Respondents .
ORIGINAL
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Complainant,
)
bq
vs .
)
PCB No
.
0
6-4
(Enforcement)
PEOPLE OF THE STATE OF ILLINOIS,
MOORE PAINTING CO., an Illinois
corporation, and ILLINOIS-AMERICAN
WATER COMPANY, an Illinois
corporation,
R
ECEIVED
CLERKS OFFICE
MAR 1 4 2006
STATE OF ILLINOIS
Pollution Control Board
ANSWER
COUNT I
Comes now, Respondent, MOORE PAINTING CO ., an Illinois Corporation, by it's
attorney, AMY SHOLAR, and for it's Answer to Count I of Complainant's Complaint states as
follows :
1
.
Admit .
2 .
Admit .
3
.
Admit .
4 .
Admit .
5
.
Admit.
6 .
Neither admits nor denies and therefore demands strict proof thereof
7 .
Neither admits nor denies and therefore demands strict proof thereof
8
.
Deny .
9 .
Neither admits nor denies and therefore demands strict proof thereof.
Page 1 of 5
10 .
Neither admits nor denies and therefore demands strict proof thereof
11 .
Admit.
12 .
Admit that a follow-up inspection occurred, however, neither admit nor deny
13. Admit .
.
14 .
Admit .
15
.
Admit .
16 .
Admit .
17 .
Deny.
18 .
Deny.
WHEREFORE, Respondent, MOORE PAINTING CO ., an Illinois Corporation, prays for
judgment in it's favor and in bar of Count I of Complainant's Complaint
.
COUNT11
Comes now, Respondent, MOORE PAINTING CO ., an Illinois Corporation, by it's
attorney, AMY SHOLAR, and for it's Answer to Count II of Complainant's Complaint states as
follows
:
1-13 .
Respondent repeats it's answers to paragraphs one through thirteen in Count I of
Complainant's Complaint
.
14 .
Admit.
15
.
Admit .
16
.
Admit .
17 .
Deny .
18 .
Deny .
Page 2 of 5
WHEREFORE, Respondent, MOORE PAINTING CO, an Illinois Corporation, prays for
judgment in it's favor and in bar of Count II of Complainant's Complaint
.
COUNTIII
Comes now, Respondent, MOORE PAINTING CO., an Illinois Corporation, by it's
attorney, AMY SHOLAR, and for it's Answer to Count III of Complainant's Complaint states as
follows
:
1-13
.
Respondent repeats it's answers to paragraphs one through thirteen in Count I of
Complainant's Complaint .
14 .
Admit .
15 .
Admit .
16 .
Admit .
17 .
Admit.
18 .
Admit .
19 .
Neither admits nor denies and therefore demands strict proof thereof
20 .
Neither admits nor denies and therefore demands strict proof thereof.
21
.
Deny.
22 .
Deny.
23. Deny.
WHEREFORE, Respondent, MOORE PAINTING CO, an Illinois Corporation, prays for
judgment in it's favor and in bar of Count III of Complainant's Complaint
.
COUNT IV
Comes now, Respondent, MOORE PAINTING CO ., an Illinois Corporation, by it's
Page 3 of 5
attorney, AMY SHOLAR, and for it's Answer to Count IV of Complainant's Complaint states as
follows :
1-13
.
Respondent repeats it's answers to paragraphs one through thirteen in Count I of
Complainant's Complaint .
14 .
Admit .
15
.
Deny .
WHEREFORE, Respondent, MOORE PAINTING CO, an Illinois Corporation, prays for
judgment in it's favor and in bar of Count IV of Complainant's Complaint
.
COUNT V
Comes now, Respondent, MOORE PAINTING CO ., an Illinois Corporation, by it's
attorney, AMY SHOLAR, and for it's Answer to Count V of Complainant's Complaint states as
follows
:
1-13
.
Respondent repeats it's answers to paragraphs one through thirteen in Count I of
Complainant's Complaint
.
14 .
Admit .
15 .
Neither admits nor denies and therefore demands strict proof thereof
.
16 .
Deny.
WHEREFORE, Respondent, MOORE PAINTING CO, an Illinois Corporation, prays for
judgment in it's favor and in bar of Count V of Complainant's Complaint
.
COUNT VI
Comes now, Respondent, MOORE PAINTING CO ., an Illinois Corporation, by it's
attorney, AMY SHOLAR, and for it's Answer to Count VI of Complainant's Complaint states as
Page 4 of 5
I hereby certify that I did on
postage thereon fully prepaid, by depositing in a United States Post Office Box a true and correct
copy of the following instruments entitled ENTRY OF APPEARANCE .
To :
ILLINOIS-AMERICAN WATER CO .
PEOPLE OF THE STATE OF ILLINOIS
c/o CT Corporation System, R.A .
c/o J. L. Homan, Attorney General's Office
208 S . LaSalle Street, Suite 814
500 South Second Street
Chicago, IL 60604
Springfield, IL 62706
DOROTHY GUNN, CLERK
Illinois Pollution Control Board
James R. Thompson Ctr., Ste, 11-500
100 West Randolph
Chicago, IL 60601
CERTIFICATE OF SERVICE
RECEIVED
CLERK'S OFFICE
MAR 1 4 2006
STATE OF
ILLINOIS
Pollution Control Board
,
2006, send by first class mail, with
The
LAW OFFICE of
2010 State Street
AMY SHOLAR, P. C .
Phone 618-208-3347
Alton, IL 62002
Fax 618-463-0989
March 10, 2006
Honorable Dorothy Gunn
Illinois Pollution Control Board
James R. Thompson Ctr., Ste. 11-500
100 West Randolph
Chicago, IL 60601
Re:
People vs. Moore Painting Co .& Illinois-American Water Co .
Dear Clerk Gunn :
Enclosed for filing please find an original and one copy
of
our Answer to Complainant's Complaint
regarding above. I would ask that you return the copy to my in the enclosed self-addressed, postage
paid envelope .
Copies have been forwarded to the attorney(s) and/or person(s)
of
record along with a Certificate
of
Service .
Thank you for your time and attention to this matter
.
Very truly yours,
I/i
AS/sln
Enclosure
ORIGINAL
RECEIVED
CLERK'S OFFICE
MAR 1 4 2006
STATE OF ILLINOIS
Pollution Control Board
