BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
)
)
)
)
AC 08-28
v.
)
)
)
(IEPA No. 52-08-AC)
JOSEPH COSENTINO and ROB PINSKI,
)
Respondents.
)
)
NOTICE OF FILING
To: Rob Pinski
529 S. Madison St.
Du Quoin, IL 62832
Tony Cosentino
1043 N. Walnut St.
St. Johns, IL 62832
PLEASE TAKE NOTICE that on this date I electronically filed with the Clerk of the
Pollution Control Board of the State of Illinois the following instrument(s) entitled MOTION TO
DISMISS RESPONDENT JOSEPH COSENTINO.
Respectfully Submitted,
_________________________________
Michelle M. Ryan
Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
Dated: June 2, 2008
1
Electronic Filing - Received, Clerk's Office, June 2, 2008
2
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
)
)
)
)
AC 08-28
v.
)
)
)
(IEPA No. 52-08-AC)
JOSEPH COSENTINO and ROB PINSKI,
)
Respondents.
)
)
MOTION TO DISMISS RESPONDENT
JOSEPH COSENTINO
NOW COMES the Complainant, the Illinois Environmental Protection Agency (“Illinois
EPA”), by and through its attorney, Special Assistant Attorney General Michelle M. Ryan, pursuant
to 35 Ill. Adm. Code 101.500, and respectfully states as follows:
(1)
On April 11, 2008, Illinois EPA filed an Administrative Citation against
Respondents JOSEPH COSENTINO as property owner and ROB PINSKI as operator, based on an
inspection conducted on February 29, 2008.
(2)
On May 12, 2008, Respondent ROB PINSKI filed a timely petition for review.
(3)
Since the filing of this Administrative Citation, Complainant has determined that
upon information and belief, Respondent JOSEPH COSENTINO has been deceased for several
years.
Electronic Filing - Received, Clerk's Office, June 2, 2008
WHEREFORE, the Illinois Environmental Protection Agency requests that the Board
dismiss the pending action against Respondent JOSEPH COSENTINO and allow the case to proceed
against ROB PINSKI as the sole defendant in this matter.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant
DATED: June 2, 2008
_________________________________
Michelle M. Ryan
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
3
Electronic Filing - Received, Clerk's Office, June 2, 2008
PROOF OF SERVICE
I hereby certify that I did on the 2
nd
day of June, 2008, send by U.S. Mail with postage
thereon fully prepaid, by depositing in a United States Post Office Box a true and correct copy of
the following instrument(s) entitled MOTION TO DISMISS RESPONDENT JOSEPH
COSENTINO
To: Tony Cosentino
1043 N. Walnut St.
St. Johns, IL 62832
Rob Pinski
529 S. Madison St.
Du Quoin, IL 62832
and an electronic copy of the same foregoing instrument on the same date via electronic filing
To: John Therriault, Acting Clerk
Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
_________________________________
Michelle M. Ryan
Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
Electronic Filing - Received, Clerk's Office, June 2, 2008
