CLERK’~0~,~~

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

DE’~

ADMINISTRATIVE CITATION

“032004

P~T4~TE

OF ILlINOIS

ILLINOIS ENVIRONMENTAL

)

1°’~

Contro’ Board

PROTECTION AGENCY,

)

Complainant,

)

)

v.

)

No.

JEPA No. 532-04-AC

)

JAMES A. HAAS, JR.,

)

)

Defendant.

PETITION FOR REVIEW

NOW COMES the Defendant, JAMES HAAS, JR.,

by and through his

attorneys, NACK, RICHARDSON

&z KURT, P.C.,

by Joseph

E.

Nack, and files the

following Petition for Review and states in support thereof as follows:

1.

That James Haas, Jr., the Defendant in this matter, did not cause the

violation that is subject of this administrative citation.

2.

That the property and site in question had been cleaned prior to the

citation being filed.

WHEREFORE,

the Defendant requests that this matter be reviewed by the

Illinois EPA.

JAMES HAAS, JR., Defendant

BY: NACK, RICHARDSON & KURT, P.C.,

His Attorneys

BY:

~

“

Joseph E. Nack

---

CERTIFICATE

OF SERVICE

I hereby certify that I have personally served the original and nine copies

of the foregoing

PETITION FOR REVIEW

by mailing the same this ~

~

day

of

&/~.~-L

,

A. D. 2004, to:

Clerk of the Illinois Pollution Control Board

State of Illinois Center

100 West Randolph Street, Suite 11-500

Chicago, IL 60601

with a copy mailed to:

Illinois Environmental Protection Agency

Attn: Division of Legal Counsel

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

Attorney for Defendant:

Joseph F. Nack #6200306

NACK, RICHARDSON

& KURT, P.C.

106 North Main Street

P. 0.

Box 336

Galena, Illinois 61036

Telephone No.: (815) 777-1218

---

FEC~E~VED

CLERK’S OFFICE

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

DEC

032004

ADMINISTRATIVE CITATION

STATE OF ILLINOIS

Pollution Control Board

ILLINOIS ENVIRONMENTAL

)

PROTECTION AGENCY,

)

Complainant,

)

~

v.

)

No.

JEPA No. 532-04-AC

)

JAMES

A. HAAS, JR.,

)

)

Defendant.

)

ENTRY OF APPEARANCE

Joseph E. Nack, of NACK, RICHARDSON

& KURT, P.C., do hereby enter

my appearance for

JAMES A. HAAS, JR.,

Defendant in the above-entitled case.

JAMES HAAS, JR., Defendant

BY: NACK, RICHARDSON

& KURT, P.C.,

His Attorneys

BY:

.:;34’~J:~

‘t’-

Joseph E. Nack

---

CERTIFICATE OF SERVICE

I hereby certify that I have served a copy of the original and nine copies of

the foregoing ENTRY

OF APPEARANCE

by mailing the same this

..?

~

day of

_______________

A. D. 2004, to:

Clerk of the Illinois Pollution Control Board

State of Illinois Center

100 West Randolph Street, Suite 11-500

Chicago, IL 60601

with a copy mailed to:

Illinois Environmental Protection Agency

Attn: Division of Legal Counsel

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

Attorney for Defendant:

Joseph E. Nack #6200306

NACK, RICHARDSON & KURT, P.C.

106 North Main Street

P. 0.

Box 336

Galena, Illinois 61036

Telephone No.:

(815) 777-1218

---

BEFORE THE ILLINOIS POLLUTION CONTROL BOA~~

0~f~CE

ADMINISTRATIVE CITATION

~EC

03

200k

ILLINOIS ENVIRONMENTAL

)

OF~LL1~~~’S

PROTECTION AGENCY,

)

COflt~

Board

)

Complainant,

)

)

v.

)

No.

IEPA No. 532-04-AC

)

JAMES A. HAAS, JR.,

)

)

Defendant.

)

AFFIDAVIT OF SERVICES

State of Illinois

)

)

ss.

Jo Daviess County

)

I, JOSEPH

F. NACK,

being first duly sworn on oath deposes and

states that

I have caused

an original and nine copies to be served upon:

Clerk of the Illinois Pollution Control Board

State of Illinois Center

100 West Randolph Street, Suite 11-500

Chicago, IL 60601

with a copy mailed to:

Illinois Environmental Protection Agency

Attn: Division of Legal Counsel

1021 North Grand Avenue East

P.O. Box 19276

Springfield, IL 62794-9276

Petition for Review and Entry of Appearance by placing a true and correct copy

of said Petition for Review and Entry of Appearance in an envelope, addressed

as is shown above.

That I sealed said envelope and placed sufficient U.S. postage on each;

that I deposited said envelope so sealed and stamped in the U.S. Mail at Galena,

---

Illinois, at or about the hour of 5:00 p.m. on the

~

day of

A. D. 2004.

“

Joseph E. Nack

Signed and sworn to before me,

this ____day of~~

~

D. 2004.

£i~

~7fl

C

Notary Public

OFFICIAL SEAL

I

KAREN ANN STIENSTRA

~

NOTARY PUBLiC

.

STATE

OF ILLINOIS

~

~cM~SS~EXPIREShhh13~8

Attorney for Defendant:

Joseph E. Nack #6200306

NACK, RICHARDSON & KURT, P.C.

106 North Main Street

P. 0.

Box 336

Galena, Illinois 61036

Telephone No.:

(815) 777-1218