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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 MOTION TO DEEM FACTS ADMITTED
     
    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 Motion to Deem Facts Admitted states as follows:
    1. Respondent, ENVIRONMENTAL HEALTH AND SAFETY SERVICES, INC.,
    submitted a Response to Complainant’s Request for Admission which provided responses
    to each and every one of the forty-eight items contained in the Request in a timely fashion.
    2. Respondent submits contemporaneously with this Response an
    Amended Response to Reqyest for Admission which contains the same Responses as the previous
    pleading and contains a Verification from the President of the Respondent Corporation.
    3. As the responses remain the same, and now contain a Verification, the state
    has not been jeopardized in any respect with regard to its preparation of this case.
    4. To grant Complainant’s Motion to Deem Facts Admitted, would not justly
    decide this matter.
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 3, 2006
     
     
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    WHEREFORE, Respondent, ENVIRONMENTAL HEALTH AND SAFETY SERVICES,
    INC., an Illinois corporation, respectfully request that the hearing officer deny the relief sought by
    the Complainant in its Motion to Deem Facts Admitted and accept the Amended Response
    containing the Verification.
    Respectfully submitted,
    ENVIRONMENTAL HEALTH AND SAFETY
    SERVICES, INC., an Illinois corporation, Respondent
     
    By: SCHLUETER ECKLUND
     
    _____________________________________
    BRYAN G. SELANDER, One of its attorneys
     
     
     
     
    DATE: February _______, 2006
     
     
    Bryan G. Selander #316
    SCHLUETER ECKLUND
    4023 Charles Street
    Rockford, IL 61108
    (815) 229-5333
           
      
     
     
     
     
     
     
     
     
     
     
     
     
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 3, 2006
     
     
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    CERTIFICATE OF SERVICE
     
    I, BRYAN G. SELANDER, Attorney for Respondent, do certify that I caused to be
    mailed this _______ day of February, 2006, the foregoing RESPONSES TO MOTION TO
    DEEM FACTS ADMITTED 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 February __________, 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, MARCH 3, 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: February _____________, 2006.
     
    Respectfully submitted,
     
    RANDY OLDENBERGER d/b/a
    ENVIRONMENTAL HEALTH and SAFETY
     
    BY: SCHLUETER ECKLUND
     
    _____________________________________
    BRYAN G. SELANDER, one of its attorneys
    ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 3, 2006

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