NOTICE OF FILING
To :
Mr. J . Richard Meno
Denby, Meno, Bloomer & Denby
P .O . Box 616
Carlinville, IL 62626
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 MOTION FOR ORDER OF HEARING OFFICER
ORDERING RESPONDENT TO PRODUCE DOCUMENTS REQUESTED BY ATTACHED
REQUEST TO PRODUCE, copies of which are 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
: November 6, 2006
MATTHEW J . DUNN, Chief
Environmental Enforcement/Asbestos
Litiga
Division
BY
:
D B R . ASCHE
Assistant Attorney General
Environmental Bureau
YER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
REC EIVED
CLERK'S OFFICE
PEOPLE OF THE STATE OF ILLINOIS, )
NOV
0 9 2006
Complainant,
)
PollutionSTATE
OF ILLINOIS
v.
)
PCB 06-77
Control Board
DENNIS K . STIEGEMEIER,
)
d/b/a I .L .C. DEVELOPMENT,
)
Respondent .
)
CERTIFICATE OF SERVICE
I hereby certify that I did on November 6, 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 FOR ORDER OF
HEARING OFFICER ORDERING RESPONDENT TO PRODUCE DOCUMENTS REQUESTED
BY ATTACHED REQUEST TO PRODUCE:
To:
Mr. J . Richard Meno
Denby, Meno, Bloomer & Denby
P
.O
. Box 616
Carlinville, IL 62626
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 .
DELBE
HASCHEMEYE
Assistant Attorney General
MOTION FOR ORDER OF HEARING OFFICER ORDERING
RESPONDENT TOPRODUCE
DOCUMENTS REQUESTED
BY ATTACHED REQUEST TO PRODUCE
NOW COMES the Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General of the State of Illinois, and pursuant to the Pollution Control Board's
procedural rules 101
.614 and 101 .616, requests the Hearing Officer to order the Respondent,
DENNIS K
. STIEGEMEIER, to produce the documents requested by the attached Request to
Produce ("Request") and in support thereof states :
1 .
The documents requested to be produced by the attached Request are all related
to the financial position of Respondent
.
2.
The information being sought is relevant or may lead to relevant information
concerning Respondent's resources and capacity to implement remediation matters to post a
performance bond and ability to pay a penalty, all of which are factors the Board is directed to
consider under Section 33(c) of the Illinois Environmental Protection Act
.
1
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
REC
LERK'S
C
S OFVE
FICE
D
PEOPLE OF THE STATE OF ILLINOIS, )
NOV 0 9 2006
Complainant,
)
v.
)
PCB 06-77
Pollution
Control
Co
ILLINOIS
Board
DENNIS K
. STIEGEMEIER,
)
d/b/a I .L.C
. DEVELOPMENT,
)
Respondent .
)
WHEREFORE, for the reasons stated, Complainant respectfully requests the Hearing
Officer order Respondent, DENNIS K
. STIEGEMEIER, to produce the information requested within
twenty-eight (28) days of the Hearing Officer's Order .
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN, Attorney General of the
State of Illinois,
500 South Second Street
Springfield, IL 62706
(217) 782-90
Dated : l( /G
6
B
DELBERT
SCHEMEYE''
Assistant Attorney General
2
COMPLAINANT'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS
NOW COMES the Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General of the State of Illinois, and pursuant to the order of the Hearing Officer
herein, hereby requests that the Respondent, DENNIS K
. STIEGEMEIER produce by mail to the
Office of the Illinois Attorney General, 500 South Second Street, Springfield, Illinois 62706, the
following documents :
"Document" shall mean every writing and record of every type and description in the
possession, control or custody of Petitioner, including, but not limited to, correspondence,
memoranda, stenographic or handwritten notes, reports, manifests, bills of lading, contracts,
studies, books, pamphlets, laboratory analyses, picture, voice recordings or computer records, and
shall mean a copy where the original is not in control of Petitioner
.
1
. Copies of all incorporation papers for Illini Lumber Company, Inc
., including, but not
limited to, Articles of Incorporation, Constitution and By-Laws, policies or any other documents
reflecting the creation and organization of Illini Lumber Company, Inc
.
2.
Copies of all financial statements prepared by or for Illini Lumber Company, Inc
.,
I .L .C
. Development and Dennis K
. Stiegemeier, including, but not limited to, annual reports,
balance sheets, and profit and loss statements for 2000 though the present
.
1
BEFORE
THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS, )
Complainant,
)
v.
)
PCB 06-77
DENNIS K . STIEGEMEIER,
)
d/b/a I.L.C
. DEVELOPMENT,
)
Respondent .
)
3.
Copies of all federal and state income tax returns filed by Illini Lumber Company,
Inc., I .L .C . Development and Dennis K
. Stiegemeier for 2000 through the present
.
4.
Copies of all the minutes for all of the meetings of the Board of Directors, or by the
officers of Illini Lumber Company, Inc
., since its incorporation
.
5
. Copies of all records showing the names of the owners or purchasers of any stocks
issued by Illini Lumber Company, Inc
., including, but not limited to, records showing the type of
stock, par value, market or any other measure of the value of the stock and any transfer of stocks
since the incorporation of Illini Lumber Company, Inc
.
6 .
Copies of any records showing the payment of dividends to stockholders of Illini
Lumber Company, Inc
., since its incorporation .
7 .
Copies of all records, including, but not limited to, bank statements or other financial
institution statements for Illini Lumber Company, Inc.,
I .L.C
. Development and Dennis K
.
Stiegemeier showing the balances on January 1, or some point in time proximate thereto, for 2001,
2002, 2003, 2004 and 2005 for any bank account or other type of financial or investment accounts
.
8.
Copies of all records identified in response to or providing information for responses
to Interrogatory Nos
. 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14 and 15
.
WHEREFORE,
Complainant respectfully requests Respondent, Dennis K
. Stiegemeier,
d/b/a U.C
. Development, produce the requested documents within 28 days
.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN, Attorney General of the
State of Illinois,
500 South Second Street
Springfield, IL 62706
Date 782-
1
Dated~
:
By:
DEL ERT D . HASCHEMEYE
Assistant Attorney General
2
