BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS
)
by LISA MADIGAN, Attorney General
)
of the State of Illinois,
)
)
Complainant,
)
)
v.
)
)
MICK MORFEY, individually, and
)
WILLIAM KNAUER, individually,
)
)
Respondents.
)
PCB No. 07-144
(Enforcement - Air)
NOTICE OF ELECTRONIC FILING
,
TO: SEE ATTACHED SERVICE LIST
Please take notice that on the 21st day
of February,. 2008 I have filed with the Office of
the Clerk of the Illinois Pollution Control Board by electronic filing the following Complainant's
Motion to Deem Facts Admitted and for Summary Judgment as to Respondent William Knauer a
true and correct copy
of which is attached and hereby served upon you.
PEOPLE OF THE STATE OF ILLINOIS,
by LISA MADIGAN, Attorney General
of the State of Illinois
BY:-_~-:--~-L.H-EN-J-S---'Yi--;:!-r-LV-"'-
E-f=-T---,r~'
-----
Assistant Attorney General
Environmental Bureau
69
W. Washington St., Suite 1800
Chicago, IL 60602
(312) 814-2087
Date: February 21, 2008
Electronic Filing - Received, Clerk's Office, February 21, 2008
James Macchitelli, Esq.
Counsel for Respondent Mick Morfey
7247 W. Touhy Ave.
Chicago,
It 60631
William Knauer
9885 Prairie St.
Walker Edition
Savanna, IL 61074
Bradley Halloran
Chief Hearing Officer
Illinois Pollution Control Board
100 West Randolph Street,
11
th Floor
Chicago, IL 60601
SERVICE LIST
Dennis Brown
Assistant Counsel
Illinois EPA, Division of Legal Counsel
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
Electronic Filing - Received, Clerk's Office, February 21, 2008
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS
)
by LISA MADIGAN
Attorney General
)
of the State of Illinois
)
)
Complainant,
)
)
v.
)
)
MICK MORFEY, individually and
)
WILLIAM KNAUER, individually
)
)
Respond~nts.
)
PCB No. 07-144
(Enforcement- Air)
MOTION TO DEEM FACTS ADMITTED AND FOR SUMMARY JUDGMENT
AS TO RESPONDENT WILLIAM KNAUER
Now comes the Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General
of the State of Illinois, pursuant to Sections 103.204 and 101.516
of the Illinois Pollution Control Board'sProcedural Rules, 35 Ill. Adm. Code 103.204 and
101.516, and hereby moves for the entry
of an order deeming all material facts in Complainant's
Complaint as admitted against Respondent WILLIAM KNAUER as to Counts I through VI
of
the Complaint. Further, Complainant moves this Illinois Pollution Control Board ("Board") for
summary judgment as to Counts I through VI
of the Complaint against Respondent WILLIAM
KNAUER. In support thereof, Complainant states as follows:
1.
On June 15,2007, the Complainant filed its Complaint against Respondents
MICK MORFEY ("Morfey") individually and WILLIAM KNAUER ("Knauer") individually for
alleged violations that occurred at barracks buildings 266 and 267, situated within the former
Savanna Army Depot, Savanna, Carroll County, Illinois ("Site"). Complainant alleged violations
of Sections 9(a), 9. 1(d), 9.13(a) and 9(c) of the Illinois Environmental Protection Act ("Act"),
415 ILCS 5/9(a),
9.1 (d), 9. 13(a), 9(c) (2006). Complainant further alleged violations of Sections
Electronic Filing - Received, Clerk's Office, February 21, 2008
61.145(a) and (b), 61.145(c)(i), (c)(2), (c)(6) and (c)(8), 61.150(b) of the National Emissions
Standards for Hazardous Air Pollutants ("NESHAP") for asbestos, 40
C.F.R. 61.145(a) and (b),
61.145(c)(i), (c)(2), (c)(6) and (c)(8), 61.150(b). Specifically, the Complaint alleged Air.
Pollution, Failure to Inspect and to Submit Complete and Accurate Notification of Demolition
and Renovation, Failure to Remove and Contain Regulated Asbestos Containing Materials
("RACM") in compliance with NESHAP Requirements, Improper Disposal
of Regulated
Asbestos-Containing Materials, and Failure to Pay Asbestos Fee.
2.
On July 2, 2007, Complainant filed its Proof of Service of the June 15, 2007
Complaint with the Board.
3.
The Proof of Service indicated that Knauer had been served with the
Complaint on June 18, 2007. Attached hereto as exhibit I.
4.
As of the date of the filing of this Motion, Knauer has not filed an Answer, nor
otherwise pled, to the Complaint.
5.
Section 103.204(d) and (e) of the Board'sProcedural Rules, 35 Ill. Adm. Code
103.204(d) and (e), provides as follows:
(d)
Except as provided in subsection (e)
of this Section, the respondent may
file an answer within 60 days after receipt
of the complaint if respondent
wants to deny any allegations in the complaint. All material allegations of
the complaint will be taken as admitted if no answer is filed or if not
specifically denied by the answer, unless respondent asserts a lack of
knowledge sufficient to form a belief. Any facts constituting an
affirmative defense must be plainly set forth before hearing in the answer
or in a supplemental answer, unless the affirmative defense could not have
been known before hearing.
(e)
If the respondent timely files a motion under Section 103.212(b) or 35 Ill.
Adm. Code 101.506, the 60-day period to file an answer described in
subsection (d)
of this Section will be stayed. The stay will begin when the
motion is filed and end when the Board disposes
of the motion.
2
Electronic Filing - Received, Clerk's Office, February 21, 2008
6.
By failing to answer the Complaint on or before August 14,2007, and
by failing to file a motion staying the 60-day period in which to file an Answer as required by
Section 103.204(d) and (e)
of the Board'sProcedural Rules, 35 Ill. Adm. Code 103.204(d) and
(e), Knauer has admitted the material allegations asserted in the Complaint.
7.
ComplaiQ.ant therefore requests that the Board enter an order finding that pursuant
to Section 103.204(d) and (e),
35 Ill. Adm. Code 103.204(d) and (e), Knauer has admitted all
material allegations asserted in the Complaint.
8.
Complainant'sComplaint sufficiently states facts establishing the following
violations
of the Act, Board Air Pollution Regulations, and the NESHAP for asbestos against
Knauer:
Count
I:
Count II:
Count III:
Count IV:
Count V:
Count VI:
Air Pollution: Violation
of Section 9(a) ofthe Act, 415 ILCS 5/9(a) (2006)
and Section 201.141 of the Board'sAir Pollution Regulations, 35 Ill.
Adm. Code 201.141;
Failure to Inspect and to Submit Complete and Accurate Notification of
Demolition and Renovation: Violation of 9.1 (d) of the Act, 415 ILCS
5/9.1(d), and Sections 61. 145(a) and (b) of the NESHAP for asbestos, 40
C.F.R. 61. 145(a) and (b);
Failure to Remove and Contain RACM in Compliance with NESHAP
Requirements: Violation
of Section 9.1 (d) of the Act, 415 ILCS 5/9.l(d),
and Sections 61.l45(c)(1), (c)(2), (c)(6) and (c)(8) and 61. 150(a)(1)(iii),
(iv) and (v) of the NESHAP for asbestos, 40 C.F.R. 61.145(c)(1), (c)(2),
(c)(6) and (c)(8) and 61.150(a)(1)(iii), (iv) and (v);
Improper Disposal
of Regulated Asbestos-Containing Materials: Violation
of Section 9.1 (d) of the Act, 415 ILCS 5/9.1 (d), and Section 61. 150(b) of
the NESHAP for asbestos, 40 C.F.R. 61.150(b);
Failure to Pay Asbestos Fees: Violation
of Section 9.13(a) ofthe Act, 415
ILCS 5/9.13(a); and
Open Burning
ofRefuse: Violation of Section 9(c) of the Act, 415 ILCS
5/9(c).
9.
Section 101.516(b) of the Board'sProcedural Regulations, 35 Ill. Adm. Code
3
Electronic Filing - Received, Clerk's Office, February 21, 2008
101.516(b), provides as follows:
(b)
If
the record, including pleadings, depositions and admissions on file,
together with any affidavits, shows that there is no genuine issue of
material fact, and that the moving party is entitled to judgment as a matter
of law, the Board will enter summary judgment.
10.
If the Board finds that Knauer has admitted all material allegations in
Complainant'sComplaint, than the record shows that there is no issue
of material fact remaining
for review. Therefore, pursuant to Section 101.516(b) of the Board'sProcedural Regulations, 35
Ill. Adm. Code
101.516(b), Complainant is entitled to summary judgment in its favor as a matter
of law.
WHEREFORE, Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General
of the State of Illinois, respectfully request that that Board issue
an order in favor
of Complainant and against Respondent WILLIAM KNAUER, individually, as
follows:
I.
Ordering
all material allegations in the Complaint admitted against Respondent
William Knauer;
2.
Finding that Respondent William Knauer violated Sections 9(a), 9.1 (d), 9. 13(a)
and 9(c)
of the Act, 415 ILCS 5/9(a), 9.1 (d), 9. 13(a), 9(c) (2006) and Sections 61. 145(a) and (b),
61. 145(c)(i), (c)(2), (c)(6) and (c)(8), 61. 150(b)
of the NESHAP for asbestos, 40 C.F.R.
61.145(a) and (b), 61.145(c)(i), (c)(2), (c)(6) and (c)(8), 61.150(b);
3.
Granting summary judgment in favor of Complainant and against Respondent
William Knauer on Counts I through VI
of the Complaint; and
REMEDY
The June 21, 2007 Board Order in this cause provides, in pertinent part:
4
Electronic Filing - Received, Clerk's Office, February 21, 2008
Accordingly, the Board further directs the hearing officer to advise the parties that in
summary judgment motions and responses, at hearing, and in briefs, each party should
consider: (1) proposing a remedy for a violation,
if any (including whether to impose a
civil penalty), and supporting its position with facts and arguments that address any
or all
of the Section 33(c) factors; and (2) proposing a civil penalty, if any (including a specific
total dollar amount and the portion
of that amount attributable to the respondent's
economic benefit,
if any, from delayed complaint), and supporting its position with facts
and argument that address any
or all of the Section 42(h) factors ...
4.
Pursuant to the June 21, 2007 Board Order, Complainant is proposing a remedy
for Respondent'sviolations
of Sections 9(a), 9.1 (d), 9. 13(a) and 9(c) of the Act, 415 ILCS
5/9(a), 9.1(d), 9. 13(a), 9(c) (2006) and Sections 61.145(a) and (b), 61. 145(c)(i), (c)(2), (c)(6) and
(c)(8), 61.150(b)
of the NESHAP for asbestos, 40 C.F.R. 61.145(a) and (b), 61. 145(c)(i), (c)(2),
(c)(6) and (c)(8), 61.150(b).
Impact on the Public Resulting from Respondent's Alleged Non-Compliance
Section 33(c) of the Act, 415 ILCS 5/33(c) (2006), 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
5.
any subsequent compliance.
In response'to these factors, the Complainant states the following:
5
Electronic Filing - Received, Clerk's Office, February 21, 2008
1.
The impact to the public resulting from Respondent's failure to comply with the
work practice standards of the asbestos NESHAP in connection with regulated building
renovation activities resulted in the emission of asbestos fibers, a known carcinogen, which
threatened human health and the environment. In addition, the Illinois Environmental Protection
Agency ("Illinois EPA") and the public were not privy to information that is important to
monitor
of hazardous material in Illinois, because no notification of activities was received by
the Illinois EPA, prior to the commencement of asbestos removal activities at the Site.
2.
The Buildings at the Site, which are the subject of the Complaint, have social and
economic value.
3.
The Buildings at the Site, which are the subject ofthe Complaint, are suitable to
the area in which they are located.
4.
Complying with the applicable provisions of the Act, the Board'sAir Pollution
Regulations and the NESHAP for asbestos was both technically practicable and economically
reasonable.
5.
Complainant states that the Site is now in compliance with the Act, the Board
Regulations, and the NESHAP for asbestos.
A civil penalty should be assessed against Knauer because
of the potentially severe
impact the exposure to asbestos, a known carcinogen for which there is no known safe level
of
exposure, had on human health and the environment.
Explanation of Civil Penalties Requested
Section 2(b) of the Act, 415 ILCS 5/2(b) (2006), provides:
It
is the purpose of this Act, as more specifically described in later
sections, to establish a unified, state-wide program supplemented by
private remedies, to restore, protect and enhance the quality
of the
6
Electronic Filing - Received, Clerk's Office, February 21, 2008
environment,
and to assure that adverse effects upon the environment are
fully considered and borne by those who cause them.
(Emphasis added.)
The primary purpose
of civil penalties is to aid in the enforcement of the Act.
See People
v.
McHenry Shores Water Co.,
295 Ill. App. 3d 628,638 (2d Dist. 1998). Civil penalties should
reflect the severity
of the violation(s) of the Act.
Southern Illinois Asphalt Company, Inc.
v.
Pollution Control Board,
60 Ill. App. 2d 204, 208 (5th Dist. 1975). But the Act authorizes civil
penalties regardless
of whether violations resulted in actual pollution.
ESG Watts, Inc.
v.
Illinois
Pollution Control Board,
282 Ill. App. 3d 43,52 (4th Dist. 1996). Moreover, the award of a civil
penalty "serves the legislative purpose of aiding enforcement of the Act, for through penalties
upon those who blatantly disregard applicable rules and regulations, others, who might consider
cutting comers at the expense
of the environment, are deterred."
Wasteland, Inc.
v.
Illinois
Pollution Control Board,
118 Ill. App. 3d 1041, 1055 (3d Dist. 1983) (subsequently cited by the
First District;
see e.g. Standard Scrap Metal Co.
v.
Pollution Control Board,
142 Ill. App 3d 655,
665 (1st Dist.1986».
Section 42
of the Act provides guidance for calculating civil penalties for violations of
the Act. The statutory maximums provided in the Act have been used as "a natural or logical
benchmark from which to begin considering factors in aggravation and mitigation
of the penalty
amounts."
Illinois EPA
v.
Allen Barry, Individually and d/b/a Allen Barry Livestock,
PCB No.
88-71, p. 72 (May 10, 1990).
Section 42(a) of the Act, 415 ILCS 5/42(a) (2006), provides in pertinent part; as follows:
a)
Except as provided in this Section, any person that violates any
provision
of this Act or any regulation adopted by the Board, or
any permit or term or condition thereof, or that violates any order
of the Board pursuant to this Act, shall be liable for a civil penalty
of not to exceed $50,000 for the violation and an additional civil
penalty of not to exceed $10,000 for each day during which the
violation continues;
7
Electronic Filing - Received, Clerk's Office, February 21, 2008
If the Board finds that Respondent violated the statutory and regulatory provisions
alleged in Counts I through VI
of the Complaint, on or before January 13,2006, the date when
Respondent Mick Morfey first retained William Knauer to remove and dispose
of asbestos-
containing siding material, asbestos-containing pipe covering, scrap metal, and waste material
located at the Site and continuing to at least October
30,2006, the maximum statutory penalty
that Section 42(a)
of the Act, 415 ILCS 5/42(a) (2006), authorizes for those violations is
$6,400,000 including the penalty for continuing violations
of$10,000 per day.
Penalties for violations of the Act and the Board Air Pollution Regulations are calculated
according to the formula contained in Section 42(a), 415 ILCS 5/42(a) (2006). The statutory
maximum is calculated as follows:
Count
I
1 violation of Section 9(a)
1 violation
of Section 201.141
2 violations continuing 290 days
Count II
1 violation of Section 9.1 (d)/40 C.F.R. 61.145(a)
1 violation of Section 9.1 (d)/40 C.F.R. 61.145(b)
Count III
1 violation of Section 9.1 (d)/40 C.F.R. 61.145(c)(1)
1 violation of Section 9. 1(d)/40 C.F.R. 61. 145(c)(2)
1 violation
of Section 9.1 (d)/40 C.F.R.61.145(c)(6)
1 violation
of Section 9.1 (d)/40 C.F.R. 61.145(c)(8)
1 violation of Section 9.1 (d)/40 C.F.R. 61.150(a)(1)(iii),
(iv) and (v)
Count IV
1 violation of Section 9. 1(d)/40 C.F.R. 61. 150(b)
8
$ 50,000
50,000
5,800,000
50,000
50,000
50,000
50,000
50,000
50,000
50,000
50,000
Electronic Filing - Received, Clerk's Office, February 21, 2008
Count V
1 violation
of Section 9. 13(a)
Count VI
- 1 violation of Section 9(c)
Total
50,000
50,000
$6,400,000
Consideration
of Section 42(H) Factors
Section 42(h) of the Act, 415 ILCS 5/42(h) (2006), provides as follows:
In determining the appropriate civil penalty to be imposed under
..., the
Board
is authorized to consider any matters of record in mitigation or
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 detennined 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 violator and other
persons similarly subject to the Act;
5. .
the number, proximity in time, and gravity of previously
adjudicated violations ofthis Act by the violator.
6.
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
9
Electronic Filing - Received, Clerk's Office, February 21, 2008
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 Complainant states as follows:
1.
The duration of the violations that are the subject of the Complaint are alleged by
Complainant to have occurred on or before January
13,2006 through at least October 30, 2006.
The gravity
of the alleged violations is enhanced, due to the hazardous nature of the RACM that
was disturbed during Respondent's activities at the Site, exposing, at a minimum, Respondents to
carcinogenic asbestos fibers.
2.
Respondent failed to act diligently in this matter, as evidenced by improperly
disturbing, handling and disposing
of dry, friable RACM at the Site. By failing to retain a
contractor trained in the requirement
of the NESHAP for asbestos and by improperly disturbing,
handling and disposing
of dry, friable RACM at the Site, Knauer caused, threatened or allowed
the discharge
or emission of asbestos, a known human carcinogen for which there is no known
safe level
of exposure, into the environment.
3.
Respondent accrued a nominal economic benefit by delaying proper abatement of
asbestos containing materials prior to commencing activities at the Site and the civil penalty
requested by Complainant would include any economic benefit that Knauer may have accrued as
a result of the delay in compliance.
4.
Complainant states that a maximum civil penalty payment of One Hundred
Thousand Dollars ($100,000.00) will serve to deter further violations by Respondent and to
otherwise aid in enhancing voluntary compliance with the Act, Board Regulations, and the
NESHAP for asbestos by Knauer and other persons similarly subject to the Act, Board
Regulations, and the NESHAP for asbestos.
10
Electronic Filing - Received, Clerk's Office, February 21, 2008
5.
To Complainant's knowledge, Knauer has had no previously adjudicated
violations.
6.
Self-disclosure is not at issue in this matter.
7.
Knauer did not offer to perform a supplemental environmental project.
These aggravating and mitigating factors provide guidance to the Board in determining
the appropriate amount
of a civil penalty in an environmental enforcement case. Accordingly,
the Complainant brings these factors to the Board's attention.
WHEREFORE, Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General
of the State of Illinois, respectfully requests that the Board grant
its Motion to Deem Facts Admitted and for Summary Judgment against Respondent, WILLIAM
KNAUER, individually, and award the relief requested herein, and take such other action as the
Board believes to be appropriate and just.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
by LISA MADIGAN
Attorney General
of the State of Illinois
BY:~~~
Assistant Attorney General
Environmental Bureau
69 W. Washington St., Suite 1800
Chicago, Illinois 60602
Tel: 312-814-2087
ssylvester@atg.state.il.us
11
Electronic Filing - Received, Clerk's Office, February 21, 2008
Electronic Filing, Received, Clerk's Office, July 2, 2007
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS
by LISA MADIGAN, Attorney General
ofthe State of Illinois,
Complainant,
v.
MICK MORFEY, individually, and
WILLIAM KNAUER, individually,
Respondents.
)
~
)
)
)
)
)
)
)
~
PCB No. 07-144
(Enforcement - Air)
NOTICE OF FILING
TO:
See Attached Service List
(VIA ELECTRONIC FILING)
PLEASE TAKE NOTICE that on July 2,2007, the Plaintiff, PEOPLE OF THE STATE
OF ILLINOIS, filed before the Illinois Pollution Control Board, its
Proof of Service, a true and
correct copy
of which is attached and hereby served upon you.
PEOPLE OF
THE STATE OF ILLINOIS,
by LISA MADIGAN, Attorney General
of the State of Illinois
BY:
s~£ny~
Assistant Attorney General
Environmental Bureau
69 W. Washington St., Suite 1800
Chicago, Illinois 60602
(312) 814-2087
Date: July
2,2007
THIS FILING IS SUBMITTED ON RECYCLED PAPER
EXHIBIT
i~
Electronic Filing - Received, Clerk's Office, February 21, 2008
Electronic FiUng, Received, Clerk's Office, July 2, 2007
.
SERVICE LIST
Mr. Mick Morfey
9734 Route 84 South
Savanna,
IL
61074
Mr. William Knauer
9885 Prairie St.
Walker Edition
Savanna,
IL
61074
Mr. Bradley
P. Halloran
Hearing Officer
Illinois Pollution Control Board
James
R. Thompson Center, Suite 11-500
Chicago, Illinois 60601
Electronic Filing - Received, Clerk's Office, February 21, 2008
Electronic Filing, Received, Clerk's Office, July 2, 2007
.
BEFORE THE ILLiNOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS
)
by LISA
MADIGAN, Attorney General
)
.ofthe State
of Illinois,
)
)
Complainant,
)
),
v.
)
)
MICK MORFEY, individually, and
)
WILLIAM KNAUER, individually,
)
)
Respondents.
) .
PCB No. 07-144
(Enforcement - Air)
PROOF OF SERVICE
COMES NOW the Complainant, People
of the State of Illinois, and pursuant to the
Board's procedural rules, provides proof
of service ofthe Complaint. Attached are copies of the
Notice
of Filing, Certificate of Service, and Return Receipt from Respondents, Mick Morfey and
William Knauer.
PEOPLE OF THE STATE OF ILLINOIS,
by LISA
MADIGAN, Attorney General
of the State of Illinois
Date: July
2,2007
BY:
STEPHEN
f4M~~
lVES
R
.
Assistant Attorney General
Environmental Bureau
69
W. Washington St., Suite 1800
Chicago, Illinois 60602
(312) 814-2087
Electronic Filing - Received, Clerk's Office, February 21, 2008
Electronic Filing,
SENDER:
COMPLETE THIS SECTION
• Complete items 1, 2.l.
~d
3. Also comelete
item 4
if Restricted uelivery IS aeslrea:
Print your name and address on the reverse
so that
we
can retum the card to
you.
Attach this card to
the
back Of the rnailpiece,
or on the front if space permits.
William Knauer
9885 Prairie Street
Walker Edition
Savanna, Illinois 61074
COMPLETE THIS SECTION ON DELIVERY
A.
Signature
o
Certified Mail
(] Express Mail
o
Registered
0 Return Receipt for Merchandise
o Insured Mail
0 C.O.D.
4. Restricted Delivery?
(EKtra
Fee)
7004 2510 0004 1999 2218
t
PS Form 3811. February 2004
Domestic Return Receipt
l02595-02.M.l540
SENDER:
COMPLETE THIS SECTION
• Complete items 1, 2, and 3. Also complete
Item 4 If Restricted Delivery Is
desired.
• Print your name and address on the reverse
So that-we can retum the card to you.
• Attach this card
to the back
of
the mallplece,
or on the front If space permits.
1. ArtIcle Addressed to:
Mr. Mickey Morley
.
Savanna Cellars Winery
&Vineyard
9734 Route 84 south
Savanna, Illinois 61074
COMPLETE THIS SECTION ON DELIVERY
A.
Sl~nature
3. 5elvtceType
o
CGrtffied Mail
(] ExpreSs Mall
o
Registered
0
Return Receipt for Merchandise
. red
(] C.O.D.
4. Restricted Delivery? (Elctr8
Fee)
0
Yes
2.
7004 2510 00D4 1999 2201
PS Form 381 1, February 2004
Domestic Return Receipt
1025!l5-02-M-1540
Electronic Filing - Received, Clerk's Office, February 21, 2008
Electronic Filing, Received, Clerk's Office, July 2, 2007
CERTIFICATE OF SERVICE
I, STEPHEN
1.
SYLVESTER, an Assistant Attorney General in this case, do certify that I
caused
to be served this 2nd day ofJuly, 2007, the foregoing Notice of Filing and Proof of
Service upon the persons listed on said Notice by depositing same in an envelope, by first class
postage prepaid, with the United States Postal Service at 100 West Randolph Street, Chicago,
Illinois, at
or before the hour of 5:00 p.m.
s~~
STEPH J. SYL4:STER .
Electronic Filing - Received, Clerk's Office, February 21, 2008
CERTIFICATE OF SERVICE
I, STEPHEN
J. SYLVESTER, an Assistant Attorney General in this case, do certify that I
caused to be served this
21 st day of February, 2008, the foregoing Notice of Filing and
Complainant'sMotion to Deem Facts Admitted and for Summary Judgment as to Respondent
William Knauer upon the persons listed on said Notice by depositing same in an envelope, by
first class postage prepaid, with the United States Postal Service at 100 West Randolph Street,
Chicago, Illinois, at or before the hour
of 5:00 p.m.
BY:
5~<4S~
STEEi'iJ.fiLVESTER
.
Electronic Filing - Received, Clerk's Office, February 21, 2008
