BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
PEOPLE
OF THE
STATE
OF
ILLINOIS
)
)
Complainant,
)
v.
)
PCB
NO.
99-1
34
)
(Enforcement
- Water)
HERITAGE
COAL
COMPANY,
L.L.C.
)
(flkla
PEABODY
COAL
COMPANY
)
L.L.CJ,
)
Respondent.
NOTICE
OF
SERVICE
OF
DISCOVERY
DOCUMENTS
To:
Dorothy
M.
Gunn
Carol
Webb
Clerk
of the
Board
Hearing
Officer
Illinois
Pollution
Control
Board
Illinois
Pollution
Control
Board
100 West
Randolph
Street
1021
North
Grand
Avenue
East
Suite
11-500
Springfield,
IL
62794
Chicago,
IL
60601
PLEASE
TAKE
NOTICE
that I have
on
September
5, 2008,
served
on
the Respondent,
HERITAGE
COAL
COMPANY,
L.L.C.
(f/k/a
PEABODY
COAL
COMPANY,
L.L.C.),
the following
discovery
documents
in the
above-referenced
matter.
1.
ANSWERS
TO
RESPONDENT
HERITAGE’S
THIRD
SET
OF
INTERROGATORIES
TO
COMPLAINANT;
2.
ANSWERS
TO RESPONDENT
HERITAGE’S
FOURTH
SET
OF
INTERROGATORIES
TO
COMPLAINT;
3.
ANSWERS
TO
RESPONDENT
HERITAGE’S
FIFTH
SET OF
INTERROGATORIES
TO
COMPLAINT;
and
4.
ANSWERS
TO
RESPONDENT
HERITAGE’S
SIXTH
SET
OF
INTERROGATORIES
TO COMPLAINANT.
Respectfully
submitted,
PEOPLE
OF THE
STATE
OF
ILLINOIS
LISA
MADIGAN
Attorney
General
of
the
State
of Illinois
MATTHEW
J.
DUNN,
Chief
EnvironmentaT
Enforcement/Asbestos
Litigation
Division
BY_____________________
Thomas
Davis,
Chief
Assistant
Attorney
General
Environmental
Bureau
500
South
Second
Street
Springfield, Illinois
62706/(21
7)782-9031
R
2008
ILJNO,S
CERTIFICATE
OF SERVICE
I
hereby
certify
that I
did on
September
5, 2008, 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
SERVICE
OF DISCOVERY
DOCUMENTS
and
ANSWERS
TO
RESPONDENT
HERITAGE’S
THIRD,
FOURTH,
FIFTH
and SIXTH
SET
OF
INTERROGATORIES
TO COMPLAINT
To:
Stephen
F.
Hedinger
W.
C.
Blanton
Hedinger
Law
Office
Husch Blackwell
Sanders
LLP
2601
South Fifth
Street
4801 Main
Street,
Ste. 1000
Springfield,
IL
62703
Kansas
City,
MO 64112
and the original
and five
copies of
the NOTICE
OF SERVICE
OF DISCOVERY
DOCUMENTS
was
sent by
First Class
Mail with
postage
thereon
fully
prepaId
To:
John
T.
Therriault,
Assistant
Clerk
Illinois
Pollution
Control Board
State of
Illinois Center
Suite
11-500
100
West Randolph
Chicago,
IL
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
Thomas
Davis
Assistant
Attorney
General
This
filing is
submitted
on recycled
paper.