Lisa Madigan
XI YORNFY 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. CSX Transportation
PCB No. 06-51
Dear Clerk Gunn
:
Enclosed for filing please find the original and ten copies of a Notice of Filing and
Complainant's Motion to Withdraw Motion to Strike Affirmative Defenses in regard to the above-
captioned matter
. Please file the originals and return file-stamped copies to me in the enclosed,
self-addressed envelope
.
Thank you for your cooperation and consideration.
OFFICE OF THE ATTORNEY GENERAL
STATE OF ILLINOIS
May 9, 2006
isten Laughridge Gale
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
(217) 782-9031
KLG/pp
Enclosures
500 South Second Street, Springfield, Illinois 62706 •
(217) 782-1090 • TFY: (217) 785-2771 • Fax
: (217) 782-7046
100 West Randolph Street, Chicago, Illinois 60601 • (312) 814-3000
• Try: (31Z) 814-3374 • Fax : (312) 814-3806
1001 East Main, Carbondale, Illinois 62901
• (618) 529-6400 • 'Fl'Y
: (618) 529-6403 • Fax : (618) 529-6416
RECEIVEDCLERK'S
OFFICE
MAY 1 1 2006
STATE OF ILLINOIS
Pollution Control Board
RECEIVED
MAY 1
1 2006
ex
PEOPLE
rel.
LISA
OF THE
MADIGAN,
STATE
AttorneyOF
ILLINOIS, ))
Pollution
STATE OF
Control
ILLINOIS
Board
General of the State of Illinois,
)
Complainant,
)
vs.
)
PCB No . 06-51
(Enforcement)
CSX TRANSPORTATION, INC ., a
)
Virginia corporation,
)
Respondent.
)
NOTICE OF FILING
To:
David L . Rieser
McGuire Woods LLP
77 West Wacker Drive, Suite 4100
Chicago, IL 60601
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the
Pollution Control Board of the State of Illinois, Complainant's Motion to Withdraw Motion to
Strike
Affirmative Defenses, 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
MATTHEW J
. DUNN, Chief
Environmental nforcement/Asbestos
Litigation D'vi11
7
BY:,
KRISTEN LAUGHRIDGE GALE
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated
: May 9, 2006
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CERTIFICATE OF SERVICE
I hereby certify that I did on May 9, 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 MOTION TO WITHDRAW MOTION TO
STRIKE AFFIRMATIVE DEFENSES
To :
David L . Rieser
McGuire Woods LLP
77 West Wacker Drive, Suite 4100
Chicago, IL 60601
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
fRISTEN
LAUGHRIDGE GALE
Assistant Attorney General
This filing is submitted on recycled paper
.
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARD RERK'EZVED
MAY 1
2006
PEOPLE OF THE STATE OF ILLINOIS, )
Pollution
STATE OF
Control
ILLINOISBoard
Complainant,
)
vs.
)
No. 06-51
(Enforcement)
CSX TRANSPORTATION, a Virginia
)
corporation,
)
Respondent .
)
MOTIONTOWITHDRAW
MOTIONTOSTRIKE
AFFIRMATIVE DEFENSES
NOW COMES Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General of the State of Illinois moves to withdraw the Motion to Strike
Affirmative Defenses against Respondent, CSX TRANSPORTATION, and states as follows
:
1 .
Complainant filed the motion to strike affirmative defenses on December 29,
2005 .
2 .
Respondent subsequently filed an amended answer and affirmative defenses on
January 19, 2006
.
3 .
Respondent's amended answer and affirmative defenses addresses the
Complainant's reasons for the motion to strike .
1
WHEREFORE, the Complainant prays that the Board enter an order withdrawing the
Complainant's Motion to Strike .
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated : May
8, 2006
2
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN,
Attorney General
of the State of Illinois,
MATTHEW J . DUNN, Chief
Environmental Enforcement/Asbestos
Litigation
on
BY:
K ISTEN
GALE
Assistant Attorney General
Environmental Bureau
