BEFORE THE
ILLINOIS
POLLUTION
CONTROL
BOARD
ADMINISTRATIVE
CITATION
CLfl
OPlGE
ILLINOIS
ENVIRONMENTAL
)
PROTECTION
AGENCY,
)
iUL
2
2009
Complainant,
)
STATE
OF
ILLINOIS
)
AC
i
Pollution
Control
Board
)
(IEPA No.
130-09-AC)
)
JASON
D. &
ANGELA
R. MARRS
d/b/a
)
MARRS
HAULING,
LANDSCAPING
&
)
MORE,
)
Respondents.
)
NOTICE
OFFILING
H
IF
I
\
jj
i
L\
I
TO:
Illinois
Environmental
Protection
Division
of
Legal
Counsel
1021
North
Grand
Avenue East
P.O.
Box
19276
Springfield,
IL 62794-9276
PLEASE
TAKE
NOTICE
that I have
today
filed
with
the Office
of the
Clerk
of the
Pollution
Control
Board the
Petition
for Review
of JASON
D.
MARRS
and ANGELA
R.
MARRS,
dlb/a
MARRS
HAULING,
LANDSCAPING
& MORE,
and
my
Entry
of Appearance,
a copy
of which
is
herewith
served
upon
you.
Blake
Weaver,
attorney
for Respondents
Blake
Weaver
NOVAK
WEAVER
SOLBERG
130 W.
Main
St.
Urbana,
IL
61801
(217) 384-0000
(Phone)
(217)
344-2662
(Fax)
BEFORE
THE ILLINOIS POLLUTION
CONTROL BOARD
ADMINISTRATIVE
CITATION
CLERK’S
OFFICE
ILLINOIS
ENVIRONMENTAL
)
PROTECTION
AGENCY,
)
JUL
2
Complainant,
AC
)
(IEPA
No. 130-09-AC)
)
JASON D. & ANGELA
R. MARRS d/b/a
)
MARRS
HAULING, LANDSCAPING
&
)
MORE,
)
Respondents
)
ENTRY OF
APPEARANCE
I hereby
file my appearance
in this proceeding,
on behalf of
the Respondents,
JASON
D.
MARRS and
ANGELA R. MARRS,
d/b/a
MARRS
HAULING, LANDSCAPING
& MORE.
Blake
Weaver,
attorney
for Respondents
Blake Weaver
NOVAK
WEAVER
SOLBERG
130
W.
Main
St.
Urbana,
IL 61801
(217)
384-0000 (Phone)
(217)
344-2662
(Fax)
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
ADMINISTRATIVE
CITATION
ILLINOIS
ENVIRONMENTAL
)
PROTECTION
AGENCY,
)
Complainant,
)
JUL
222009
)
AC
(1
)
(IEPAN0.
JASON
D.
&
ANGELA R.
MARRS
d/b/a
)
MARRS
HAULING,
LANDSCAPING
&
)
MORE,
)
Respondents.
)
PETITION
FOR
REVIEW
Now
come
the
Respondents,
JASON
D.
MARRS
and
ANGELA
R.
MARRS,
d/b/a
Marrs
Hauling,
Landscaping
and
More,
and
as
and
for
their
Petition
for
Review
of
Administrative
Citation dated
June
15,
2009,
they
state
as
follows:
1.
The
Respondents,
JASON
D.
MARRS
and
ANGELA
R.
MARRS,
are
husband
and
wife
and
formerly
resided
at
the
real
estate
located
at
30
CR
3050N,
Foosland,
Champaign
County,
Illinois.
The
Respondent,
JASON
D.
MARRS,
is the
owner
of
the
real
estate
which
is
improved with
various
buildings
and
formerly
was
improved
by
a personal
residence
occupied
by
JASON
D.
MARRS
and
ANGELA
R.
MARRS,
until
on
or
about
December
23,
2008
when
it
was
destroyed
by
fire.
2.
The
Respondents,
JASON
D.
MARRS
and
ANGELA
R.
MARRS,
state
that
they
have
operated
no
facility
as a
dump
at
any
time
covered
by
the
facts
stated
in
this
Citation,
have
not
caused
or allowed
open
dumping,
or
in the
event
of a
violation,
Respondents
state
the
same
was
the
result
of
circumstances
beyond
the
Respondents’
control.
3.
The
Respondents
admit
that
on
June
15, 2009,
an
Administrative
Citation
was
sent,
via
certified
mail.
4.
The
Respondents
deny
that
they
have
violated
the
provisions
of the
Illinois
Environmental
Protection
Act
with
respect
to Open
Dumping
of
Waste,
Resulting in
Litter,
or
the
Open
Dumping
of
Waste
Resulting
in
the
Deposition
of
General
Construction
or
Demolition
Debris, or Clean Construction
or Demolition
Debris,
in
violation
of
Section
21(p)
of
the
Illinois
Environmental
Pollution
Control Act.
Wherefore,
the
Respondents
pray
that
a
hearing
be
held
in
connection
with
this
matter
to
determine
the
true
facts
and,
after
consideration
of
the
same,
that
a
finding
be
made
in
favor
of
the Respondents
and
against
the
Complainant,
and
that
all
relief
requested
by
the
Complainant
be
denied.
Respectfully
submitted
JASON
D.
MARRS
and
ANGELA
R.
MARRS
Respondents
By:_____________________________
Blake
Weaver,
their
attorney
VERIFICATION
Under
penalties
as
provided
by
law
pursuant
to
Section
1-109
of
the
Code
of
Civil
Procedure
the
undersigned
certifies
that
the
statements
set
forth
in
this
instrument
are
true
and
correct,
except
as
to
matter
therein
stated
to
be
on
information
and
belief
and
as
to
such
patters
the
undersigned
certifies
as
aforesaid
that
he
verily
believes
the
same
to
be
true.
SON
D.
MARRS
VERIFICATION
Under
penalties
as
provided
by
law
pursuant
to
Section
1-109
of
the
Code
of
Civil
Procedure
the
undersigned
certifies
that
the
statements
set
forth
in
this
instrument
are
true
and
correct,
except
as
to
matter
therein
stated
to
be
on
information
and
belief
and
as
to
such
matters
the
undersigned
certifies
as
aforesaid
that
she
verily
believes
the
same
to
be
true.
R
ANGJ)A
R.
MARRS
Blake
Weaver
NOVAK
WEAVER
SOLBERG
130
W.
Main
St.
Urbana,
IL
61801
(217)
384-0000
(Phone)
(217)
344-2662
(Fax)
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
ADMINISTRATIVE
CITATION
cus
oic
ILLINOIS
ENVIRONMENTAL
)
JUL
222009
PROTECTIONComplainant,
AGENCY,
))
Pollution
STATE
OF
Control
ILLINOIS
Board
)
AC
)
(IEPAN0.
130-09-AC)
)
JASON
D.
&
ANGELA
R.
MARRS
d/b/a
)
MARRS
HAULING,
LANDSCAPING
&
)
MORE,
)
Respondents
)
CERTIFICATE
OF
SERVICE
I,
the undersigned,
on
oath,
state
that
I have
served
on
the
date
of
July
20,
2009,
a
copy
of
the
Entry
of
Appearance,
Notice
of
Filing
and
Petition
for
Review,
upon:
Illinois
Environmental
Protection
Division
of
Legal
Counsel
1021
North
Grand
Avenue
East
P.O.
Box 19276
Springfield,
IL
62794-9276
by
first-class
mail,
postage
properly
prepaid.
Blake
Weaver,
attorney
for
Respondents
Blake
Weaver
NOVAK
WEAVER
SOLBERG
130
W.
Main
St.
Urbana,
IL
61801
(217) 384-0000
(Phone)
(217) 344-2662
(Fax)