ELECTRONIC FILING, RECEIVED, CLERKS OFFICE, APRIL 7, 2006
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
by LISA MADIGAN, Attorney
)
General of the State of Illinois,
)
Complainant,
)
vs .
)
PCB 05-51
ENVIRONMENTAL HEALTH & SAFETY
)
(Enforcement-Air)
SERVICES, INC., an Illinois corporation,
)
Respondent .
)
NOTICE OF FILING OF WRITTEN DISCOVERY
TO :
Mr. Bryan G. Selander
Schlueter Ecklund
4023 Charles Street
Rockford, IL 61108
Mr. Bradley P. Halloran, Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph, Suite 11-500
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 certificate of service and notice of
filing of written discovery, a copy of which is attached and herewith served upon you
.
By
:
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN
Attorney General of the State of Illinois
By: Assistant Attorney General Katherine M . Hausrath
Environmental Bureau
188 West Randolph, 20 h Floor
Chicago, IL 60601
312-814-0660
Dated : Y/3-
f
ZC3"U
((7
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, APRIL 7, 2006
CERTIFICATE OF SERVICE
I, KATHERINE M. HAUSRATH, an Assistant Attorney General, do certify that I
caused to be mailedthis day of April, 2006, 1) PLAINTIFF'S FIRST SET OF
INTERROGATORIES TO RESPONDENT ENVIRONMENTAL HEALTH & SAFETY
SERVICES, INC. and 2) PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF
DOCUMENTS TO RESPONDENT ENVIRONMENTAL HEALTH & SAFETY
SERVICES, INC., by certified mail to Mr. Selander, and depositing same with the United
States Postal Service located at 188 West Randolph Street, Chicago, Illinois, 60601
.
It is hereby certified that a true copy of the foregoing Notice was electronically
filed with the following on April
i-
, 2006
:
Dorothy M . Gunn
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph, Suite 11-500
Chicago, IL 60601
t~
4
K THERINE M. HAUSRAT
Assistant Attorney General
Environmental Bureau
188 West Randolph, 20 th Floor
Chicago, IL 60601
312-814-0660