BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVEDCLERK'S
OFFICE
SEP 2 5 2006
PEOPLE OF THE STATE OF ILLINOIS,
)
Pollution
STATE OFControl
ILLINOIS
Board
Plaintiff,
)
0
v.
)
No. PCB ACr'
(Enforcement-Air)
RAY F. LANDERS, individually, and
)
EQUIPPING THE SAINTS MINISTRY,
)
INTERNATIONAL, INC ., and Illinois
)
not-for-profit corporation,
)
Defendant .
)
ANSWER TO COMPLAINT
NOW COMES, RAY F . LANDERS and EQUIPPING THE SAINTS MINISTRY,
INTERNATION, INC.,
Defendants, by and through their attorneys, Brandenburg-Rees & Rees,
and for their Answer to Complaint, respectfully states
as follows:
I .
The Defendant neither admits nor denies the allegations contained in Paragraph 1
of the Complaint, but demands strict proof thereof .
2.
The Defendant neither admits nor denies the allegations contained in Paragraph 2
of the Complaint, but demands strict proof thereof
3 .
The Defendant admits all of Paragraph 3 of the Complaint, except we deny that
the Cooperation is in good standing .
4.
The Defendant admits the allegations contained in Paragraph 4 of the Complaint
.
5 .
The Defendant admits the allegations contained in Paragraph 5 of the Complaint .
6.
The Defendant admits the allegations contained in Paragraph 6 of the Complaint .
7.
The Defendant admits the allegations contained in Paragraph 7 of the Complaint.
8 .
The Defendant denies the allegations contained in Paragraph 8 of the Complaint .
9.
The Defendant denies the allegations contained in Paragraph 9 of the Complaint .
10.
The Defendant denies the allegations contained in Paragraph 10 of the Complaint .
11 . The Defendant denies the allegations contained in Paragraph 11 of the Complaint
.
12. The Defendant denies the allegations contained in Paragraph 12 of the Complaint
.
13 .
The Defendant denies the allegations contained in Paragraph 13 of the Complaint
.
WHEREFORE, Defendants, RAY F . LANDERS, EQUIPPING THE SAINTS
MINISTRY, INTERNATIONAL, INC
., requests the Court to dismiss the Complaint and award
the Defendants their reasonable attorney's fees and costs incurred in defending this action
.
RAY F . LANDERS, EQUIPPING THE
SAINTS MINISTRY, INTERNATIONAL,
INC., Defendants
BY:
EDMOND H. REES
Reg. No. 02301008
BRANDENBURG-REES & REES
Attorneys at Law
128 South Broad Street
Post Office Box 556
Carlinville, IL 62626-0556
217-854-2602
CERTIFICATE OF SERVICE
The undersigned certifies that a true copy of the foregoing was served upon the following
by enclosing the same in an envelope addressed as follows :
J.L. Homan
Dorthy Gunn, Clerk
Environmental Bureau
Illinois Pollution Control Board
500 South Second Street
James R. Thompson Center
Springfield, IL 62706
Suite 11-500
100 West Randolph
Chicago, IL 60601
Said envelope, addressed as set out above, containing a copy of the foregoing instrument was
deposited in a United States Post Office receptacle in the City of Carlinville, Illinois, with
postage fully prepaid, on the
a
' day of
S ertem bet
, 2006 .
