BEFORE THE
ILLINOIS POLLUTION
CONTROL BOARD
CLERK’S
OFFICE
PEOPLE OF
THE STATE OF
ILLINOIS
)
JUL
272005
Complainant,
STATE OF
ILLINOIS
Pollution
Control
Board
v.
)
No.
04-84
)
(Enforcement
-
Water)
PARAMOUNT DEVELOPERS, INC.
)
an Illinois
Corporation,
)
)
Respondent.
)
NOTICE
OF FILING
To:
See attached Service List
PLEASE TAKE NOTICE that on the 27th day of July, 2005, the People ofthe State ofIllinois,
filed with
the
Illinois
Pollution
Control
Board,
a MOTION
FOR
RELIEF FROM
HEARING
REQUIREMENTand a STIPULATION AND PROPOSAL FOR SETTLEMENT, trueand correct
copies ofwhich
are attached hereto and
is hereby served upon you.
PEOPLE OF THE STATE
OF ILLINOIS,
ex rel.
LISA MADIGAN, Attorney General
ofthe
te of Illinois
By:
_______________________
‘George
~.
Theophilos
Assistant Attorney General
Environmental Bureau
188 West Randolph Street,
20th
Fl.
Chicago,
IL 60601
(312) 814-6986
DATE:
July 27, 2005
THIS FILING IS SUBMITTED ON RECYCLED PAPER
SERVICE LIST
Mr. Bradley P. Halloran, Esq.
Hearing Officer
Illinois Pollution Control Board
James R.
Thompson Center
100
W. Randolph Street, Suite 11-500
Chicago, IL 60601
Mr. Charles Gunnarson, Esq.
Illinois Environmental Protection Agency
1021
North Grand Avenue East
P.O. Box
19276
Springfield,
IL 62794-9276
Mr.
Kim R. Denkwalter, Esq.
Paramount Developers, Inc.
5215 Old Orchard Rd., Suite 1010
Skokie, IL 60077
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
A
E
CE! V E D
CLERK’S OFFICE
PEOPLE OF THE STATE OF ILLINOIS,
)
JUL
272005
Complainant,
STATE OF
ILLINOIS
Pollution Control Board
)
)
v.
)
PCB 04-84
)
PARAMOUNT DEVELOPERS, INC., an
)
(Enforcement
-
Water)
Illinois Corporation,
)
)
Respondent.
)
MOTION FOR RELIEF
FROM
HEARING REQUIREMENT
NOW
COMES
the
Complainant,
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
by
LISA
MADIGAN, Attorney General of the
State of Illinois,
and
hereby moves
for relief from
the hearing
requirement
in
this
case pursuant
to
Section
31 (c)(2) of the
Illinois
Environmental Protection
Act
(“Act”),
415
ILCS
5131(c)(2)
(2002),
and
Section
103.300 of the Illinois
Pollution
Control Board
(“Board”) Procedural Rules, 35
Ill.
Adm, Code
103.300.
In support of this Motion, the Complainant
states as follows:
1.
Section
31 (c)(2) of the Act allows the parties in certain enforcement cases to request
relief from the mandatory hearing requirement where the parties submit to the Board a Stipulationand
Proposal
for Settlement.
Section 31(c)(2) provides as follows:
Notice; complaint; hearing.
*
*
*
(c)(2) Notwithstanding the provisions ofsubdivision (1) ofthis subsection (c), whenever
a
complaint
has been
filed on
behalf ofthe Agency or by
the People of the
State of
Illinois,
the parties may file with the Board
a stipulation and
proposal
for settlement
accompanied by
a
request for
relief from
the requirement of a
hearing pursuant
to
subdivision (I). Unless the Board, in its discretion, concludes that a hearingwill be held,
the Board
shall cause notice of the stipulation, proposal
and
request for relief to
be
1
published and sent in the samemanner as is required for hearing pursuant to subdivision
(1) of this subsection. The notice shall include a statement that
any person may file a
written demand forhearing within 21 days afterreceiving the notice. Ifany person files
a timely written demand for hearing, the Board shall deny the request forrelief from a
hearing and shall hold a hearing in
accordance with the provisions ofsubdivision (1).
2.
Board
Procedural Rule
103.300
provides,
in
relevant part,
as
follows
(emphasis
in
original):
Request for Relief from Hearing Requirement in State Enforcement Proceeding.
(a) Whenevera complaint has beenfiled on behaifoftheAgency orby the People ofthe
State of illinois,
the parties
may file
with
the Board
a
proposed
stipulation
and
settlement
accompanied by
a
request for
relieffrom
the
requirement of a
hearing
pursuant to Section
31 (c)(2) ofthe Act.
.
3.
On November 24, 2003, the Complaint in this matter was filed with the Board.
4.
Subsequently, theparties to this action reached agreement on a Stipulation and Proposal
For Settlement,
which
is
being filed with
the Board
concurrently
with this
motion.
No hearing
is
currently
scheduled in this case.
WHEREFORE,
the
Complainant,
PEOPLE
OF
THE
STATE
OF
ILLINOIS,
by
LISA
MADIGAN, Attorney General ofthe State ofIllinois, respectifilly moves for relief from therequirement
of a hearing pursuant to
Section
31 (c)(2) of the Act
and Board Procedural Rule
103.300.
Respectflully submitted,
PEOPLE OF THE STATE OF
ILLINOIS,
by
MADIGAN, Attorney General
o
h
t
e(p\f
linois
/
~
BY:
)
GEO~9~D.
THEOPWLOS
Assistant Attorney General.
Environmental Bureau/North
188 West Randolph Street, Suite 2001
Chicago, Illinois 60601
DATE: July 27, 2005
312-814-6986
2
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOAPDRECEIVED
CLERK’S OFFICE
PEOPLE OF THE STATE OF ILLINOIS,
)
III!
~
ex
rel.
LISA MADIGAN, Attorney
)
.JteL
£
1
2005
General
of the State of Illinois
)
STATEOFILLINOIS
Pollution Control Board
Complainant,
PCB No.
04-84
(Enforcement
-
Water)
v.
PARAMOUNT DEVELOPERS,
INC.,
an Illinois Corporation.
Respondent.
STIPULATION AND PROPOSAL FOR SETTLEMENT
Complainant,
PEOPLE OF THE STATE OF ILLINOIS,
by LISA MADIGAN,
Attorney
General
of
the
State
of
Illinois
and
the
Illinois
Environmental
Protection Agency
(“ILLINOIS
EPA”),
and PARAMOUNT
DEVELOPER’S,
INC.,
an Illinois Corporation,
(“Respondent”),
have
agreed
to
the
making
of
this
Stipulation
and
Proposal
for
Settlement
(“Stipulation”)
and submit it to the Illinois Pollution
Control Board
(“BOARD”)
for approval.
The parties agree that the
statement of facts
contained herein represents a fair summary of
the evidence and testimony which would be introduced by the parties
if a hearing were held.
The parties further stipulate that this
statement
of
facts
is
made
and
agreed
upon
for
purposes
of
settlement only and that neither the fact that a party has entered
into this
Stipulation,
nor any of
the
facts
stipulated
herein,
1
shall be introduced into evidence in any other proceeding regarding
the claims asserted in the Complaint,
except as otherwise provided
herein.
If
the Board approves
and enters this Stipulation,
the
Respondent
agrees to be bound by the Stipulation and Board Order
and not to contest their validity in any subsequent proceeding to
implement or enforce their terms.
I.
JURISDICTION
The Board has jurisdiction of the subject matter herein and of
the
parties
consenting
hereto
pursuant
to
the
Illinois
Environmental Protection Act
(“Act”)
,
415 ILCS 5/1 et
seq.
(2002)
II.
AUTHORIZATION
The undersigned representatives for each party certify that
they are fully authorized by the party whom they represent to enter
into the terms and conditions of
this Stipulation and to legally
bind them to it.
III. STATEMENT OF FACTS
A.
Parties
1.
On November 24,
2003,
a Complaint was filed on behalf of
the
People
of
the
State
of
Illinois by Lisa Madigan,
Attorney
General of the State
of Illinois,
on her own motion and upon the
request of the Illinois EPA, pursuant to Section 31 of the Illinois
2
Environmental Protection Act
(“Act”),
415 ILCS 5/31(2002),
against
the Respondent.
2.
The Illinois EPA is an administrative agency of the State
of Illinois,
created pursuant to Section 4 of the Act,
415 ILCS 5/4
(2002)
3.
At
all
times
relevant
to
the
Complaint,
Respondent
was
and is an Illinois corporation in good standing, and is authorized
to transact business in the State of Illinois.
B.
Site Description
1.
At all times relevant to the Complaint,
Respondent was a
developer
of
residential
homes,
at
the
Hatch
Farm development
located in Section 15, Township 38 North,
Range 10 East in Lisle,
DuPage
County,
Illinois
(“Site”)
.
Water
from storm
sewers
and
other areas of
the Site discharges into a pond and wetland area.
Water
from
the pond and wetland
area
discharges
into
the
East
Branch of the DuPage River.
2.
The
Illinois EPA granted Respondent
coverage under the
general National Pollutant Discharge Elimination System storm water
permit for construction site activities
(“general NPDES permit”).
The permit was effective from June
1,
1998 until May 31,
2003.
3.
The provisions and conditions
of Respondent’s general
NPDES
permit
required
Respondent
to,
inter
alia,
develop
and
implement
a
water
pollution
plan
in
accordance
with
good
3
engineering practices for
each construction site covered by the
permit.
4.
Complainant contends that:
a.
Respondent
failed to monitor the Site as required by
the general NPDES permit;
b.
Respondent failed to install adequate stormwater
controls when excessive
erosion was evident,
as required
by the general NPDES permit;
c.
On or about July 19,
2001,
Respondent caused,
threatened,
or allowed erosion of
loose dirt and
silt,
and poor to nonexistent erosion control measures at the
Site;
d.
As of August
7,
2001,
Respondent had taken few,
if
any,
actions to install
improved erosion control
measures
at
the Site,
there was no silt fencing around
large piles of dirt on the Site,
filters on storm sewer
inlets were either shredded or improperly installed, and
there was substantial soil erosion at the Site;
e.
On August
16,
2001,
Respondent had caused,
threatened or allowed an excessive amount of loose dirt
and silt at the Site to wash off into unprotected storm
sewers and that the Respondent had not installed any
improved erosion control measures;
4
f.
On May
9,
2002,
Respondent had not installed silt
fencing sufficient to adequately control erosion; and
g.
On May 12, 2003,
areas of the Site remained either
without control measures or with inadequate controls to
prevent Site silt discharges to Illinois waters.
C.
Allegations
of
Non-Compliance
Complainant
contends
that
the
Respondent
has
violated the
following provisions of the Act and regulations of the Board:
Count
I:
Water Pollution,
in violation of Section 12(a)
of
the Act, 415 ILCS 5/12(a)
(2002).
Count
II:
Water
Pollution,
in violation of Section 12(d)
of
the Act,
415 ILCS 5/12(d)
(2002).
Count III:
NPDES Storm Water Permit Violation,
in violation of
Section 12(f)
of the Act,
415 ILCS 5/12(f)
(2002),
and Sections 309.102(a)
and 309.146(a) (1)
and
(2)
of the Board’s Water Pollution Regulations,
35
Ill.
Adm. Code 309.102(a)
and 309.146 (a) (1) and
(2).
Count IV:
Failure
to
Maintain
Reliable
Pollution
Control
Systems,
in violation of 12(a)
of the Act,
415 ILCS
5/12(a)
(2002),
and
Section
306.102(a)
of
the
Board’s Water Pollution Regulations,
35
Ill.
Adm.
Code 306.102(a).
5
D.
Admission
of
Violations
The
Respondent
represents
that
it
has
entered
into
this
Stipulation for the purpose of settling and compromising disputed
claims without having to incur the expense of contested litigation.
By entering into this Stipulation and complying with its terms,
the
Respondent neither admits nor denies the violations alleged in the
Complaint and referenced in Section III.
C. herein.
E.
Compliance Activities
to Date
Erosion control from construction activities
is no longer
a
concern because the Respondent’s site has now been developed with
residential homes.
IV.
APPLICABILITY
This
Stipulation
shall
apply
to
and
be
binding
upon
the
Complainant and the Respondent,
and any officer, director,
agent,
or employee of the Respondent,
as well as any successors or assigns
of the Respondent.
The Respondent shall not raise as
a defense to
any
enforcement
action
taken
pursuant
to
this
Stipulation
the
failure
of
any
of
its
officers,
directors,
agents,
employees,
successors or assigns to take such action as shall be required to
comply with the provisions
of
this
Stipulation.
No
change
in
ownership, corporate status or operator of the company shall
in any
way
alter
the
responsibilities
of
the
Respondent
under
this
Stipulation and Proposal for Settlement.
Respondent shall continue
6
to be bound by and remain liable for performance of all obligations
under
this
Stipulation.
V.
COMPLIANCE WITH OTHER LAWS AND REGULATIONS
This Stipulation in no way affects the responsibilities of the
Respondent to comply with any other federal,
state or local laws or
regulations
including,
but not limited to,
the Act and the Board
regulations,
35
Ill. Adm.
Code,
Subtitles A through
H.
VI.
IMPACT ON THE PUBLIC RESULTING FROM ALLEGED NON-COMPLIANCE
Section 33(c)
of the Act, 415 ILCS 5/33 (c) (2002)
,
provides as
follows:
In making its orders and determinations,
the Board shall
take into consideration all the facts and circumstances
bearing
upon
the
reasonableness
of
the
emissions,
discharges,
or
deposits
involved
including,
but
not
limited to:
1.
The
character
and
degree
of
injury
to,
or
interference
with
the
protection
of
the
health,
general
welfare
and
physical
property
of
the
people;
2.
The
social
and economic
value
of
the
pollution
source;
3.
The suitability or unsuitability of
the pollution
source
to
the
area
in
which
it
is
located,
including the question of priority of
location in
the area involved;
4.
The
technical
practicability
and
economic
reasonableness
of
reducing
or
eliminating
the
emissions,
discharges
or
deposits
resulting
from
such pollution source;
and
7
5.
Any subsequent compliance.
-
In response to these factors,
the parties state the following:
1.
The
discharge
of
pollutants
in
stormwater
associated with construction activities at the Site
posed,
at a minimum,
a threat to the environment.
2.
There
is
a
social
and
economic
benefit
to
the
residential
development
constructed
by
the
Respondent.
3.
The
residential
development
involved
in
this
matter
is
suitable
for
the
area
where
the
discharges
occurred.
4.
Complying with the requirements of the Act,
Board
regulations,
and permit conditions was both
technically practicable and economically
reasonable.
5.
With
the
completion
of
the
development
and
the
ceasing of development operations, Respondent
is no
longer in violation of the Act.
VII. CONSIDERATION OF SECTION 42(h)
FACTORS
Section 42W)
of the Act,
415 ILCS 5/42W) (2002),
provides as
follows:
In
determining
the
appropriate
civil
penalty
to
be
imposed under this Section,
the Board is authorized to
consider
any
matters
of
record
in
mitigation
or
8
aggravation of penalty, including but not limited to the
following factors:
1.
The duration and gravity of the violation;
2.
The presence or absence
of
due diligence
on the
part of the respondent in attempting to comply with
requirements of this Act and regulations thereunder
or to secure relief
therefrom as provided by this
Act;
3.
Any
economic
benefits
accrued by
the
respondent
because of delay
in compliance with requirements,
in
which
case
the
economic
benefits
shall
be
determined
by
the
lowest
cost
alternative
for
achieving compliance;
4.
The amount of monetary penalty which will serve to
deter further violations by the respondent
and to
otherwise
aid
in
enhancing
voluntary
compliance
with this Act by the respondent and other persons
similarly subject to the Act;
5.
The
number,
proximity
in
time,
and
gravity
of
previously
adjudicated violations
of
this Act by
the respondent;
s.
whether the respondent voluntarily self-disclosed,
in accordance with subsection
i
of
this
Section,
the non-compliance to the Agency; and
7.
Whether the
respondent has
agreed to undertake a
“supplemental
environmental project,”
which means
an
environmentally
beneficial
project
that
a
respondent agrees to undertake in settlement of an
enforcement
action
brought
under
this
Act,
but
which
the
respondent
is
not
otherwise
legally
required to perform.
In response to these
factors,
the parties state as follows:
1.
The
Complainant alleges
that Respondent’s failure
to implement adequate erosion control measures was
in
direct
contravention
of
the
general
NPDES
9
permit.
It
appears
that
many
areas
of
the
site
remained without erosion control measures or with
inadequate
controls
during
the
period
of
time
between
July
19,
2001,
and
May
12,
2003.
2.
In failing to take adequate stormwater pollution
prevention controls at the Site over the course of
approximately 22 months,
the Respondent
demonstrated an absence of due diligence.
3.
The
Respondent
likely
enjoyed
some
financial
benefit,
but
the
penalty
obtained
negates
the
economic benefit accrued as
a result of the delay
in compliance.
4.
The
Complainant
believes
that
a
$12,000.00
civil
penalty should deter the Respondent and similarly
situated
developers
from
allowing
poor
erosion
control
practices
and
excessive
silt-laden
stormwater discharges associated with construction
activities in the future.
5.
Complainant
is
presently
unaware
of
prior
enforcement action against Respondent.
6.
Self-disclosure did not occur in this matter.
7.
The
settlement
of this matter does not
include
a
supplemental environmental project.
10
VIII.
TERMS
OF
SETTLEMENT
A.
Penalty
Payment
1.
The Respondent shall pay
a civil penalty in the sum of
Twelve Thousand Dollars
($12,000)
within thirty
(30)
days from the
date
the
Board
adopts
and
accepts
this
Stipulation.
The
Respondent
stipulates that payment has been tendered to Respondent’s attorney
of record in this matter in
a form acceptable to that
attorney.
Further, Respondent stipulates that said attorney has been directed
to make the penalty payment on behalf of Respondent, within thirty
(30)
days
from
the
date
the
Board
adopts
and
accepts
this
Stipulation,
in a manner prescribed below.
The penalty described
in this Stipulation shall be paid by certified check, money order
or
electronic
funds
transfer
payable
to
the
Illinois
EPA,
designated to the Illinois Environmental Protection Trust Fund and
submitted to:
Illinois Environmental Protection Agency
Fiscal Services Section
1021 North Grand Avenue East
P.O. Box 19276
Springfield,
IL 62794-9276
The name and number of the case and Respondent’s Federal Employer
Identification Number
(FEIN)
shall appear on the check.
A copy of
the certified
check,
money order or
record of
electronic
funds
transfer and any transmittal letter shall be sent to:
11
George Theophilos
Assistant Attorney General
Environmental Bureau
188
W.
Randolph St.,
20th
Floor
Chicago, Illinois 60601
2.
Pursuant
to Section 42(g)
of the Act,
415 ILCS 5/42(g)
(2002),
interest shall
accrue on any payment not paid within the
time
period
prescribed
above
at
the
maximum
rate
allowable
under
Section
1003(a)
of
the
Illinois
Income
Tax Act,
35
ILCS
5/1003
(2002).
Interest on any unpaid payment shall begin to accrue from
the date the payment is due and continue to accrue until the date
payment
is
received.
When
partial
payment(s)
are
made,
such
partial payment shall be first
applied to any interest on unpaid
payment
then
due
and
owing.
All
interest
on
payment
owed
shall
be
paid by certified check, money order or electronic funds transfer,
payable
to
the
Illinois
EPA,
designated
to
the
Illinois
Environmental Protection Trust Fund and delivered to the address
and in the manner described above.
3.
For purposes of payment and collection, Respondent may be
reached at the following address:
Kim R. Denkewalter,
Esq.
Paramount Developers,
Inc.
5215 Old Orchard RD,
STE 1010
Skokie,
Illinois,
60077-0000
4.
In
the
event
of
default
of
this
Section
VIII.A,
the
Complainant
shall be entitled to all available relief including,
12
but not limited to, reasonable costs
of collection and reasonable
attorney’s
fees.
B.
Future
Use
Notwithstanding any other language
in this Stipulation to the
contrary,
and
in
consideration
of
the
mutual
promises
and
conditions
contained in
this
Stipulation,
including
the Release
from Liability contained in Section VIII.D,
below,
the Respondent
hereby
agrees
that
this
Stipulation
may
be
used
against
the
Respondent
in
any
subsequent
enforcement
action
or
permit
proceeding as proof of a past adjudication of violation of the Act
and the Board Regulations promulgated thereunder for all violations
alleged in the Complaint in this matter,
for purposes of Section
39(a)
and
(i)
and/or
42(h)
of
the
Act,
415
ILCS
5/39(a)
and(i)
and/or
5/42 (h) (2002).
Further,
Respondent
agrees
to waive
any
rights to contest,
in any subsequent enforcement action or permit
proceeding,
any allegations
that
these
alleged violations
were
adjudicated.
C.
Cease and Desist
The Respondent
shall cease and desist from future violations
of the Act and Board Regulations that were the subject matter
of
the Complaint as outlined in Section III.C
(“Allegations of Non-
Compliance”)
of this Stipulation.
13
D.
Release from Liability
In consideration of
the Respondent’s payment of the Twelve-
Thousand Dollar
($12,000.00)
penalty and any specified costs and
accrued interest,
commitment
to Cease and Desist as contained in
Section VIII.C and upon the Pollution Control
Board’s acceptance
and
approval
of
the terms
of this Stipulation and
Proposal
for
Settlement,
the Complainant
releases,
waives and discharges
the
Respondent
from
any
further
liability
or
penalties
for violations
of the Act
and Board Regulations that were the subject matter of
the Complaint herein.
The release set forth above does not extend
to
any
matters
other
than
those
expressly
specified
in
Complainant’s
Complaint
filed
on
November
24,
2003.
The
Complainant reserves, and this Stipulation is without prejudice to,
all rights
of the State
of Illinois against
the Respondent with
respect
to all other matters,
including but
not limited to,
the
following:
a.
Criminal liability;
b.
Liability for future violation of state,
federal,
local,
and common laws and/or regulations;
c.
Liability for natural resources damage arising out of the
alleged violations; and
d.
Liability or claims based on the Respondent’s failure to
satisfy the requirements of this Stipulation.
14
Nothing
in
this
Stipulation
is
intended
as
a
waiver,
discharge,
release,
or covenant not to sue for any claim or cause
of action, administrative or judicial,
civil or criminal,
past or
future,
in law or in equity,
which the
State
of Illinois or the
Illinois EPA may have against any person,
as defined by Section
3.315
of
the
Act,
415
ILCS
5/3.315,
or
entity
other
than
the
Respondent.
E.
Enforcement of Board Order
1.
Upon
the
entry
of
the
Board’s
Order
approving
and
accepting this Stipulation and Proposal for Settlement, which Order
is
a
binding
and
enforceable
order
of
the
Illinois
Pollution
Control
Board
and may be
enforced
as
such
through any
and
all
available means.
2.
Respondent
agrees
that
notice
of
any
subsequent
proceeding to enforce the Board Order approving and accepting this
Stipulation and Proposal
for Settlement may be made by mail
and
waives any requirement of service of process.
3.
The parties agree that,
if the Board does not approve and
accept this Stipulation and Proposal for Settlement,
then neither
party is bound by the terms herein.
4.
It is the intent of the Complainant and Respondent that
the provisions of this Stipulation and Proposal for Settlement and
any Board Order accepting and approving such shall
be severable,
15
and
should
any
provision
be
declared
by
a
court
of
competent
jurisdiction to
be
inconsistent with
state
or
federal
law,
and
therefore unenforceable,
the remaining clauses shall remain in full
force and effect.
WHEREFORE,
Complainant and Respondent request that the Board
adopt
and
accept
the
foregoing
Stipulation
and
Proposal
for
Settlement as written.
PEOPLE OF THE STATE OF ILLINOIS,
LISA
MADIGAN
Attorney General
State of Illinois
MATTHEW J.
DUNN,
Chief
Environmental Enforcement/
Asbestos Litigation Division
BY:t2~~~t\Jlfr~,
k
DATE:
7
Environmental Bureau
Assistant Attorney General
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
BY:
Z4~C~
~,Lp~co,/7
DATE:
tThfrw S
act’S—
WILLIAM D.
INGERSOL
Acting Chief Legal Counsel
16
PARAMOUNT
DEVELOPERS,
INC.
BY:
KIMR.
DE KEWALTER
President
17
CERTIFICATE OF SERVICE
I,George D. Theophilos, an AssistantAttorneyGeneral, do certi&
that I causethabemailedr
this
27th
day
of
July,
2005,
the
foregoing
MOTION
FOR
RELIEF
FROM
HEARING
REOUIREMENT and
STIPULATION AND PROPOSAL FOR SETTLEMENT
tcLthe persons
listed on said Service List by first class mail in a postagepre-paid envelope
anddepiisitingsamewith
the United States Postal
Service located at
100 West Randolph Street, Chicago, Illinois
60601.
Georg
.
Theopiilos
