Milton and
    Virginia
    Kamholz
    I
    Ii
    1306 Sullivan
    Road
    U \.-
    1
    Woodstock,
    Illinois
    60098
    Phone:
    (815)
    568
    6166
    STATE
    OP
    ILL
    iNOjs
    oIIut
    Con
    trol
    Board
    May 15,
    2002
    BY
    CERTIFIED
    MAIL
    RETURN REQUESTED
    Illinois Pollution
    Control
    Board
    Attention:
    Clerk
    of the
    Board
    James
    R Thompson
    Center, Suite
    11-500
    100
    W Randolph
    Street
    Chicago,
    Illinois
    60601
    Re:
    PCB 02-41 Karnholz
    v.. Sporleder
    Dear
    Clerk of
    the Board,
    Enclosed, please
    find
    a
    Notice
    of
    Filing,
    for a
    Motion
    To
    Compel
    for answers
    to
    Complainant’s
    Interrogatories
    from the
    Respondents
    Lawrence
    and
    Mariann
    Sporleder.
    This is filed
    by the Complainants,
    Milton
    and Virginia
    Kamholz, and
    directed
    to
    Hearing Officer
    Bradley
    Halloran.
    Proof of Service
    is also
    enclosed.
    Please
    find one original
    of the Motion,
    along
    with four copies,
    as
    stated
    in Section 10
    1.302
    (h)
    (1)
    of the Pollution
    Control
    Board’s
    Procedural
    Rules.
    Sincerely
    yours,
    1/t-
    44/
    Milton
    and
    Virginia Kamholz
    Milton and Virginia
    Kamholz
    1306
    Sullivan
    Road
    Woodstock,
    Illinois
    60098
    (815) 568
    6166

    CLER1<
    OFPTCE
    M4Y
    i
    iLLINOIS
    POLLUTION
    CONTROL
    BOARD
    +
    MILTON
    and
    VIRGINIA
    KAMHOLZ
    )
    STATE
    OF
    ILLINOIS
    Pollutto,,
    Control
    Board
    Complainants
    )
    PCB
    02-41
    )
    (Citizen’s
    Enforcement
    case
    Air,
    Noise)
    v.
    )
    )
    LAWRENCE
    and
    MARIANN
    SPORLEDER
    )
    )
    Respondents
    )
    NOTICE
    OF
    FILING
    To:
    The
    Clerk
    of
    the
    Board
    Illinois
    Pollution
    Control
    Board
    100
    W.
    Randolph
    Street
    James
    R
    Thompson
    Center
    Suite
    11-500
    Chicago,
    Illinois
    60601
    Bradley
    P.
    Halloran
    Hearing
    Officer
    Illinois
    Pollution
    Control
    Board
    100
    W.
    Randolph
    Street
    James
    R
    Thompson
    Center
    Suite
    11-500
    Chicago,
    Illinois
    60601
    Joseph
    Gottemoller,
    attorney
    for
    the
    Respondents
    One
    North
    Virginia
    Street
    Crystal
    Lake,
    Illinois
    60014
    PLEASE
    TAKE
    NOTICE
    that
    I
    have
    today
    filed
    with
    the
    Office
    of
    the
    Clerk
    of
    the
    Pollution
    Control
    Board,
    a
    Motion
    to
    Compel,
    for
    the
    Respondent’s,
    Lawrence
    an
    Mariann
    Sporleder
    “Request
    to
    Produce”
    and
    for
    the
    “Interrogatories
    To
    Be
    Answered
    By
    The
    Respondents.
    This
    filing
    is
    being
    issued
    by
    the
    Complainants,
    Milton
    and
    Virginia
    Kamholz,
    and
    is
    directed
    to
    Hearing
    Officer
    Brad
    Halloran.
    copy
    is
    herewith
    served
    upon
    you.
    Milton
    and
    Virginia
    KamhoIComplainan
    May
    15,
    2002
    Milton
    and
    Virginia
    Kamholz
    1306
    Sullivan
    Road
    Woodstock,
    Illinois
    60098

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    CU!RWS
    O
    MJY
    16
    2002
    MILTON
    C.
    AND
    VIRGINIA
    L.
    KAMHOLZ
    )
    1ATEOPIWNOIS
    PoI!t,
    0
    Control
    Board
    Complainants
    )
    )
    PCB
    02-41
    )
    (Citizen’s
    Enforcement
    Air,
    Noise)
    v.
    )
    )
    )
    LAWRENCE
    and
    MARIANE
    SPORLEDER
    )
    )
    )
    Respondents
    )
    MOTION
    TO
    COMPEL,
    FOR
    RESPONDENTS
    ANSWERS
    TO
    COMPLAINANTS
    REQUEST
    TO
    PRODUCE
    Complainant’s
    Milton
    and
    Virginia
    Kamholz,
    come
    before
    you
    with
    a
    MOTION
    TO
    COMPEL
    for
    Respondents
    Lawrence
    and
    Mariann
    Sporleder’s
    response
    to
    Complainant’s
    Request
    to
    Produce,
    pursuant
    to
    the
    Boards
    Procedural
    Rules,
    Subart
    F,
    Sec.
    101.614
    regarding
    “Production
    of
    Information,”
    and
    Sec.
    101.616
    (h)
    regarding
    “Discovery.
    Question
    #
    1
    Regarding
    question
    and
    answer
    to
    #1
    of
    The
    Request
    to
    Produce,
    Complainants
    accept
    the
    Respondents
    response,
    however
    there
    is
    a
    concern
    that
    nothing
    was
    presented
    at
    this
    time,
    regarding
    previously
    known
    information.
    Respondents
    should
    take
    this
    opportunity
    to
    respond
    at
    this
    time,
    if
    possible.
    Question
    #
    2
    Again,
    the
    response
    raises
    concern
    regarding
    the
    lack
    of
    response
    for
    previously
    known
    evidence.
    The
    Complainants
    do
    not
    understand
    the
    response,
    “Investigation
    continues.”
    Some
    previously
    known
    evidence
    or
    information
    regarding
    this,
    was
    due
    on
    May
    31
    We
    understand
    and
    respect
    that
    Duty
    to
    seasonably
    supplement
    applies.
    This
    motion
    to
    compel,
    gives
    them
    an
    opportunity
    to
    respond
    differently
    if
    they’d
    like
    to.
    Based
    on
    the
    fact
    that
    nothing
    was
    presented,
    we
    request
    that
    you
    consider
    and
    record
    Complaint’s
    concerns,
    and
    motion
    to
    compel
    if
    possible
    to
    do
    so.
    Complainants
    are
    not
    seeking
    sanctions,
    just
    timely
    information.
    Milton
    and
    Virginia
    Kamholz
    1306
    Sullivan
    Road
    Woodstock,
    Illinois
    60098
    (815)
    568
    6166
    Respectihily
    submitted,

    CLERKS
    OFFICE
    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    iy
    I
    2002
    MILTON
    C.
    AND
    VIRGINIA
    L. KAMHOLZ
    )
    STATE
    OF
    IWNOIS
    )
    Pollu
    Hon
    Control
    Bocr
    Complainants
    )
    )
    PCB 02-4
    1
    )
    (Citizen’s
    Enforcement
    — Air, Noise)
    v.
    )
    )
    )
    LAWRENCE
    and
    MARIANE
    SPORLEDER
    )
    )
    )
    Respondents
    )
    MOTION
    TO COMPEL
    ANSWERS
    TO
    INTERROGATORJES
    Complainants Milton
    and
    Virginia
    Kamholz
    bring before
    you a motion
    to
    compel
    answers
    to
    the
    complaint’s
    interrogatories
    pursuant
    to the
    Board’s
    Procedural
    Rules,
    Subpart
    F,
    Section
    101.616
    (a) (b)
    (d)
    (e)
    (g)
    and
    (h).
    Following
    are
    the
    reasons
    for
    this request.
    Interrogatory
    #
    1.:
    Insufficient
    response.
    The
    question
    asks
    for
    names
    and
    addresses.
    Please
    use
    this
    opportunity
    to answer
    the
    question.
    Interrogatory
    # 2:
    Incomplete
    answer:
    Respondents
    should
    use
    this opportunity
    to
    amend
    their
    response.
    Section
    101.616(h)
    of
    the Boards
    Procedural
    Rules.
    Interrogatory
    #
    3:
    Evasive
    answer.
    Please
    answer
    (a)
    Interrogatory
    #
    4.
    Insufficient,
    evasive
    response.
    The
    question
    states
    the fact
    that it’s
    a rule you’ve
    imposed.
    The
    question
    asks why?
    Interrogatory
    #
    5
    OK
    Interrogatory
    #
    6
    OK
    Interrogatory
    # 7
    Incorrect
    information.
    Respondents
    should
    use this
    opportunity
    to amend
    this
    answer.
    Interrogatory
    #
    8
    Unresponsive
    :
    Complainants
    do not
    understand
    why,
    or
    agree
    to, the
    reasoning
    that
    this
    question
    is beyond
    the scope
    of permissible
    questions.
    Pursuant
    to
    Subpart
    F, Sec.
    101.616
    (a) and
    (b)
    the question’s
    answer
    will
    support
    the complainant’s
    claims
    of
    frequent
    and
    continious
    ,riding,
    and
    is
    relevant
    to the
    case.
    The
    question
    does not
    ask for
    any private
    or damaging
    personal
    information.
    It’s
    no
    secret
    to anyone
    that
    the boys
    live there.
    “Living
    there,
    as
    opposed
    to visiting,
    makes
    a huge
    difference
    in
    the
    riding
    patterns.
    Complainants
    request
    that
    this
    question
    be answered.
    PLEASE
    NOTE:
    I WILL
    CHANGE
    TillS
    OUESTION
    TO
    READ:
    Has
    your
    grandson
    Kelly,
    ever
    had
    occasion
    to live with
    you
    in your
    home,
    over
    the
    past
    10
    years?
    Yes
    or No?
    Interrogatory
    #
    9
    OK
    Interrogatory
    #
    10
    This
    answer
    is incomplete.
    Complainants
    accept
    it
    as
    is.
    Interrogatory
    #
    11
    Answer
    accepted.

    Pg 2
    Interrogatory
    # 12
    Insufficient and
    incorrect answer.
    Evasive. Please read and answer. Complainants
    know
    when you
    responded, they ask why
    you
    didn’t respond to earlier attempts
    to
    deliver.
    Interrogatory
    #
    13
    Unresponsive answer. Complainants do not understand why, or
    agree with your
    reason
    as
    to why this question is beyond the scope of permissible
    questions.
    Sec.
    101.616
    (a)
    and
    (b)
    Complainant
    requests
    an answer to this question. It’s not a
    privacy
    matter. It’s big, and
    every one can see
    it, including
    any
    prospective buyer of our property. It’s
    107
    fret
    from
    the
    dividing property line. Your
    intent is important to us, and to
    our
    lives.
    We are retired, and want to make plans. Complainant Milton
    will be 67 years old this
    June, and he
    would
    like to know if you
    intend
    to have a dirt bike track of this
    magnitude on your
    property. This information is also to Virginia. This information
    is relevant
    to
    the
    case
    and this question
    deserves
    an
    answer. On what grounds would a question like this be
    protected from an
    answer?
    Please respond.
    Interrogatory # 14
    OK
    Interrogatory # 15
    OK
    Interrogatory
    #16
    Ifyou do
    supplement, Complainants would appreciate addresses.
    Interrogatory # 17
    OK
    This motion to compel answers to
    interrogatories is respectfully submitted on
    May 15, 2002.
    Complainants do
    not seek sanctions ,just timely answers
    and information.
    Sincerely
    +dt1
    /øfhf3
    Milton d
    Virginia
    Kamholz.
    Milton and Virginia
    Kamholz
    1306
    Sullivan Road
    Woodstock, Illinois
    60098
    (815) 568
    6166

    VERIFICATION BY CERTIFICATION
    Under penalties as provided by law pursuant to Section 109 of the
    Code
    of Civil
    Procedure, the
    undersigned
    certifies that the statements
    set forth in this instrument are true, correct, and complete, except
    as to
    matters
    therein stated
    to
    be on
    information
    and
    belief
    and as to such matters the undersigned certifies
    as
    aforesaid
    that he
    verily believes
    the same to be true.
    ;&
    Milton
    Kamholz
    (Virginia
    Kamholz
    SUBSCRIBED AND SWORN TO
    Bef
    me this /ffday
    of
    (Notary public
    /
    SHERALYNN
    F.
    THUROW
    Notary
    Public,
    State
    of
    Illinois
    My
    Commission
    Exp.
    02/05/2005

    RECEIVED
    BEFORE
    THE
    ILLINOIS POLLUTION
    CONTROL
    BOARDCLIS
    flFP
    MIW
    16
    2002
    MILTON
    C.
    and
    VIRGINIA
    L. KAMHOLZ
    )
    STATE
    OF
    IWNOIS
    )
    Pollution
    Control
    Board
    Complainants
    )
    )
    v.
    )
    PCBO2-41
    )
    (Citizens
    Enforcement
    Air,
    Noise)
    LAWRENCE
    and
    MARIANE
    SPORLEDER
    )
    )
    Respondents
    )
    )
    RESPONDENTS’
    ANSWERS
    TO
    COMPLAINANTS’
    REOUEST TO
    PRODUCE
    Now
    come
    the
    Respondents,
    LAWRENCE
    and
    MARLkNE
    SPORLEDER,
    and in
    answer
    to
    Complainants’
    Request
    to
    Produce,
    provide
    the
    following:
    1.
    With
    regard
    to the
    motorized
    vehicles
    that
    have
    been
    ridden,
    and
    or
    operated,
    on
    your
    property from
    within
    70
    to
    160
    feet
    of
    the complainant’s
    residence,
    during
    the
    past
    10
    years,
    please
    provide
    documentation
    relating
    to,
    and
    confinnation
    of, factory
    installed
    mufflers
    for
    each
    vehicle.
    ANSWER:
    Respondents
    are
    not
    in
    possession
    of any
    documentation
    relating
    to,
    and
    conlinnation
    of,
    factory
    installed
    mufflers
    for
    each
    vehicle.
    Respondents
    reserve
    the
    right
    to
    supplement
    their
    answer.

    VERIFICATION
    BY CERTIFICATION
    Under
    penalties
    as provided
    by law
    pursuant
    to
    Section
    109
    of
    the Code
    of Civil
    Procedure,
    the
    undersigned
    certifies
    that
    the
    statements set forth in
    this instrument are
    true,
    correct,
    and
    complete,
    except
    as to
    matters therein
    stated
    to
    be on information
    and belief and
    as to
    such
    matters
    the
    undersigned
    certifies
    as aforesaid
    that he verily believes
    the
    same
    to
    be true.
    r)1
    MARTANE
    SPORLEDE
    SUBSCRIBED
    AND
    SWORN
    TO
    before
    me this
    day
    of
    MADSEN, SUGDEN
    & GOTTEMOLLER
    Attorneys
    for
    Respondents
    One
    North
    Virginia Street
    Crystal
    Lake,
    IL
    60014
    (815)459-5152
    2.
    Please provide
    any
    documentation,
    which
    will
    form the
    basis
    of
    your
    denials
    of
    complainant’s
    allegations
    of air and
    noise
    pollution
    violations.
    ANSWER:
    Investigation continues.

    CLERI<’S
    OFpr
    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    1
    6
    2002
    STATE
    OF
    IWNOJS
    PoJ!tj
    MILTON
    C.
    and
    VIRGINIA
    L.
    KAMHOLZ
    )
    0
    Con
    trol
    B
    Oar
    )
    Complainants
    )
    )
    v.
    )
    PCB02-4
    1
    )
    (Citizens
    Enforcement
    Air,
    Noise)
    LAWRENCE
    and
    MARIANE
    SPORLEDER
    )
    )
    Respondents
    )
    )
    RESPONDENTS’
    ANSWERS
    TO
    COMPLAINANTS’
    INTERROGATORIES
    Now
    come
    the
    Respondents,
    LAWRENCE
    and
    MARIANE
    SPORLEDER,
    and
    in
    answer
    to
    Complainants’
    Request
    to
    Produce,
    provide
    the
    following:
    (1)
    Please give
    the
    names
    and
    addresses
    of
    the
    people
    who
    have
    ridden
    or
    operated
    a
    motorized
    vehicle
    on
    your
    property
    during
    the
    past
    10
    years
    with
    in
    a
    range
    of
    70
    to
    160
    feet
    of
    the
    complainant’s
    residence.
    ANSWER:
    Friends
    of family
    and
    family including
    Lawrence
    and
    Mariann
    Sporleder.
    We
    cut
    grass
    up
    by
    the
    fence
    line
    and
    use
    the
    ATV
    to
    water
    the
    evergreens
    that
    we
    planted.
    (2)
    Please give
    the
    following
    information
    about
    all
    of
    the
    motorized
    vehicles,
    on
    or
    off
    road,
    that
    have
    been
    operated
    on
    your
    property
    within
    the
    range
    of
    70
    to
    160
    feet
    of
    the
    complainants’
    residence,
    during
    the
    past
    10
    years.
    (a)
    The
    model
    of
    the
    vehicle
    (b)
    The
    manufacturer
    of
    the
    vehicle
    (c)
    The
    year
    of
    the
    vehicle
    (d)
    The
    engine
    size
    of
    the
    vehicle
    (e)
    The
    engine
    type
    (2
    cycle
    or
    4
    cycle)
    ANSWER:
    1996
    Kawasaki
    — KX250-2cycle
    1993
    Polaris
    —350
    Trail
    Boss-2cycle
    1993
    Suziki-RM
    250-2
    cycle
    Two
    4
    cycle
    go-karts
    Respondents
    reserve
    the
    right
    to
    supplement
    their
    answer.

    •1
    (3)
    Please
    state
    which
    vehicles
    are,
    or
    were,
    equipped
    with
    (a)
    factory
    installed
    muffler
    (b)
    a
    spark
    arrester
    ANSWER:
    All
    vehicles
    have
    standard
    factory
    equipment.
    A
    spark
    arrester
    is
    not
    required
    for
    the
    type
    of
    riding
    the
    vehicles
    were
    used
    for.
    (4)
    Please
    state
    why,
    since
    the
    year
    2000,
    do
    you
    only
    allow
    the
    operation
    of
    the
    motorized
    vehicles
    to
    take
    place
    between
    the
    daytime
    hours
    of
    10
    am
    and
    8
    pm?
    ANSWER:
    The
    time
    frame
    was
    a
    rule
    we
    imposed
    on
    the
    riders.
    (5)
    During
    the
    past
    10
    years,
    have
    you
    ever
    had
    a
    designated
    area
    on
    your
    property
    that
    was
    of
    a
    certain
    oval
    or
    round
    shape,
    free
    of
    sod,
    and
    used
    specifically
    for
    the
    purpose
    of
    riding
    recreational
    vehicles
    on
    it?
    ANSWER:
    Yes.
    (6)
    During
    the
    past
    10
    years,
    were
    you
    ever
    made
    aware
    of,
    and
    asked
    to
    address
    a
    noise
    problem
    that
    was
    being
    caused
    by
    the
    operation
    of
    a
    motorized
    vehicle
    on
    your
    property?
    ANSWER:
    Yes
    (7)
    During
    the
    past
    10
    years,
    has
    the
    complainant,
    any
    member
    of
    the
    complainants’
    family,
    or
    anyone
    else,
    operated
    a
    motorcycle,
    ATV,
    go
    kart,
    or
    any
    other
    off
    the
    road
    vehicle,
    either
    on
    their
    ownproperty,
    or
    on
    yours?
    Is
    so,
    please
    state:
    (a)
    The
    name
    and
    address
    of
    operator
    (b)
    Date
    and
    time
    of
    operation
    (c)
    The
    type
    of
    vehicle
    operated
    ANSWER:
    Complainants
    operated
    a
    golf
    cart,
    and
    lawn
    tractor
    over
    the
    last
    10
    years.
    Children
    of
    complainants’
    rode
    mini-bikes

    (8)
    During
    the
    past
    10
    years,
    have
    your
    2
    grandsons,
    Donald
    and
    Kelly,
    lived
    with
    you
    in
    your
    home?
    If
    so
    please
    state:
    (a)
    The
    years,
    and
    how
    many
    months
    of
    each
    year
    stated:
    ANSWER:
    The
    interrogatory
    is
    beyond
    the
    scope
    of
    permissible
    questions,
    and
    Respondent
    object
    on
    those
    grounds.
    (9)
    Were
    you,
    and/or
    the
    operators
    other
    vehicles,
    aware
    that
    the
    complainants
    were
    taking
    decibel
    readings
    while
    the
    riding
    was
    taking
    place?
    ANSWER:
    No
    (10)
    Please
    give
    the
    names
    and
    addresses
    of
    the
    riders
    and
    drivers,
    operating
    motorized
    vehicles
    on
    your
    property
    on
    Mother’s
    Day,
    May
    13,
    2001.
    ANSWER:
    Don
    Peterson,
    Woodstock,
    IL
    Matt
    Mullin,
    Woodstock,
    IL
    Tammy
    Lane,
    McHenry,
    IL
    Clayton
    Lane,
    McHenry,
    IL
    Alyssa
    Lane,
    McHenry,
    IL
    SpencerLane,
    McHenry,
    IL
    Mariarm
    Sporleder,
    Woodstock,
    IL
    Kelly
    Krampotich,
    Woodstock,
    IL
    (11)
    Of
    all
    of
    the
    motorized
    vehicles
    that
    have
    been
    operated
    on
    your
    property
    during
    the
    past
    10
    years,
    within
    the
    range
    of
    70
    to
    160
    feet
    of
    the
    complainant’s
    residence,
    were
    any
    of
    them,
    or
    are
    any
    of
    them
    now,
    EPA
    legal?
    ANSWER:
    Yes
    (12)
    Please
    state
    the
    reason
    for
    not
    responding,
    as
    directed,
    to
    the
    complainant’s
    complaint
    last
    September,
    October,
    November,
    and
    December,
    of
    2001,
    and
    up
    to
    the
    end
    of
    February,
    of
    2002?
    ANSWER:
    Notice
    was
    first
    received
    in
    December,
    via
    personal
    delivery.
    At
    which
    time
    we
    responded
    after
    the
    February
    7,
    2002
    telephone
    conference.

    -
    I
    (13)
    Is
    the
    newly
    excavated
    area, cleared
    of
    sod,
    and
    strategically
    placed
    dirt
    mounds,
    on
    your
    property,
    the
    beginning
    of
    a
    new
    dirt bike
    track?
    ANSWER:
    The
    interrogatory
    is
    beyond the
    scope
    of
    permissible
    questions,
    and
    Respondent
    object
    on
    those
    grounds.
    (14)
    Have
    you
    discussed
    the
    complainant’s
    noise
    and air
    allegations
    with
    your
    friend
    and
    neighbor,
    Mr.
    Price?
    ANSWER:
    Yes.
    (15)
    What
    did you
    tell
    Sheriff
    Deputy,
    Anthony
    Pena,
    when
    he
    came
    to
    talk
    to
    you
    on
    the
    evening
    of
    Wednesday,
    May
    16, 2002,
    regarding
    the
    noise
    complaint
    of
    Mother’s
    Day,
    May
    13, 2001?
    Please
    state
    what
    you
    told
    him
    about
    the
    complainants?
    ANSWER:
    Respondents
    do
    not
    have
    any
    recollection
    of
    what
    was
    said
    during
    the
    conversation.
    If
    a
    report
    was
    written,
    one
    can
    be
    obtained
    from
    the
    Sheriff’s
    Department.
    (16)
    Please
    provide
    the
    name
    and
    addresses
    of
    each
    witness
    who
    will
    testify
    at
    trial,
    and
    state
    the
    subject
    matter
    of
    each
    witness’
    testimony.
    ANSWER:
    Tammy
    and
    Clayton
    Lane,
    McHenry,
    Illinois
    Don
    Peterson,
    Woodstock,
    Illinois
    Matt
    Mullin,
    Woodstock,
    Illinois
    Mariann
    and
    Larry
    Sporleder,
    Woodstock,
    Illinois
    Each
    witness
    will
    testify
    to
    the
    history
    and
    their
    involvement
    of
    operating
    motorized
    vehicles
    on
    Respondents’
    property.
    If
    so
    questioned,
    each
    witness
    will
    testify
    to
    the
    type
    of
    vehicle
    they
    have
    operated
    on
    Respondent’s
    property.
    Respondents
    reserve
    the
    right
    to
    supplement
    their
    answer.
    (17)
    Please
    provide
    the
    name
    and
    address
    of
    each
    opinion
    witness
    who
    will
    offer
    any
    testimony,
    and state:
    (a)
    The
    subject
    matter
    on
    which
    the
    opinion
    witness
    is
    expected
    to
    testify;
    (b)
    The
    conclusions
    andlor
    opinions
    of
    the opinion
    witnesses
    and
    the
    basis
    thereof
    including
    reports
    of
    the
    witnesses,
    if
    any;
    (c)
    The
    qualifications
    of
    each
    opinion
    witness,
    including
    a
    curriculum
    vitae
    and/or
    resume,
    if
    any;
    and

    (d)
    The
    identity
    of
    any
    written
    reports
    of
    the
    opinion
    witnesses
    regarding
    this
    occurrence.
    ANSWER:
    Investigation
    continues.

    VERIFICATION
    BY
    CERTIFICATION
    Under
    penalties
    as provided
    by law pursuant
    to
    Section
    109
    of
    the Code
    of Civil
    Procedure,
    the
    undersigned
    certifies that
    the
    statements
    set forth in
    this
    instrument
    are
    true,
    correct,
    and
    complete,
    except
    as
    to
    matters
    therein
    stated to be
    on
    information
    and
    belief
    and as to
    such
    matters
    the
    undersigned
    certifies as
    aforesaid
    that he
    verily believes
    the same
    to be true.
    L
    WRENCE
    SPOR EDER
    N
    MARIANE
    SPORLEDER
    SUBSCRIBED
    AND
    SWORN
    TO
    before
    me this
    day
    of
    N
    ublic
    -I
    MADSEN,
    SUGDEN
    &
    GOTTEMOLLER
    Attorneys
    for
    Respondents
    One
    North
    Virginia
    Street
    Crystal
    Lake, IL
    60014
    (815)459-5152

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    MILTON
    C.
    and
    VIRGINIA
    L.
    KAMHOLZ
    )
    )
    Complainants
    )
    )
    v.
    )
    PCBO2-41
    )
    (Citizens
    Enforcement
    Air,
    Noise)
    LAWRENCE
    and
    MARIANE
    SPORLEDER
    )
    )
    Respondents
    )
    )
    PROOF
    OF
    SERVICE
    TO:
    Milton
    and
    Virginia
    Kaniholz
    1306
    Sullivan
    Rd
    Woodstock,
    IL
    60098
    I,
    KEITH
    SLOAN,
    on
    oath
    state
    that
    I
    mailed
    Respondents
    Answers
    to
    Interrogatories
    and
    Request
    to
    Produce
    to
    the
    party
    to
    whom
    it
    is
    directed
    by
    re,gular
    mail
    by
    depositing
    the
    same
    in
    the
    U.S.
    Mail
    at
    Crystal
    Lake,
    Illinois,
    on
    the
    ,
    day
    of
    ,4iA
    ,
    2002,
    at
    approximately
    5:00
    p
    .m.
    with
    proper
    postage
    prepaid.
    KEITH
    SLOAN
    SUBSCRIBED
    AND
    SWORN
    TO
    before
    me
    this
    day
    of
    vY),Th-1
    ,2002
    -
    PATRICIA
    A
    SCHMITT
    Y
    PUBUC,
    STATE
    OF
    IUJN
    Notary
    Public
    MY
    COMMteSON
    EXPmE8:O7l2e,o
    MADSEN,
    SUGDEN
    &
    GOTTEMOLLER
    Attorneys
    for
    Respondents
    One
    North
    Virginia
    Street
    Crystal
    Lake,
    IL
    60014
    (815)459-5152

    BEFORE
    TIlE
    ILLINOIS
    POLLUTION CONTROL
    BOAR])
    MILTON
    and VIRGINIA KAMHOLZ
    Complainants
    LAWRENCE
    and
    MARIANE
    SPORLEDER
    Respondents
    )
    )
    )
    )
    )
    PCB
    02---41
    (Citizen’s
    Enforcement,
    Noise,
    Air)
    )
    )
    )
    )
    )
    )
    )
    PROOF
    OF
    SERVICE
    I,
    the
    undersigned,
    on oath,
    state
    that
    I served
    the attached
    Notice
    of
    Filing,
    to
    the
    Clerk
    of
    the
    Board
    ,and
    a Motion
    to
    Compel
    ,for
    Request
    to
    Produce,
    and
    Interrogatories
    to
    be
    answered
    by
    Respondents,
    directed
    to
    Hearing
    Officer
    Bradley
    Halloran,
    upon
    the
    following
    persons
    by Certified
    Mail
    on this
    date
    of
    May
    15,
    2002.
    The
    Clerk
    ofthe
    Board
    Illinois
    Pollution
    Control
    Board
    James
    R.
    Thompson
    Center,
    Suite
    11-500
    100
    W. Randolph
    Street
    Chicago,
    Illinois
    60601
    Joseph
    Gottemoller
    One North
    Virginia
    Street
    Crystal
    Lake,
    illinois
    60014
    Bradley
    P. Halloran,
    Hearing
    Officer
    Illinois
    Pollution
    Control
    Board
    James
    R. Thompson
    Center,
    Suite
    11-500
    100
    W. Randolph
    Street
    Chicago,
    Illinois
    60601
    “OFFICIAL
    SEAL”
    SHERALyNN
    F.
    THUROW
    Notary
    Public,
    State
    of
    Illinois
    My
    Commission
    Exp.
    02/05/2005
    Milton
    and
    Virginia
    Kamholz
    1306
    Sullivan
    Road
    Woodstock,
    Illinois
    60098
    (815) 568
    6166
    v.
    SUBSCRIBED
    AI%D
    SWORN
    TO
    BEFORE
    ME
    TIllS
    OF

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