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    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
     
     
    PEOPLE OF THE STATE OF ILLINOIS, )
    LISA MADIGAN, Attorney General of )
    the State of Illinois, )
    )
    Complainant, )
    )
    vs ) PCB No. 05-51
    ) (Enforcement-Air)
    ENVIRONMENTAL HEALTH AND SAFETY )
    SERVICES, INC., an Illinois corporation )
    )
    Respondent. )
     
     
    RESPONSE TO REQUEST FOR ADMISSION OF FACTS
     
    NOW COMES the Respondent, ENVIRONMENTAL HEALTH AND SAFETY
    SERVICES, INC., an Illinois corporation, by its attorneys, SCHLUETER ECKLUND and for
    its response to Complainant’s Request for Admission of Facts states as follows:
    1. Respondent admits Fact No. 1.
     
    2. Respondent admits Fact No. 2.
     
    3. Respondent admits Fact No. 3.
    4. Respondent denies Fact No. 4.
    5. Respondent denies Fact No. 5.
    6. Respondent denies Fact No. 6.
    7. Respondent denies Fact No. 7.
    8. Respondent admits Fact No. 8.
    9. Respondent admits a notification was sent but currently is unsure of the date
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 17, 2006
     
     
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    and therefore denies the remaining facts stated.
    10. Respondent states that the notification speaks for itself.
    11. Respondent states that the notification speaks for itself.
    12. Respondent states that the notification speaks for itself.
    13. Respondent states that the notification speaks for itself.
    14. Respondent states that the notification speaks for itself.
    15. Respondent denies Fact No. 15.
    16. Respondent denies Fact No. 16.
    17. Respondent admits Fact No. 17.
    18. Respondent states that the notification speaks for itself.
    19. Respondent states that the notification speaks for itself.
    20. Respondent states that the notification speaks for itself.
    21. Respondent states that the notification speaks for itself.
    22. Respondent has insufficient knowledge to form an opinion, therefore denies
    the same.
    23. Respondent denies Fact No. 23.
    24. Respondent denies Fact No. 24.
    25. Respondent denies Fact No. 25.
    26. Respondent denies Fact No. 26.
    27. Respondent denies Fact No. 27.
    28. Respondent denies Fact No. 28.
    29. Respondent denies Fact No. 29.
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 17, 2006
     
     
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    30. Respondent denies Fact No. 30.
    31. Respondent denies Fact No. 31.
    32. Respondent denies Fact No. 32.
    33. Respondent denies as the temperatures were below freezing.
    34. Respondent has insufficient information to form a belief as to the statement
    made in Fact No. 34 and therefore denies the same.
    35. Respondent has insufficient information to form a belief as to the statement
    made in Fact No. 35 and therefore denies the same.
    36. Respondent denies Fact No. 36.
    37. Respondent denies Fact No. 37.
    38. Respondent has insufficient information therefore denies the same.
    39. Respondent denies Fact No. 39.
    40. Respondent has insufficient information to form a belief as to the statement
    made in Fact No. 40 and therefore denies the same.
    41. Respondent has insufficient information to form a belief as to the statement
    made in Fact No. 41 and therefore denies the same.
    42. Respondent denies Fact No. 42.
    43. Respondent denies Fact No. 43.
    44. Respondent denies Fact No. 44.
    45. Respondent denies Fact No. 45.
    46. Respondent denies Fact No. 46.
    47. Respondent denies Fact No. 47.
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 17, 2006
     
     
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    48. Respondent denies Fact No. 48.
    Respectfully submitted,
    ENVIRONMENTAL HEALTH AND SAFETY
    SERVICES, INC., an Illinois corporation, Respondent
     
    By: SCHLUETER ECKLUND
     
    _____________________________________
    BRYAN G. SELANDER, One of its attorneys
     
     
     
     
    DATE: January 17, 2006
     
     
    Bryan G. Selander #316
    SCHLUETER ECKLUND
    4023 Charles Street
    Rockford, IL 61108
    (815) 229-5333
           
      
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
     
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 17, 2006
     
     
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    CERTIFICATE OF SERVICE
     
    I, BRYAN G. SELANDER, Attorney for Respondent, do certify that I caused to be
    mailed this 17
    th
    day of January, 2006, the foregoing RESPONSES TO ADMISSION OF FACTS
    to the persons listed on the said NOTICE by first-class mail in a postage prepaid envelope and
    depositing same with the United States Postal Service located at 5225 Harrison Avenue,
    Rockford, IL 61125.
     
    It is hereby certified that a true copy of the foregoing Notice was electronically filed with
    the following on January 17, 2006:
    Dorothy M. Gunn
    Illinois Pollution Control Board
    James R. Thompson Center
    100 West Randolph, Suite 11-500
    Chicago, IL 60601
     
    ________________________________
    BRYAN G. SELANDER
    Attorney for Respondent
    Schlueter Ecklund
    4023 Charles Street
    Rockford, IL 61108
    (815) 229-5333
     
       
       
      
     
     
     
     
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 17, 2006
     
     
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    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
     
    PEOPLE OF THE STATE OF ILLINOIS, )
    LISA MADIGAN, Attorney General of )
    the State of Illinois, )
    )
    Complainant, )
    )
    vs ) PCB No. 05-51
    )
    ) (Enforcement-Air)
    ENVIRONMENTAL HEALTH AND SAFETY )
    SERVICES, INC., an Illinois corporation, )
    )
    Respondent. )
     
    NOTICE OF FILING
     
    TO: Katherine M. Hausrath Bradley P. Halloran
    Assistant Attorney General Hearing Officer
    Environmental Bureau Illinois Pollution Control Board
    188 W. Randolph St., 20
    th
    Flr. James R. Thompson Center, Suite 11-500
    Chicago, IL 60601 100 W. Randolph Street
    Chicago, IL 60601
     
     
      
    PLEASE TAKE NOTICE that I have today electronically filed with the Office of the
    Clerk of the Illinois Pollution Control Board a copy of Respondent’s Response to Admission
    of Facts, a copy of which is attached and herewith served upon you.
     
    Dated: January 17, 2006.
     
      
     
    Respectfully submitted,
     
    ENVIRONMENTAL HEALTH and SAFETY
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 17, 2006
     
     
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    SERVICES, INC.
     
    BY: SCHLUETER ECKLUND
     
    _____________________________________
    BRYAN G. SELANDER, one of its attorneys
     
      
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JANUARY 17, 2006

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