Lisa Madigan
ATTORNEY GENERAL
The Honorable Dorothy Gunn
Illinois Pollution Control Board
James R
. Thompson Center, Ste . 11-500
100 West Randolph
Chicago, Illinois 60601
Re :
People v. J & S Companies, Inc., et al.
PCB 06-33
Dear Clerk Gunn
:
Enclosed for filing please find the original and ten copies of a Request for Admission of Fact
Directed Towards First Choice Construction, Inc ., in regard to the above-captioned matter
. Please
file the original and return a file-stamped copy to me in the enclosed, self-addressed envelope
.
KLG/pp
Enclosures
OFFICE OF THE ATTORNEY GENERAL
STATE OF ILLINOIS
April 21, 2006
Thank you for your cooperation and consideration
.
Very truly yours,,
Kristen Laughridge Gale
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
(217) 782-9031
RECEIVED
APR 2 5 2006
Pollution
STATE OF
Control
ILLINOISBoard
500 South Second Street, Springfield, Illinois 62706 • (217) 782-1090
• TTY: (217) 785-2771 • Fax: (217) 782-7046
100 West Randolph Street, Chicago, Illinois 60601
• (312) 814-3000 • TTY : (312) 814-3374
• Fax : (312) 814-3806
1001 East Main, Carbondale, Illinois 62901 • (618) 529-6400
• TTY: (618) 529-6403 • Fax : (618) 529-6416
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVEDCLERK'S
OFFICE
PEOPLE OF THE STATE OF
)
APR 2 5 2006
ILLINOIS,
)
Pollution
STATEOF
Control
ILLINOISBoard
Complainant,
)
vs.
)
PCB No. 06-33
(Enforcement)
J & S COMPANIES, INC
., a Missouri
)
corporation,
and FIRST CHOICE
)
CONSTRUCTION, INC .,
an Illinois
)
corporation,
)
Respondents.
)
NOTICE OF FILING
To :
Mike Bowman
Tom LeChien
First Choice Construction, Inc .
Registered Agent for First Choice
1932 Townsley Lane
Construction, Inc .
East St
. Louis, IL 62204
120 W . Main Street, Ste
. 110
Belleville, IL 62220
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 REQUEST FOR ADMISSION OF FACT DIRECTED
TOWARDS FIRST CHOICE CONSTRUCTION, INC
., 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
: April 21, 2006
MATTHEW J
. DUNN, Chief
Environmental Epforcementt/ sbestos
Litigation Dj4sion
BY:
KRISTEN LAUGHRIDGE GALE
Assistant Attorney General
Environmental Bureau
CERTIFICATE OF SERVICE
I hereby certify that I did on April 21, 2006, 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 NOTICE OF FILING and REQUEST FOR ADMISSION OF
FACT DIRECTED TOWARDS FIRST CHOICE CONSTRUCTION, INC
.
To :
Mike Bowman
Tom LeChien
First Choice Construction, Inc .
Registered Agent for First Choice
1932 Townsley Lane
Construction, Inc.
East St
. Louis, IL 62204
120 W . Main Street, Ste
. 110
Belleville, IL 62220
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
.
KRISTEN LAUGHRIDGE GALE
Assistant Attorney General
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS, )
Complainant,
)
vs .
)
No
. PCB 06-33
(Enforcement-Land)
J & S COMPANIES, INC., a Missouri
)
corporation, and FIRST CHOICE
)
CONSTRUCTION, INC
., an Illinois
)
corporation,
)
Respondent .
)
REQUEST FOR ADMISSION OF FACT DIRECTED
TOWARDS FIRST CHOICE CONSTRUCTION, INC
.
The PEOPLE OF THE STATE OF ILLINOIS,
ex rel
.
LISA MADIGAN, Attorney General
of the State of Illinois, pursuant to Supreme Court Rule 216 submits this request for the
admission of the truth of the following specified relevant facts within 28 days after service
hereof:
1 .
In 2003, J & S Companies, Inc
. hired First Choice Construction, Inc . to haul the
construction and demolition debris from the Lansdowne Junior High School demolition site in
East St . Louis, St. Clair County, Illinois .
2.
Starting on or about February 6, 2003 until about December 3, 2003, First
Choice Construction hauled approximately 92 truckloads of construction and demolition debris
from the school demolition site to 7401 Bunkum Road, East St
. Louis, St. Clair County, Illinois
("disposal site") .
3.
The construction and demolition debris disposed at the disposal site consisted of
brick, metal, plaster, paper, wood, pipe insulation, wire, and rebar
.
4.
The disposal site is not permitted by the Illinois Environmental Protection Agency
RECEIVEDCLERK'S
OFFICE
APR 2 5 2006
STATE OF ILLINOIS
Pollution Control Board
(Illinois EPA) as a sanitary landfill
.
500 South Second Street
Springfield, Illinois 62076
217/782-9031
Dated :
3
Respectfully Submitted,
PEOPLE OF THE STATE OF ILLINOIS,
ex rel . LISA MADIGAN,
Attorney General of the State of Illinois
MATTHEW J . DUNN, Chief
Environmental Enforcement/
Asbestos tigation .Division,.
By
: / -
KRI TEN LAUGHRIDGE GALE
Assistant Attorney General
Environmental Bureau
