,
)
STATE OF ILLINOIS
Pollution Control Board
Complainant,
)
-VS-
)
PCB No. 06-78
(Enforcement-Air, Water)
NORTH AMERICAN LIGHTING, INC .,
)
a Michigan corporation,
)
Respondent .
)
REPLY TO AFFIRMATIVE DEFENSES
The PEOPLE OF THE STATE OF ILLINOIS, by LISA MADIGAN, Attorney General of the
State of Illinois, replies to the Affirmative Defenses filed by Respondent, North American Lighting,
Incorporated, as follows :
1
.
Plaintiff does not respond to Respondent's "First Affirmative Defense" because it does
not plead a proper Affirmative Defense under Illinois law
.
2
.
Plaintiff denies the "Second Affirmative Defense" and states that the Complaint is not
barred by any statute of limitations
.
3
.
Plaintiff denies the "Third Affirmative Defense ."
4
.
Plaintiff denies the "Fourth Affirmative Defense" and states that Respondent has
suffered no prejudice in its ability to defend itself .
5
.
Plaintiff denies the "Fifth Affirmative Defense ."
6 .
Plaintiff denies the "Sixth Affirmative Defense
."
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: December 21, 2005
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN
Attorney General
of the State of Illinois,
MATTHEW
Environmen
Asbestos
Litigatio D
BY :
RAYMOND J. CALLERY
Assistant Attorney General
