MAR
09
2007
OFFICE
OF
STATE
THE
ATFORNEY
OF
ILLINOIS
GENERAL
POllution
stq
OF
Cor’
LroI
8
oard
Lisa
Madigan
ATTORNEY
GENERAL
March
7,
2007
The Honorable
Dorothy
Gunn
Illinois
Pollution
Control
Board
James
R.
Thompson
Center,
Ste.
11-500
100 West
Randolph
Chicago,
Illinois
60601
Re:
People
v. Gary
Simmons,
individually,
andLawrence
County
Disposal
Centre,
Inc.,
an
Illinois
corporation,
PCB
No.
06-1
59
Dear Clerk
Gunn:
Enclosed
for
filing
please
find
the original
and
five
copies
of a
Notice
of
Filing Discovery
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.
Thank
you
for
your cooperation
and
consideration.
Very truly
yours,
,vç
//‘t
Phillip
McQullan
Environmental
Bureau
500 South
Second
Street
Springfield,
Illinois
62706
(217) 782-9031
PM/pp
Enclosures
ILLINOIS,
)
Complainant,
V.
GARY
SIMMONS,
individually,
and
LAWRENCE
COUNTY
DISPOSAL
CENTRE,
INC.,
an Illinois
corporation,
Respondents.
)
)
I
b7\j
)
PCB
NO. 06-1 59
)
(Enforcement)
)
—
U
CLERK’S
OFFICE
t
MARO2OO7
STATE
OF
ILLINOIS
POUtjon
Control
Board
NOTICE
OF SERVICE
OF
DISCOVERY
DOCUMENTS
To:
Dorothy
M.
Gunn
Clerk of the
Board
Illinois
Pollution
Control
Board
100
West Randolph
Street
Suite
11-500
Chicago,
IL 60601
Carol
Webb
Hearing
Officer
Illinois
Pollution
Control
Board
1021 North
Grand
Avenue East
Springfield,
IL
62794
PLEASE
TAKE
NOTICE that
I have today
served
on the Respondents,
GARY
SIMMONS,
individually,
and LAWRENCE
COUNTY
DISPOSAL
CENTRE,
INC.,
the
following
discovery
documents
in
the above-referenced
matter.
1.
COMPLAINANT’S
FIRST
SET OF
INTERROGATORIES
DIRECTED
TO
RESPONDENTS,
and
3.
COMPLAINANT’S
FIRST
REQUEST
FOR
PRODUCTION
OF
DOCUMENTS
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
Di
isio
BY:_________
Phil
lip
cQu
1 Ia r
Assistant
Attorney
General
Environmental
Bureau
500
South
Second
Street
I hereby
certify
that
I did on
March 7, 2007, send
by
First
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,
COMPLAINANT’S
FIRST SET OF
INTERROGATORIES
DIRECTED TO
RESPONDENTS
and
COMPLAINANT’S
FIRST
REQUEST
FOR
PRODUCTION
OF DOCUMENTS
To:
Gary Simmons
Gary Simmons
2101 South
Sievers Road
P.O.
Box 1852
Vincennes,
IN 47591
Vincennes, IN 47591
Lawrence
County Disposal
Centre,
Inc.
C/o
National Registered
Agents, Inc.
200 West Adams Street
Chicago,
IL 60606
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:
Dorothy Gunn, 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
Phillip
Mcøuillan
I
Assistant
Attorney
General
This filing
is
submitted
on
recycled
paper.