NOTICE OF FILING
TO: Clerk of the Illinois Pollution Control Board
Mr. Charles A . King
James R. Thompson Center
City of Chicago, Dept . of Environment
100 West Randolph Street, Suite 11-500
30 North LaSalle Street, 9` h Floor
Chicago, Illinois 60601
Chicago, Illinois 60602
PLEASE TAKE NOTICE that we have this day filed with the Clerk of the Illinois
Pollution Control Board, Petition to Contes dministra ve Citation .
Dated at Chicago, Illinois, this 2" d day of Jun
006
Jeffrey J
. Levine, P.C. #17295
20 North Clark Street, Suite 800
Chicago, Illinois 60602
(312) 372-4600
PROOF OF SERVICE
The undersigned, being first duly sworn on oath, deposes and says that he served a copy of
the Notice together with the above mentioned documents to the person to whom said Notice is
directed by hand delivery, this
2nd
day of Jun 2006.
J
. LE
T 1
BEFORE THE ILLINOIS POLLUTION CONTROL BOAIVAERK'S
RECEIVEDOFFICE
CITY OF CHICAGO DEPARTMENT
)
JUN 0 2 2006
OF ENVIRONMENT,
)
STATE OF ILLINOIS
Complainant,
) Site Code
:0316485103
Pollution Control Board
AC: 2006-039
v.
)
SPEEDY GONZALEZ LANDSCAPING, )
INC.,
)
Respondent .
)
(CDOE No
. 06-02-AC)
RECEIVEDCLERKS
OFFICE
PETITION TO CONTEST ADMINISTRATIVE CITATION
Now comes the Respondent, SPEEDY GONZALEZ LANDSCAPING, INC ., by and
through it's counsel Jeffrey J . Levine, P .C ., and pursuant to Section 108 .204 of the Administrative
Rules of the Illinois Pollution Control Board, seeks to contest the Issuance of the Administrative
Citation, and in support thereof, states and asserts as follows :
1 . Respondent is within 35-daytime period described in Section 108-204(b) of the Rules and
Section 31 .1(d) of the Act, as the Citation in this matter was filed on May 10, 2006 .
2 . Respondent contests the issuance of the Administrative Citation for the following reasons :
a. Respondent does not own property cited in the Administrative Citation ;
b. Respondent did not cause or allow specific violations cited in the Administrative
Citation .
c . Upon information and belief, specific violations cited in the Administrative
Citation were untimely and/or improperly alleged ;
d
. Numerous alleged violations were the result of uncontrollable circumstances ;
e. Certain alleged violations are baseless and without merit ;
f. Specific alleged violations did not involve pollution ;
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
JUN 0
CITY OF CHICAGO DEPARTMENT
OF
ENVIRONMENT,
)
STATE OF ILUNOIS
)
Pollution control Board
Complainant,
) Site Code:0316485103
V .
)
SPEEDY GONZALEZ LANDSCAPING, )
INC.,
)
Respondent.
)
AC : 2006-039
(CDOE No
. 06-02-AC)
g
. Respondent had no intent to commit specific violations ;
h
. Other individuals or entities were responsible for the violations and have been
punished for the specific acts alleged by the Complainant ;
i. Complainant seeks recovery from numerous entities for the same violations ; and
j . Complainant exceeded it's authority in alleging portions of the Administrative
Citation .
Wherefore, for the above and forgoing reasons, Respondent Speedy Gonzalez Landscaping,
Inc.,
prays that the Illinois Pollution Control Board dismiss Complainant's Administrative Citation
and for such further relief as it deems just and equitable
.
Levine, P.C.
for Respondent
Speedy Gonzalez Landscaping, Inc.
Jeffrey J . Levine, P.C. #17295
20 North Clark Street, Suite 800
Chicago, Illinois 60602
(312) 372-4600
