In response to Question 9, respondent has refused to provide complete
information on certain employees, citing Illinois Rule of Professional Conduct 4.2.
That rule does not limit the scope of discovery.
6.
Rather than prepare a separate “emergency response plan” under OSHA rules
and a “contingency plan” under Board rules, respondent appears to haveprepared a single “Emergency Response and Contingency Plan” to meet bothrequirements. PCB 05-049 ) FLEX-N-GATE CORP...
Allowed
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