1. PROOF OF SERVICE
      2. NOTICE OF APPEARANCE
      3. PROOF OF SERVICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ADMINISTRATIVE CITATION
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
vs.
ROGER RAY,
Respondent.
)
)
)
)
)
ACO4~
)
)
(IEPA No. 392-03-AC)
)
kiE
CLERK’S
OFF1CF
SEp
2
9
20U3
STATE
OF
ILLINOIS
Po!/~t,0~
~ontro/BoQrd
NOTICE OF
FiLING
TO:
Clerk of the Illinois
Pollution Control Board
State of Illinois Center
100 West Randolph, Suite
11-500
Chicago, IL
60601
The Illinois Environmental
Protection Agency
Division of Legal Counsel
1021 North Grant Ave., East
P.O. Box
19276
Springfield, IL
62794
PLEASE TAKE NOTICE that on this date I mailed for filingwith the Clerk ofthe
Pollution Control Board of the State of Illinois, the following instrument entitled Petition for
Review,
as well as a Certificate of Service andNotice ofAppearance.
Mark S.
Morthland
Attorney at Law
227
S. Water Street
Decatur, IL
62523
(217) 429-2800
PROOF OF SERVICE
I hereby certifythat on the ~
~2of
September 2003, I sent by United States Post
Office, postage fully prepaid, a copy of the Petition for Review and Notice of Filing to:
TO:
Clerk of the Illinois
Pollution Control Board
State of Illinois Center
100 West Randolph,
Suite 11-500
Chicago, IL
60601
Mark S. Morthiand
Attorney at Law
227 S. Water Street
Decatur, IL
62523
(217) 429-2800
The Illinois Environmental
Protection Agency
Division of Legal Counsel
1021 North
P.O.
Box
19
RECEIVED
CLFRK’~
(IWFII”F
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
-
-
ADMiNISTRATIVE CITATION
~p
2
9
Z~JO3
ILLINOIS ENVIRONMENTAL
)
STATE
OF
ILLINOIS
PROTECTION AGENCY,
)
Pollution Control Board
Complainant,
)
AC
)
vs.
)
(IEPANo.
392-03-AC)
)
ROGER RAY,
)
)
Respondent.
)
PETITION FOR
REVIEW
NOW COMES RogerRay, Respondent, by and through his attorneys, MORTHLAND,
MORTHLAND & RAU, P.C., and for his Petition for Reviewrespectfully represents unto the
Illinois Environmental Protection Agency Control Board as follows:
1.
Your Respondent herein is the owner and operator of a facility located on the
southeast side ofthe intersection between the railroad tracks and 750 East in
Kirksville, Moultrie County, Illinois.
2.
That the parcel of real estate described above,
is to be used as a home for the
Respondent herein, in that it is his
intention to build a residence on the subject
property.
3.
That your Respondent herein was advised that ifhe desiredtoburn old brush, which
he had cut down, that he needed to dig a hole and burn the brush in said hole.
4.
That your Respondent.did
in fact dig ahole and had burned brush in said hole.
5.
That, based
upon information and belief, that other individuals began to throw items
of waste in the hole and your Respondent only discovered that after he had received
the Administrative Citation referred to above.
6.
That when he received acopy ofthe Complaint filed herein, he saw the pictures and
realizedthat there were items in his dump
site, which he did not put into or throw
into said hole.
7.
That the Respondenfs sole purpose in excavating said hole was to burn brush therein.
8.
That your Respondent was not operating awaste disposal operation at said time, nor
did he dump any ofthe waste found in the hole therein.
-2-
9.
That at this time, your Respondent herein does not reside on the subject property, but
lives in Sullivan, Moultrie County, Illinois.
10.
That your Respondent herein purchased the subject property in the year 2002.
WHEREFORE, your Respondentrespectfully prays that the Pollution Control Board will
dismiss the Complaint filed herein and send the Complainant henceforth without its day.
Mark S. Morthland
Attorney atLaw
227 S. Water Street
Decatur, IL
62523
(217) 429-2800
Roger Ray,
Respondent
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ADMINISTRATIVE CITATION
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
vs.
ROGER RAY,
Respondent.
)
AC
)
(IEPA No. 392-03-AC)
)
)
)
)
RECEIVED
CLERK’S
OFFrCF
SEP
2
9
2003
STATE OF ILLINOIS
Pollution Control Board
NOTICE OF APPEARANCE
TO:
Clerk of the Illinois
Pollution Control Board
State ofIllinois Center
100 West Randolph, Suite 11-500
Chicago, IL
60601
The Illinois Environmental
Protection Agency
Division of Legal Counsel
1021 North Grant Ave., East
P.O. Box 19276
Springfield, IL
62794
PLEASE BE ADVISED that the undersigned, Mark S. Morthland, hereby enters the
appearance ofthe law firm ofMORTHLAND,
MORTHLAND & RAU, P.C.,
on behalf of the
Respondentherein, Roger Ray.
Mark S. Morthiand
Attorney at Law
227 S. Water Street
Decatur, IL
62523
(217) 429-2800
Roger Ray,
Respondent
PROOF OF SERVICE
I hereby certifythat on the
~
ay ofSeptember 2003, I sent by United States Post
Office, postage fullyprepaid, a copy of the Notice ofAppearance to:
TO:
Clerk of the Illinois
Pollution Control Board
State of Illinois Center
100 West Randolph,
Suite 11-500
Chicago, IL
60601
Mark S. Morthland
Attorney at Law
227 S. Water Street
Decatur, IL
62523
(217) 429-2800
The Illinois Environmental
Protection Agency
Division of Legal Counsel
1021 North Grant M
P.O. Box 19276

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