BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
R
CLERK'S
E C E I
OFFICEV
E D
County of Wayne,
OCT 2 0 2006
)
STATE
Complainant,
Pollution Control Board
)
vs.
)
AC 191-06-06
Mr. Julian Buchanan,
)
)
h1]_CU
~,-SS
Respondent.
)
NOTICE OF FILING
TO: KEVIN KAKAC
Wayne County, Illinois, State's Attorney
P . O. Box 641
Fairfield, IL 62837
and
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
P . 0. Box 19274
Springfield, IL 62794-9274
PLEASE TAKE NOTICE that I have filed, with the office of the Clerk of the
Illinois Pollution Control Board, a Joint Motion for Withdrawal of Administrative
Citation, on behalf of WAYNE COUNTY, ILLINOIS, Complainant, and JULIAN
BUCHANAN, Respondent, a copy of which is herewith served upon you
.
JULIAN BUCHANAN, Respondent
BY: LAW OFFICE OF
MICHAEL J
. MOLT, LTD .
Attorney for Respondent
BY: MICHAEL J
J. M
DATED this
\ l
day of October, 2006
LAW OFFICE OF
MICHAEL J. MOLT, LTD .
Attorney for Respondent
P
. O
. Box 652
Fairfield, IL 62837
Telephone
: 618/842-4080
PROOF OF SERVICE
The undersigned certifies that a copy of the foregoing instrument was served upon
the following listed persons :
KEVIN KAKAC
Wayne County, Illinois State's Attorney
P . O. Box 641
Fairfield, IL 62837
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
P. 0
. Box 19274
Springfield, IL 62794-9274
by enclosing the same in an envelope addressed to such person at their addresses as
disclosed by the pleadings of record herein and as listed above, with postage fully prepaid
and by depositing said envelope in a U
.S
. Post Office mail box in Fairfield, Illinois, on
the
)Yrudayof dcTw$8r~ ,2006 .
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARD
County of Wayne,
RECEIVED
CLERK'S
OFFICE
)
OCT 2.0
2006
Complainant,
Pollution Control Bo
STATE
ILLINOIS
vs
.
)
AC 191-06-06
Mr. Julian Buchanan,
)
Respondent.
)
JOINT MOTION TO WITHDRAW
ADMINISTRATIVE CITATION
Now comes WAYNE COUNTY ILLINOIS, Complainant, by KEVIN KAKAC,
Wayne County, Illinois States Attorney and JULIAN BUCHANAN, Respondent, by his
attorney, the LAW OFFICE OF MICHAEL J
. MOLT, LTD ., and for their Joint Motion
to Withdraw Administrative Citation regarding the site which is owned by JULIAN
BUCHANAN, Respondent, which gave rise to the issuance of the Administrative
Citation in this case and which has been properly cleaned so that currently no violation of
the Illinois Environmental Protection Act exists on the site in question and state the
following :
1
. That WAYNE COUNTY ILLINOIS, Complainant, hereby requests that the
Administrative Citation issued in this case be withdrawn and that the case be closed
.
2
. JULIAN BUCHANAN, Respondent, hereby requests that the Illinois Pollution
Control Board allow WAYNE COUNTY ILLINOIS, Complainant, to withdraw the
Administrative Citation and close the above captioned case
.
WHEREFORE, WAYNE COUNTY ILLINOIS, Complainant, and JULIAN
BUCHANAN, Respondent, both respectively request that the Administrative Citation
issued in this case be withdrawn and that the Illinois Pollution Control Board close the
above captioned case .
LAW OFFICE OF
MICHAEL J . MOLT, LTD.
Attorney for Respondent
P
. O
. Box 652
Fairfield, IL 62837
Telephone : 618/842-4080
BY
: Kevin Kakac
Wayne County State's Attorney
JULIAN BUCHANAN, Respondent
BY: LAW OFFICE OF
MICHAEL J . MOLT, LTD .
Attorney for Respondent
BY: r'-tkc
M ~
MICHAEL J . I4IOLT
PROOF OF SERVICE
The undersigned certifies that a copy of the foregoing instrument was served upon
the following listed persons ;
KEVIN KAKAC
Wayne County, Illinois State's Attorney
P. O. Box 641
Fairfield, IL 62837
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
P. 0
. Box 19274
Springfield, IL 62794-9274
by enclosing the same in an envelope addressed to such persons at their addresses as
disclosed by the pleadings of record herein and as listed above, with postage fully prepaid
and b depositing said envelope in a U
.S . Post Office mailbox in Fairfield, Illinois, on
the
Ilrp
day of (ZcT
e %.
t O-
, 2006 .
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ReC
CLERK'S
e
OFF,
,
Vr
County of Wayne,
)
OCT
2
2006
Complainant,
)
Pollution
STATE OF
Control
ILLINOIS
Board
vs.
)
AC 191-06-06
Mr. Julian Buchanan,
)
Respondent.
)
CERTIFICATE OF SERVICE
I hereby certify that I did, on the
ISTN
day of October, 2006, send, by U. S
. mail,
with postage fully pre-paid, by depositing in the United States Post Office box in
Fairfield, Illinois, a true and correct copy of a Joint Motion to Withdraw Administrative
Citation with said envelope addressed to KEVIN KAKAC, Wayne County Courthouse,
P. O
. Box 641, Fairfield, IL 62837, and to Carol Webb, Hearing Officer, Illinois
Pollution Control Board, 1021 North Grand Avenue East, P
. O. Box 19274, Springfield,
IL 62794-9274 and the original and one copy of said Motion for Reconsideration on the
same date by U
. S. Express Mail with postage fully pre-paid, by depositing in the United
States Post Office Box in Fairfield, Illinois the original and one copy of the Motion for
Reconsideration addressed to
: DOROTHY GUNN, Clerk, Pollution Control Board,
James R
. Thompson Center, 100 West Randolph Street, Suite 11-500, Chicago, IL
60601 .
JULIAN BUCHANAN, Respondent
BY : LAW OFFICE OF
MICHAEL J
. MOLT, LTD .
Attorney for Respondent
BY:
,
MICHAELq
MOLT
