1. STATE OF ILLINOIS
      2. NOTICE OF FILING
  1. RECEIVED
      1. CERTIFICATION
      2. PROOF OF SERVICE
RECEIVED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
FEB
26
2004
STATE OF ILLINOIS
ILLINOIS ENVIRONMENTAL
)
Pollution Control Board
PROTECTION AGENCY,
)
)
Complainant,
)
AC 04-31
)
(IEPA No. 747-03-AC)
v.
)
)
EQUIPPING THE SAINTS MINISTRY,
)
INTERNATIONAL, INC.,
)
)
Respondent.
)
NOTICE OF FILING
To:
Equipping the Saints Ministry, International, Inc.
Billie Landers, Registered Agent
5000 Dickey John Road
Auburn, Illinois
62615
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution Control
Board of the State
of Illinois the following instrument(s) entitled MOTION FOR DEFAULT JUDGMENT.
Respectfully submitted,
~
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield,
Illinois 62794-9276
(2 17) 782-5544
Dated:
February 18, 2004
THIS FILING
SUBMITTED
ON
RECYCLED PAPER

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RECEIVED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
FEB
262004
STATE OF ILLINOIS
ILLINOIS ENVIRONMENTAL
)
Pollution
Control
Board
PROTECTION AGENCY,
)
)
Complainant,
)
AC
04-3 1
)
)
(IEPA No. 747-03-AC)
)
EQUIPPING THE SAINTS
MINISTRY,
)
INTERNATIONAL,
INC.,
)
)
Respondent.
)
MOTION FOR DEFAULT JUDGMENT
NOW COMES the Complainant, the Illinois
Environmental Protection Agency
(“Illinois
EPA”), by and through its attorney, Michelle M. Ryan, pursuant to 35 Ill. Adm. Code 101.500, and
respectfully states as follows:
(1)
On December
18,
2003, Illinois
EPA issued an
Administrative Citation (“AC”) to
Respondent, Equipping the Saints Ministry International,
Inc., an Illinois corporation, based on an
inspection conducted on November 18, 2003.
(2)
On January
9,
2004,
service was made on
Respondent’s
registered
agent,
Billie
Lauder, by hand delivery.
(3)
Pursuant
to 415
ILCS
5/31.1(d)
and
35
Ill.
Adm.
Code
108.204(b), a petition for
review was required to be flied in this matter by February 13, 2004.
(4)
According to theIllinois Pollution Control Board’s (“Board”) website, the document
filed on February 13, 2004 with the Board does not contain reasons whyRespondentbeJievestheAC
was improperly issued, as is required fora petition for review by 35
Ill. Adm. Code
108.206.
1
(5)
Furthermore,
pursuant to
35
Iii. Adm.
Code
101.400(a)(2),
a person other than an
individual must appear through an
attorney-at-law.
See also People
v. Patrick RobertLand
Trust,
PCB No. 01-135 (September 19, 2002), p. 4.
As
a corporation, the Respondent is not an individual
and is required to
appear through an attorney.
(6)
Accordingto the ARDC website (www.iardc.org),
Ray Landers, the signatory on the
document filed with the Board on February 13, 2004, is not licensed to practice law
in Illinois.
(7)
For the foregoingreasons, Respondent has not timelyfiled a petition for review, and
pursuant
to
415
ILCS
5/31.1(d)(1),
a
final
order
against Respondent including
the
finding of
violations as alleged in the AC and the penalty specified in 415 ILCS 5/42(b) is required.
WHEREFORE,
the
Illinois
EPA
requests
that
the
Board
issue
a
final
order
against
Respondent, including a finding ofviolations as alleged in the AC and the penalty requestedtherein.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
-
Complainant
DATED:
February 18, 2004
ichelle M. Ryan
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box
19276
Springfield, Illinois 62794-9276
(217) 782-5544
2
CERTIFICATION
Underpenalties asprovidedby law pursuant to Section 1-109 ofthe Code ofCivil Procedure,
the undersigned certifies that the statements
set
forth
in this
instrument
entitled MOTION FOR
DEFAULT
JUDGMENT
are
true
and
conect,
except
as
to
matters
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.
Michelle M. Ryan
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box
19276
Springfield, Illinois 62794-9276
(217) 782-5544
Dated:
February 18, 2004
3
PROOF OF SERVICE
I herebycertify that I did on the l8t~~
dayofFebruary, 2004 sendby U.S. mail, postageprepaid, a
true and correct copyofthe following instrument(s) entitled MOTIONFORDEFAULT JUDGMENT
To:
Equipping the Saints Ministry,
International, Inc.
Billie Landers, Registered Agent
5000 DickeyJohn Road
Auburn, Illinois 62615
and the original
and nine (9) true and correct copies ofthe same foregoing instruments on the same
date by U.S. Mail with postage thereon fully prepaid
To:
Dorothy Gunn, Clerk
Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
Special Assistant Attorney General
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box
19276
Springfield, Illinois 62794-9276
(217)782-5544
THIS FILING SUBMITTED ON RECYCLED PAPER

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