ILLINOIS POLLUTION CONTROL BOARD
November 16, 2006
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
AC 05-40
NORTHERN ILLINOIS SERVICE
) (IEPA No. 567-04-AC)
COMPANY,
) (Administrative Citation)
Respondents.
)
MOTION FOR STAY OF ENFORCEMENT OF ADMINISTRATIVE ORDER
TO : Michelle M. Ryan
Special Assistant Attorney General
Illinois Environmental Protection Agency
Division of Legal Counsel
1021 North Grand Avenue East
P.O . Box 19276
Springfield, IL 62794-9276
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, IL 60601
NOW COMES petitioner NORTHERN ILLINOIS SERVICE COMPANY by
PETER DeBRUYNE, P .C. and Lewis B . Kaplan, its attorneys, and pursuant to Supreme
Court Rule 335(g) moves that enforcement of the Order, a copy of which is attached
hereto marked Exhibit "A" and made a part hereof, adopted by the Illinois Pollution
Control Board on November 16, 2006 for payment by petitioner, NORTHERN
ILLINOIS SERVICE COMPANY, of a Civil Penalty and costs in the total amount of
$3,406 .50 no later than January 2, 2007 be stayed pending review of the aforesaid Order
of November 16, 2006 by the Appellate Court of Illinois, Second Judicial District in its
case No
. 02-06-1237
.
pSTp7
o~%tor? Obfittr
®~
,0/
ivoi s
Peter DeBruyne
Peter DeBruyne, P .C.
838 North Main Street
Rockford,IL 61103
Telephone (815) 964-3810
Lewis B. Kaplan
Attorney at Law
838 North Main Street
P.O. Box 1254
Rockford, IL 61105-1254
Telephone (815) 963-3090
Attorneys for Petitioner, NORTHERN ILLINOIS SERVICE COMPANY
NORTHERN ILLINOIS SERVICE
COMPANY, Petitioner,
By PETER DeBRUYNE, P .C
.
By
Peter DeDeBruyne, Attorney
for Petitioner
Lewis B. Kaplan, Attorney for Petitioner
thi/3tday
of December, 2006.
otary
~ Public/i
1
Peter DeBruyne
Peter DeBruyne, P .C .
838 North Main Street
Rockford, IL 61103
Telephone (815) 964-3810
AFFIDAVIT OF SERVICE
•Peter DeBruyne on oath states
: On the _ ay of December, 2006, I served this
4by
mailing a copy to each person to whom it is directed .
SUBSCRIBED and sworn to before me
