- FBEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
v.
- NORTHERN ILLINOIS
SERVICE COMPANY,
Respondent.
- 87-12-AC)
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RESPONDENT'S MEMORANDUM OF LAW IN RESPONSE TO
COMPLAINANT'S MOTION FOR SUMMARY JUDGMENT
NOW COMES the respondent, NORTHERN ILLINOIS SERVICE COMPANY,
("NORTHERN") by its attorney, Peter DeBruyne, P.C.
- and for its Memorandum of Law in
Response to Complaint's Motion for Summary Judgment, states as follows:
I.
- FACTS
A.
- Background Facts. (Deposition of Paul Munson, ("Munson Dep."), p. 11 ").
Hoff runs the field; Paul Mun...
AC 12-51,040714 NISCmemorandum 
