OR~G~NAL
Page
1
1
ILLINOIS POLLUTION
CONTROL BOARD
RECE~VED
2
January
22,
2004
CLERK’S OFFICE
3
CITY OF CHICAGO DEPARTMENT
OF)
APR
142004
STATE
OF ILLINOIS
4
ENVIRONMENT,
)
Pollution
Control Board
5
Complainant,
6
vs.
)
No. AC 04-13
7
EDDIE GREER,
)
(CDOE No.
03-02-AC)
8
Respondent.
)
(Administrative
9
)
Citation)
10
11
12
13
TRANSCRIPT
OF PROCEEDINGS had
in the
14
above-entitled
cause
on
the
5th
day
of
April,
A.D.
15
2004.,
at
1:00
p.m.
16
17
BEFORE:
BRADLEY
P.
HALLORAN,
Hearing
Officer.
18
19
20
21
22
23
24
Page
2
1
APPEARANCES:
2
3
OFFICE OF THE CORPORATION
COUNSEL,
4
CITY OF CHICAGO,
5
(121 North LaSalle
Street,
Room 600,
6
Chicago,
Illinois
60602,
7
312-744-0220),
by:
8
MR.
CHARLES
A.
KING,
9
appeared on behalf
of the City of
10
Chicago;
11
12
EDDIE
GREER,
13
(9923 Peoria,
9914 South Green,
14
and 605 West 59th Street,
15
Chicago,
Illinois)
16
appeared
on behalf of himself.
17
18
19
20
21
22
23
REPORTED BY:
SHARON BERKERY,
C.S.R.
24
CERTIFICATE
NO.
84-4327.
Page 3
1
INDEX
2
3
WITNESS
DX
CX
RDX
RCX
4
LINDA
KELLY
5
By
Mr.
King
7,
22
43
6
By
Mr.
Greer
39,
40
44,
63
7
EDDIE
GREER
8
By
Mr.
King
58,
63
9
10
11
12
EXHIBITS
13
NUMBER
MARKED
FOR
ID
RECEIVED
14
Complainant’s Exhibit
15
No.
1
20
16
17
18
19
20
21
22
23
24
Page4
I
THE HEARING OFFICER:
We are on the record.
Good afternoon,
everybody.
My name
is
Bradley Halloran,
I’m a hearing officer here with
the Illinois Pollution Control Board,
and I’m also
assigned to this matter,
which
is entitled City of
Chicago, Department of Environment,
Complainant
versus
Eddie
Greer,
the
Respondent.
And
the
PCB
number
±5
Administrative
Citation
4-13
also note for the record that today is
April
5th,
2004,
it’s approximately
1:04 p.m.
This
administrative
citation was filed by the City.
It
alleges that during an inspection of August
14th,
2003,
it was determined
that respondent violated
Section 2lPl and Section 21P7
of the Act.
As a
result of the August 14th,
2003 inspection and
subsequent administrative citation,
Mr. Greer filed
a petition for review disputing the violations,
and
that’s
why we are here today
This matter will be conducted
in
accordance with Section
108 and Section 101,
Subpart
F of the Board’s procedural
rules.
I also
note,
for the record,
that
I will not be making the
ultimate decision in the case.
That decision is
left up to the five board members
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page
5
1
I’m here to ensure an orderly hearing
2
and rule on any evidentiary matters that may arise.
3
There is no members of the public here; but
if they
4
were,
they’d be allowed to make a public comment or
5
statement that is relative to the matter.
6
With that said,
Mr.
King, would you like
7
to introduce yourself, please.
8
MR.
KING:
Charles
A.
King,
Assistant
9
Corporation Counsel for the City of Chicago,
10
representing the Department of Environment,
11
Petitioner.
12
THE HEARING OFFICER:
Thank you.
13
Mr. Greer?
14
MR. GREER:
Eddie Greer,
9923 Peoria,
9914
15
South Green,
and 605 West 59th Street.
16
THE HEARING OFFICER:
And
I talked to
17
Mr.
Greer a little bit about the procedure before
18
you came,
Mr.
King,
regarding opening,
case in
19
chief,
closing.
I said that sometimes the parties
20
like
to
waive
opening,
save
it
for
the
post-hearing
21
briefs.
22
But with that said,
Mr.
King,
it’s your
23
case
in
chief,
and
if
you
want
to
give
an
opening,
24
so
be
it.
And
if
you
do,
then
Mr. Greer will want
Page6
1
to have an opportunity,
as well.
2
MR.
KING:
I’ll
waive
opening.
3
THE
HEARING
OFFICER:
Okay.
4
Mr.
Greer, would you like to give an
5
opening
statement?
6
MR. GREER:
Momentarily,
yeah.
I really,
7
really
don’t
know
the
reason
why
I’m
here
for
the
8
Pollution
Control
Board.
That’s
the
first
9
statement
I
would
like
to
submit.
10
THE
HEARING
OFFICER:
Okay.
Then that’s your
11
opening?
12
MR. GREER:
That’s my opening.
13
THE
HEARING
OFFICER:
Okay.
Thank
you
very
14
much.
15
Mr.
King,
you
may
call
your
first
16
witness.
17
Or do we have any preliminary issues we
18
have
to
deal
with
before
Mr.
King
--
19
MR.
KING:
I
don’t
think
so.
20
THE
HEARING
OFFICER:
Okay.
You
may
proceed
21
then,
Mr.
King.
22
MR.
KING:
As my first witness,
I’d like to
23
call Linda Kelly.
24
THE
HEARING
OFFICER:
Ms.
Kelly,
would you
Page 7
1
just
step
up
here,
and
sit
here,
and
the
court
2
reporter will swear you in,
please.
3
(WHEREUPON,
the
witness
was
duly
4
sworn.)
5
THE HEARING OFFICER:
Let’s stop here for a
6
minute.
7
(WHEREUPON,
discussion
was
had
8
off
the
record.)
9
THE
HEARING
OFFICER:
Okay.
We
are
back
on
10
the
record.
11
LINDA KELLY,
12
called
as
a
witness
herein,
having
been first duly
13
sworn,
was
examined
and
testified
as
follows:
14
DIRECT
EXAMINATION
15
BY
MR.
KING:
16
Q.
All
right.
Would
you
please
state
your
17
full
name
for
the
record.
18
A.
Linda
D.
Kelly.
19
Q.
Would you spell your last name,
please.
20
A.
K-E-L-L-Y.
21
Q.
And,
Ms. Kelly,
what
is your occupation?
22
A.
I’m
a
project
coordinator
for
the
23
Department
of
Environment
and
the
permitting
and
24
enforcement
division.
Page 8
1
Q.
How long have you held that position?
2
A.
Maybe about six years.
3
Q.
And what are your job duties and
4
activities?
5
A.
I supervise and inspect the south side
6
of the city of Chicago,
from 35th Street to
7
138th
Street,
and
it involves working with
8
inspectors,
inspecting
permitted sites that are
9
permitted
by
our
department,
such
as
auto
10
junkyards,
recyclers,
and
other
types
of
11
facilities.
And
also,
working
with
the
State as
12
far
as
the
solid waste land with open dumping,
13
vacant
lots,
fly
dumping,
inspections
of noise,
and
14
other
things
like
that.
15
Q.
So you do
--
have
done
inspections
16
yourself of facilities in the city?
17
A.
Yes,
I
have.
18
Q.
Approximately how many inspections have
19
you
conducted?
20
A.
Well,
under my routine,
that are
21
permitted by the department,
I have,
approximately,
22
20 that
I inspect once
a month,
and then
I have
23
special sites that involve lots that are not
24
permitted
to
have
solid
waste
on
them.
And
I
have
Page 9
1
like about five or six different sites that
I
2
inspect,
not
once
a month but on a semi-routine
3
basis for clean up of those sites.
And then
I have
4
other projects that
I work on.
5
Q.
So in a typical month,
about how many
6
inspections would you say you do?
7
A.
About
40.
8
Q.
And
has
that
been,
approximately,
the
9
same
volume
for
the
time
you
have
been
working?
10
A.
Since
I started doing this job?
I
11
started this position with working with the
12
inspectors about two years now.
And it
is almost
13
approximate
--
yeah,
40 or more a month.
14
Q.
Have you had any particular training or
15
education
regarding
inspecting
sites?
16
A.
Yes.
I
have been trained by the U.S.
17
EPA
to
do
site
inspections.
Also,
we’ve
18
been
--
I’m
certified
to
inspect
a
solid waste dump
19
on
vacant
lots
by
the
IEPA.
20
Q.
What
did
that
certification
entail?
21
A.
It entails the City of Chicago
22
inspectors
to
be
able
to
cite
for state violations
23
on
property
in
the
city
of
Chicago.
24
Q.
Was there a training program or testing
Page
10
1
program
that
you
went through with IEPA to get that
2
certification?
3
A.
Yes,
I
did.
We
had
a
week
of
training,
4
and
we
had
a
--
about four days of reading and
5
going over the rules and regulations of the State.
6
And then we had to pass a written exam.
7
Q.
Now,
are
you familiar with the site at,
8
approximately,
601 West 59th Street?
9
A.
Yes,
I
am.
10
Q.
And
how
are
you
familiar
with
that
site?
11
A.
I’m
familiar
with
that
site
because
I
12
responded
to
--
our
division
also
responded
to
13
complaints.
And
I responded to a
complaint
14
concerning cars taken in the rear of the lot
15
from
--
stolen
from
--
from
people
and
taken
in
the
16
rear
of
the
lot
and
being
stripped.
And
that
there
17
was
a
lot
of
cars
dumped
near
that
site.
18
Q.
Have you done inspections of that site?
19
A.
Yes,
I
have.
20
Q.
Did
you
do
an
inspection
of
that
site
on
21
August 14th of last year,
2003?
22
A.
Yes,
I
did.
23
Q.
Now,
what
prompted
you,
on
that
24
occasion,
to go and inspect that site?
Page 11
you
that what prompted
A.
Well,
what
--
because we were
--
well,
I
had already submitted the site to the State from
previous inspections, and so
I had to go
back
--
you know,
it’s a routine
--
maybe once
a
month and check on the site to see if any cleanup
was
in progress, you know
Q.
Had
you
been
--
was
to go there on that date?
A.
No.
And also, from the cleanup on
another site,
I was informed that material from
that site
--
from this other site on 64th and State
was being
--
was taken to the 601-209 West
59th
Street
site.
So
I
went
there
to
check
on
the
condition
of
the
site
and
see
how
much
material
was
stored
on
the
site
Q.
Had
you
been
inspecting
the
State Street?
A.
Yes
Q.
And
how
did
you
--
what
caused
you
to
believe,
or
understand
--
or
how
did
you learn that
material
had
been
taken
from
that
site
to
the
59th Street site?
A.
From
Mr.
Frank
King
Q.
Who
is
Frank
King?
site on
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page
12
1
A.
He
was
the
operator-owner
of
the
6409
2
South State Street site.
3
Q.
And
did
he tell you that material had
4
been taken to the
59th
Street
site?
5
A.
Yeah.
That he had stored some material
6
there
and
some
heavy
equipment.
7
Q.
So
--
and
that
prompted
you
to
go
and
8
inspect the 59th Street site?
9
A.
Right.
10
Q.
On August 14th?
11
A.
That’s correct.
12
Q.
Now,
when
you
went
to
the
site
on
13
August
14th,
describe
what
you
did
and
what
you
14
saw.
15
A.
Well,
basically,
I
went
there
to
see
if
16
I
could
get
inside
the
site
to
take
some
pictures,
17
which
is
part
of
my
job.
And
the
site
was
secured,
18
I
couldn’t
get
on.
19
So,
basically,
from
the
alley,
I
just
20
took
some
pictures
of
what
I
could
see
from
the
21
gate entrance.
22
Q.
And
what
did
you
see
from
the
gate
23
entrance?
24
A.
Well,
I
observed
that
there
was
more
Page
13
heavy equipment and trucks than
--
that wasn’t
there before at the site.
And the yard appeared to
be full with material
But,
like
I
said,
I couldn’t get on the
actually see everything
Had
you
inspected
the
site
before
site to
Q.
that?
A.
Yes,
I
had.
Q.
Was
the
material
you
saw
on
August
14th,
had
you
seen
it
there in your prior inspections?
A.
Not
some
of
the
heavy
equipment.
It
was
like
a
front-end
loader
and
a
few other things.
And
mostly
trucks,
additional trucks
Q.
Okay.
I’m going to hand you a copy of
Administrative Citation
--
this is
a copy of the
actual
citation
--
04-13 that was filed with the
Pollution
Control
Board.
Now,
if you flip through that
--
I
have
to
get
my
glasses.
Okay.
Uh-huh.
Q.
Now,
if
you
flip through there,
towards
the
end
you
will
see
as
an
exhibit
--
THE HEARING OFFICER:
Keep your voice up,
please.
Thanks
A.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 14
1
BY MR.
KING:
2
Q.
There are
a series of photographs.
Do
3
you see these?
4
A.
Yes,
I do.
5
Q.
Can
you
identify
those
photographs?
6
A.
Yes.
It’s
the
photos
that
I
took
that
7
day
of
the
601-209
West
59th
Street
site.
And,
8
basically,
this
is
photos
--
the
first
photo
is
9
from
the
alleyway,
and
the
second
photo
is
when
I
10
was
looking
toward
--
through
the
fence
at
some
of
11
the
heavy
equipment,
and
trucks,
and
auto
junk
12
cars.
The
third
photo,
like
I
said,
is
more
13
trucks,
loaded
with
all
their
junk
cars.
And
then
14
the
fourth
photo
is
part
of
the
alleyway.
15
Q.
All right.
Now,
do
any
of
those
photos
16
depict
the
material,
that
you
mentioned
in
your
17
testimony
a
couple
minutes
ago,
that
you
noticed
18
there
that
you
had
not noticed before?
19
A.
Yes.
Basically,
a
lot
more
heavy
20
equipment
and
trucks.
21
Q.
Which
photographs
particularly
depict
22
it?
23
A.
No.
3
and
No.
2.
24
Q.
Let
me
see
that
a
second.
Page 15
A.
Uh-huh.
Did
I
say
No.
4?
Yeah,
No.
2
and
No.
3,
right
Q.
All
right.
Now,
when
you
mentioned
heavy
equipment
and
trucks,
what
is
the
material
that
you
saw
that
had
been
placed
at
that
site?
Were these operable, drivable machines, or were
they
wrecked
or
salvaged?
A.
Basically,
I couldn’t tell.
The only
thing
I
can
say
about
these
--
those
trucks,
is
they
were
loaded
with
some
of
the
auto
--
wrecked
trucks.
But
then
you
have
some
trucks
that
are
--
look
like
they
are
operable
As
far
as
the
heavy
equipment,
whether
or
not
it’s
operable
or
inoperable,
from
the
photos,
is kind of hard to tell which ones would
be
Q.
a couple
A.
Q.
A.
Q.
A.
Q.
All right.
Now,
if you would flip back
pages
the other way.
Oh.
Uh-huh
Another
couple
Okay.
Go back some more.
Yeah.
There?
Okay.
There.
Let’s
try
and
identify
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page
16
1
that page.
The page that we are looking at,
as a
2
heading at the top,
it says,
“State apparent
3
violations”?
4
A.
That’s correct.
5
Q.
And that would be
--
well,
let’s start
6
with
this
page.
7
Okay,
now,
the
page
I’m
referring
to,
8
for the record,
this is
the first page of the
9
materials appended to the administrative
10
citation
--
11
A.
Uh-huh.
12
Q.
--
after the citation, and affidavit,
13
and remittance
forms.
Now,
can you identify this
14
document?
15
A.
Yes,
it’s
the
Illinois
Environmental
16
Protection Agency’s open dump inspection checklist.
17
Q.
And did you prepare this document?
18
A.
Yes,
I
did.
19
Q.
Now,
would
you
--
looking at these
20
violations
that you identified in there
--
21
A.
Uh-huh.
22
Q.
.
And
this
document
identifies
apparent
23
violations
of
the
State
law
that you noticed during
24
your inspection;
is that correct?
Page 17
1
A.
Yes.
2
Q.
Now,
among them are violations
of
3
Section 21P1?
4
A.
Right.
5
Q.
And
21P7
of
the
Environmental
Protection
6
Act?
7
A.
Yes,
that’s correct.
8
Q.
How
did
you conclude that those sections
9
of
the
Act
had
been
violated?
10
.
A.
Well,
because
21P1
states
about
litter,
11
and
then
2lP
--
or
55
--
let
me
see.
Which
other
12
one
are
you
talking about?
13
Q.
This
one
here.
14
A.
955A.
15
Q.
Here,
this one.
16
A.
Okay.
Yeah,
2lP7.
Deposition of
17
general construction or demolition debris,
or clean
18
construction
or demolition debris.
19
Q.
Now,
what conditions at the site that
20
you
observed caused you to conclude that those
21
violations had happened?
22
A.
Because they had a lot of
--
to
the
23
west
--
you
probably
couldn’t
see
it real good on
24
these
--
from
these
photos.
But
they
had
a
lot
Page 18
1
like
waste
soil,
and
they
had
construction
material
2
like wood and other debris mixed with bricks and
3
stuff
that
was
on
the
ground.
4
Q.
Did that appear to be waste to you?
5
A.
Yes.
6
Q.
Was
it
in
a
condition
where
it
could
7
have
been
used
as
construction
material?
8
A.
No,
it
was
mounded
with
the
rest
of
the,
9
like waste
--
autos,
auto parts,
rubbish,
waste
10
scrap
metal,
all
of
it
was
all
mixed
up
and
mounded
11
to
the
west.
12
Q.
All
right.
13
A.
And
it
was
mixed
with
soil.
So,
14
basically,
that’s
considered
waste
when
it’s
mixed
15
like that.
That’s not clean soil.
16
Q.
Thank
you.
And
how
about
the
litter?
17
A.
The
litter
was
the
scattered
litter
that
18
was
all
over
the
site,
paper,
rubber tubing,
and
19
metal embedded in the ground,
cans,
garbage,
some
20
tires,
paper,
small
--
like small pieces
of scrap
21
metal,
waste auto parts, maybe
tools,
small pieces
22
of tools,
and all that scattered all over the
23
ground.
24
Q.
All right.
Now,
looking at the
Page
19
1
following pages of this
--
of
the
administrative
2
citation, turning a couple pages further on,
3
there’s a page that’s headed,
City of Chicago
4
Department of Environment Narrative?
S
A.
Uh-huh.
6
Q.
What’s that document?
7
A.
That,
basically,
is
a narrative stating
8
what
I saw and what happened at the site when
I was
9
there.
10
Q.
Did you prepare that document?
11
A.
Yes,
I did.
12
Q.
When did you prepare that?
13
A.
On the exact date that
I wrote
it,
or do
14
you mean dated it?
15
Q.
If you recall.
16
A.
No,
I don’t remember the date,
the exact
17
date that
I wrote
it.
18
Q.
Did you prepare it shortly after you did
19
the inspection?
20
A.
Yeah,
after the inspection.
21
Q.
Within
a day,
two days,
a week?
22
A.
Maybe within
--
let me see if
I can
23
tell.
Within like about two weeks.
Two weeks
--
24
yeah,
two weeks after
I
--
Page 20
that
Q.
Okay.
And then the next page following
narrative document?
A.
Uh-huh.
Yes.
It’s the site map.
Q.
Did you prepare that?
A.
Yes
I did
Q.
And what
is that document?
A.
That’s,
basically,
a sketch of where
I
took the photos,
where
I was standing, and the
direction that
I had the camera
Q.
All right
MR.
KING:
I move that the attachments to the
administrative citation, which comprise Ms.
Kelly’s
report,
be admitted into evidence
THE HEARING OFFICER:
Do you want to
Complainant’s Exhibit No.
1,
it would be the
administrative citation with the attachments
admitted into evidence?
MR.
KING:
Yes
THE HEARING OFFICER:
Thank you.
Complainant’s Exhibit No.
1
is admitted
do--
whole
being
evidence
(WHEREUPON,
said document,
previously marked Complainant
Exhibit No.
1,
for identification,
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
into
22
23
24
MR. KING:
was offered and received in
evidence.)
I have no further questions for
Page 21
Ms. Kelly
THE HEARING OFFICER:
Okay.
Thank you.
Mr.
Greer,
you’re free to cross-examine
Ms.
Kelly,
if you so choose, and ask her questions.
MR.
GREER:
Okay
THE HEARING OFFICER:
Take your time.
MR. GREER:
I don’t even know the exhibit.
THE HEARING OFFICER
Okay
MR. GREER:
I don’t even know the exhibit.
THE HEARING OFFICER:
Well,
do you have the
administrative
citation itself?
MR. GREER:
No
THE HEARING OFFICER:
Do you have
a copy of it
so he can look at it?
MR.
KING:
Mr. Greer
-
WHEREUPON,
the document was
tendered.
THE HEARING OFFICER:
Please don’t mark
it up.
That’s the one that’s going into evidence.
MR.
KING:
If you would like to take
a few
minutes to look it over,
we can go off the record.
)
1
2
3
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8
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16
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18
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20
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22
23
24
Page22
1
THE HEARING OFFICER:
Yeah,
we can go off the
2
record.
3
(WHEREUPON,
a recess was had.)
4
THE HEARING OFFICER:
Back on the record.
And
5
before we proceed with Mr. Greer,
Mr. King said he
6
has one more question,
I
believe,
of Ms. Kelly.
7
MR.
KING:
All right.
Yes.
Thank you.
8
FURTHER DIRECT EXAMINATION
9
BY MR.
KING:
10
Q.
Ms.
Kelly,
this administrative citation
11
was issued to Eddie Greer.
How did you determine
12
that Eddie Greer was responsible for the violations
13
you observed at the site?
14
A.
I put Eddie Greer,
because when we did a
15
title search of the property, maybe two or three
16
years ago,
his name came up on the title search.
17
So
I did it as owner-operator,
as owner of the
18
property.
19
Q.
And did you,
subsequently,
have any
20
contact with Mr. Greer?
21
A.
I talked to him on the phone,
and I’ve
22
met him on cleanup of another property.
23
Q.
Okay.
24
A.
Cleaning of the property.
We talked
Page 23
about cleaning the property
Q.
What did he say in those conversations?
A.
Basically,
that he just
--
and plus,
we
had a meeting in our office with Johnna,
my
supervisor,
Johnna Pothoff, and we talked about
what he needed to do to bring the 1~t into
compliance
Q.
And did he,
during those conversations,
demonstrate
--
or head up responsibility for that
piece
of property?
A.
What do you mean demonstrate enough?
Q.
Did he
--
based on those conversations,
was it your impression that he was the owner of
that property
A.
Yes.
Based on the lot,
he was the owner
of the property
Q.
All right.
Did he ever indicate that he
wasn’t the owner of the property?
No.
He just,
basically,
said
that
--
also that he had acquired the
property.
When
I first met him,
he talked about
how he had acquired the property from some previous
owner.
And some material was there.
And I,
basically,
informed him that he
7
A.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 24
1
was
--
he comes up as the owner
--
owner-operator.
2
He’s the present owner,
that he’s responsible for
3
the property and cleanup of the property.
4
MR.
KING:
All right.
Thank you.
5
THE HEARING OFFICER:
Thank you, Mr.
King.
6
Mr. Greer,
you’re
on.
7
MR.
GREER:
These items
on the photo,
8
Your Honor,
are
--
these items are not even mine.
9
And
I don’t have anything to do with these.
10
The only thing that
I have to do with is
11
the truck,
the moving equipment.
Just the truck
12
and one back
--
one payloader.
13
Other than that,
the stuff belongs to a
14
guy named Columbus Don,
that
--
prior to this time,
15
Linda Kelly spoke to this guy.
He had some kind of
16
recommendation from another source
of the city.
17
THE HEARING OFFICER:
Excuse me,
Mr.
King, you
18
have
--
19
MR.
KING:
If Mr.
Greer is going to tell his
20
story,
maybe we should just put him under oath and
21
he can testify.
22
MR.
GREER:
That’s
fine.
23
THE HEARING OFFICER:
Let’s do that.
Raise
24
your right hand and Sharon will swear you in.
Page 25
1
(WHEREUPON,
the witness was duly
2
.
sworn.)
3
THE HEARING OFFICER:
Thank you.
4
You can proceed,
Mr. Greer.
5
MR. GREER:
Yes.
6
THE HEARING OFFICER:
You can start at the
7
beginning now that you are under oath.
8
MR.
GREER:
About that this stuff is not mine?
9
THE HEARING OFFICER:
Right.
10
MR.
GREER:
Well,
the pictures that
I see
11
before me
--
12
THE HEARING OFFICER:
You’re referring to
13
Complainant’s
Exhibit No.
1,
the photos that are
14
attached to the exhibit?
15
MR.
GREER:
Exactly.
16
The four photos that
I
see,
the only
17
thing that
I own,
myself,
is the red truck and
18
payloader.
19
THE HEARING OFFICER:
And that’s in photograph
20
number
--
21
MR.
GREER:
That’s the photo
--
in No.
3.
22
Photo
3,
exactly.
23
The rest
of these items belongs to a guy
24
named Columbus Don.
Prior to this investigation of
Page 26
Linda Kelly,
she spoke to this guy, and he had told
her that he was in the process of cleaning up
But he had an ordinance from someone in
the City to relocate.
So,
the guy, he came to me
and said that,
“Look,
I have my license and the
City is buying my property on Canal Street”
--
you
can strike it
if it’s the wrong address, but it’s
Canal
--
This guy is Mr.
Don
THE HEARING OFFICER:
you’re referring to?
MR. GREER:
His name
is Don King.
I’m sorry,
Don King.
His name
is Columbus Don.
THE HEARING OFFICER:
Okay.
MR.
GREER:
And this guy,
Linda spoke to him.
And she talked to him briefly about some things.
And he said that he was encited for
condemnation on his property.
And he needed a
place
to go to
So the City says,
“Find a place.”
So he
found my place.
It’s zoned for what he wants to
do.
So
I told him,
“Okay,
you can come
in,
and you can do it.”
And so,
we talked about
the
money,
the pay, and financially how much rent
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 27
1
wanted.
That’s another whole source anyway,
that
2
goes to another chapter in this.
3
And
so, he moved his stuff there.
So,
I
4
guess,
this guy didn’t have any license.
I don’t
5
know
--
I don’t even know the bottom half,
but the
6
bottom line was that we had to clean up on another
7
site of mine that was 6S34 South State,
6539 South
8
State.
9
So this property that we had cited to
10
clean up prior to this became
a catastrophe.
11
Because it was a site for a fuel station
--
for the
12
mayor to open up a fuel station.
13
So we motivated and dedicated a lot of
14
our time over there at this site on 65th and State.
15
Columbus Don was running this site because he had
16
rented this from us also.
17
Not only that,
the site on 65th and
18
State,
someone
--
I don’t know the name of the
19
person that gave him the permission
--
bought this
20
stuff
--
bought his lot from him personally and
21
said that he could move
the stuff if he finds a
22
place to move it to.
So them two lots we had open,
23
so he moved his stuff there.
24
Now,
we were focusing a lot of time on
Page 28
1
65th and State
to clean up.
So,
I told the
2
guy
--
you know,
well,
he was telling me back and
3
forth that,
“Hey, you get
a lot of stuff out
of
4
here,
because, you know,
eventually,
I want to
5
clean the whole lot, because
I want to get
a tow
6
service there.”
7
And he was going to go in
--
he was
8
going to be my partner.
So one thing led to
9
another
--
we had to get on the site on 65th and
10
State.
We had
--
they was
--
they was
--
they was
11
like
--
12
THE HEARING OFFICER:
Mr.
Greer,
I guess
13
before we go any farther,
do you have any questions
J
14
of Ms. Kelly?
15
MR. GREER:
What?
16
THE HEARING OFFICER:
Do you have any
17
questions or cross-examination of Ms. Kelly?
18
Or do you just want to give a little background and
19
just ask her some questions?
20
MR.
KING:
I can cross-examine her,
but some
21
things
--
from this lecture,
she will hear some
22
things she didn’t
say.
But
I don’t
--
I don’t have
23
too much to say to her,
I’m just listening and
24
finding out the details.
Page 29
THE HEARING OFFICER:
Okay
MR. KING:
Because I’m kind of
apprehensive
--
I’m
kind of baffled in this.
I
don’t know where I’m at, you know,
to be honest
with you
Because,
gosh,
I’m getting sued by some
City attorneys for this same lot for $3,000.
The
Department
of Administrative Hearings wants $3,000.
Now I’m getting cited with pollution for another
$3,000.
So I’m lost
I don’t even know
--
except
to
this while
be here now.
And,
to be honest
you,
I have been working with the City for,
maybe
20 years,
30
And the steps that the City takes when
they
--
when they give you a citation
--
and,
all
of
a sudden,
I just got these citations from the
Pollution Board for
--
I don’t know
--
I don’t have
them in front
of me, but
I think
it’s $1,300
a
piece for each citation.
t was just dropped to my house one day.
It wasn’t even a
--
it wasn’t even no kind of plot
to
--
it wasn’t no steps.
I know that sometime you
would get tickets, you’d be issued a ticket
to,
take
with
gosh,
Gosh,
I
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 30
1
“Hey,
look,” you got
--
you got dirt,
you got this,
2
“here is your citation.”
3
Now,
you should
--
if you don’t respond
4
to this
citation
--
and then they take the next
5
step.
The City works with you very well,
I got to
6
admit.
7
On this
right here, with this pollution
8
control,
I never got anything but
--
9
THE HEARING OFFICER:
Well,
let me qualify on
10
the transcript and the record, the “Pollution
11
Board,” I’m not sure what you’re referring to.
12
What we are dealing with today
is, when the City
13
sent you an administrative citation, that’s
the
14
City’s.
lS
MR. GREER:
Exactly.
16
THE HEARING OFFICER:
Okay.
Now,
I am a
17
little confused.
When you’re saying the Pollution
18
Board sent you
--
19
MR.
GREER:
Well,
the Pollution Board
--
the
20
pollution
--
the IPCB
--
IPCB
--
Control.
21
THE HEARING OFFICER:
Can
I take
a look at
22
what you’re referring to, please?
23
(WHEREUPON,
the document was
24
tendered to the hearing officer.)
Page 31
MR. GREER:
That’s my copy
MR.
KING:
Can we go off the record again?
THE HEARING OFFICER:
We can go off the
record,
sure.
(WHEREUPON,
discussion was had
off the record.)
THE HEARING OFFICER:
We just took
a little
moment to try and clarify some things.
Mr. Greer
was saying that the Pollution Control Board has
been citing
--
and,
in fact,
we talked,
and that’s
not the case
t is the City with the administrative
citation,
but,
I guess,
earlier, previous citations
were dealt with in another way,
Mr. King?
I’m
sorry,
correct?
MR.
KING:
Yes.
Mr. Greer had also received
citations,
and the City
--
that were adjudicated in
the City’s administrative hearings department.
THE HEARING OFFICER:
All right.
MR.
KING:
Which is
a,
you know,
different
--
a separate forum
MR.
GREER:
But
I didn’t receive any tickets
from them
THE HEARING OFFICER:
I’m sorry, you didn’t
I
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 32
1
receive any tickets from whom?
2
MR. GREER:
No.
From Administrative
--
3
THE HEARING OFFICER:
Well, you haven’t
4
received any tickets from the Board,
I’ll clue you,
5
that doesn’t happen.
I mean,
do you understand
6
that it’s not the Board pursuing you?
7
MR.
GREER:
I’m saying administrative
8
hearing
--
administrative hearing.
I
didn’t
9
receive any tickets from them guys.
10
The tickets was going to the wrong
11
address that they were
--
any tickets.
I
wasn’t
12
getting anything.
13
THE HEARING OFFICER:
All right.
We’re going
14
off a little
--
a little astray here.
15
MR.
GREER:
Yeah.
16
THE HEARING OFFICER:
But do you understand
17
that the Illinois Pollution Control Board
is not
18
prosecuting you?
19
MR. GREER:
Okay.
20
THE HEARING OFFICER
Do you understand7
21
MR. GREER:
So who is prosecuting me?
22
THE HEARING OFFICER:
The City.
23
MR.
GREER:
Administrative hearing,
right?
24
THE HEARING OFFICER:
This is an
Page 33
administrative hearing
MR.
GREER:
Yes
THE HEARING OFFICER:
The City has filed a
citation against you
MR.
GREER:
Okay
THE HEARING OFFICER:
Now,
it’s come out in
the last couple seconds that you haven’t ever
received the citation.
Now,
you can
--
MR. GREER:
I haven’t
-
THE HEARING OFFICER:
--
proceed along that
course,
if you’d like,
I don’t know
MR. GREER:
I haven’t
--
I haven’t received
any citations.
That’s what
I was saying,
that
--
THE HEARING OFFICER:
Okay.
This is kind of
an anomaly here.
And Mr.
Greer has kind of taken a
course and is not crossing it
And it sounds like he
is, pretty much,
presenting
his case in chief.
I’m going
to allow
Mr.
King
to make
a statement,
or a question,
or
whatever you want to do,
Mr. King
MR.
KING:
First,
I’d like the record to
reflect that Mr. Greer was served with this
administrative citation.
In fact,
he has his copy
with him.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 34
1
And my understanding
is that the
2
Department
of Environment also issued him other
3
tickets under our own system.
But that’s really
4
not
relevant
to
the
proceedings today.
I don’t
5
want to get off on that tangent.
6
THE HEARING OFFICER:
Right.
I don’t want
to
7
either.
I think we’re
just going to clarify
8
Mr.
Greer’s
questions
regarding
who
is prosecuting
9
whom.
10
It
sounds
like
Mr.
King
is
finished
now.
11
Now,
Mr.
Greer
--
and
Mr.
King
has
12
already responded
--
you said you’ve never received
13
the
administrative
citation.
And,
from my
14
understanding,
it looks like you’ve brought
it with
15
you
today.
This
is
Administrative
Citation
4-13,
16
the Pollution Control Board.
17
MR. GREER:
Right,
I received that.
But
I
was
18
just saying that with Illinois Pollution Control,
19
like
you
said,
that
don’t
have
anything
to
do
with
20
it.
21
But
the
Department
of
the
Environment,
22
that’s all
I received from them.
I’m talking about
23
I received that from them,
but
--
24
THE
HEARING
OFFICER:
Well,
“that”
being
what?
Page
35
MR. KING:
That, meaning
that the citations
that
they
was
given prior to that was going to
someone else.
Because had
I receive them,
I
probably wouldn’t have been here
today.
THE HEARING OFFICER:
Well,
we’re not there on
MR. KING:
Okay.
That’s fine
THE
HEARING
OFFICER:
We’re
here
on
the
City
Department
of Environment.
Their case number
is
03-02-AC, Administrative
Citation.
MR.
KING:
Right
THE HEARING OFFICER:
Their corresponding
number
is AC4-13
Now,
you
said
you’ve
received
this
citation
--
MR.
THE
MR.
THE
MR.
THE
GREER:
HEARING
GREER:
HEARING
GREER:
HEARING
--
we don’t
MR.
GREER:
THE
HEARING
Yes
OFFICER:
Yes
OFFICER:
Yes
OFFICER:
want
to
Okay.
OFFICER:
--
from
the
City?
Okay
Now,
we
can
start
get
off
on
a
tangent.
That’s
fine
That,
right now,
is,
1
2
3
4
5
6
those.
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
with
Page 36
1
pretty
much,
irrelevant.
But
we’re talking about
2
this
one
in
front
of
us.
3
MR.
GREER:
Okay.
4
THE
HEARING
OFFICER:
So,
with
that
said,
do
5
you
have
any
questions
of
Ms.
Kelly?
Or
you
may
6
proceed with what,
I assume,
is your case in chief
7
and your narrative
summary of the situation.
8
MR. GREER:
Yeah.
Well,
like
I was saying,
at
9
first,
the
items
on
the
photos
1
through 4,
I don’t
10
even own none of them items,
other than the truck
11
and
the
payloader.
The
other
items
was
a
guy
--
it
12
was
Columbus
Don.
13
And,
as
we
speak
now,
the
things
that
14
you
see
in
the
photo
are
no
longer
there.
The lot
15
is like 35 percent
clean.
16
And they were
--
someone was cleaning up
17
the lot prior to that and was stopped by some City
18
inspector.
It would probablyhave
been cleaned up
19
awhile
back,
but
someone
had
stopped the cleanup.
20
Some
City
inspector
stopped
the
person
from
21
cleaning up the lot.
22
I had photos
to show that
it was clean,
23
but these are
--
I grabbed the wrong photos.
So
I
24
don’t have them with me at this particular
time.
Page 37
1
didn’t bring
them.
2
THE HEARING OFFICER:
Okay.
3
MR. GREER:
Right.
And we have
--
it
was
a
4
couple
of
guys
--
it
was
a couple
of guys or trucks
5
that
was
fly
dumping.
On
the
Photo
4,
you’ll
see
6
that
it’s
a
lot
of
debris
on
the
outside
of
the
7
fence.
8
And
we
got
a
lot
of
fly
dumpers.
We
9
kind
of
--
kind
of
put
a
lock
on
it,
because
10
we
--
we
had
a
guy
staying
out
there
just
waiting
11
on them.
12
And he didn’t get a license plate
13
because
his
trucks didn’t have them on there,
14
but
we
kind
of
like
stopped
a
lot
of their fly
15
dumping.
16
This
(indicating)
is
a
street.
But
--
17
it’s
called
a
street.
It looks like an alley but
18
it’s known as a street.
And
I think the street
is
19
called
--
it’s
Wallace.
20
And
we
stopped
a
lot
of
that
fly
21
dumping.
That’s outside of our premises.
22
THE HEARING OFFICER:
You’re referring
to
23
Photograph
No.
4
--
24
MR. GREER:
Exactly.
Page 38
1
THE
HEARING
OFFICER:
--
The Complainant’s
2
Exhibit No.
1?
3
MR.
GREER:
And
also
you
can
--
Exhibit
1
4
also.
And
not
even
that
--
5
THE HEARING OFFICER:
Exhibit
1 or
6
Photograph
1?
7
MR. GREER:
It’s Photograph
1,
and
it’s
8
Photograph
4.
That’s the street.
9
THE
HEARING
OFFICER:
Okay.
10
MR. GREER:
That’s where they do the fly
11
dumping at.
And we had one little person to stay
12
with us
--
well,
one little,
small vehicle to sit
13
on the side so that he wouldn’t be known
to the
14
viewer.
15
And
he
caught
some
guys
coming
to
16
fly
dump.
And
we
got
credit
from
the
alderman
17
and
another
precinct
captain
guy
and
also
an
18
inspector.
19
And
we
clean
up
a
lot
of
stuff
that
they
20
dumped on there.
We clean a lot of tires up that a
21
lot
of
fly
dumpers
did.
22
You
know,
we
did
a
lot
of
improvement
to
23
that
street,
with
our
own
equipment.
24
THE
HEARING
OFFICER:
Do
you
have
any
Page 39
questions of Ms.
Kelly?
CROSS -EXAMINATION
BY MR.
GREER:
Q.
When you spoke
to
Don,
did
he
let
you
that
--
did you ever speak to Don before?
you
ever
spoke
to
Don?
A.
Yeah.
Q.
And
did
he
let
you
know
that
that
stuff
that
he
was
cleaning
up
in
there,
he
was
going
to
get
that
stuff
out,
and
someone
stopped
him
from
cleaning up
in there?
I don’t know who
the
inspector
was,
but
he
said
someone
stopped
him,
so
he didn’t go back.
He would be here
-
a slipped disk.
you spoke to that
A.
On
one
--
one
of
the
occasions
when
I
did
meet
him.
And
he
stated
that
he
was
there
to
clean
up
the
site
Q.
Yeah,
right
A.
So
that
he
wanted
to
get
like
a
permit
to
use
the
yard.
And
then
after
that,
I
didn’t
see
him
anymore.
Q.
Yeah.
back
-
--
so
know
Have
his
say
today for a witness but
But,
needless to
guy?
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 40
1
A.
And
I
don’t
know
--
I never talked to
2
him
anymore,
if
someone
had
came
and
stopped
him
3
from cleaning up the site
--
4
Q.
Right.
Exactly.
That was just
--
the
5
items
that
you
see
were
his.
And
the
guy
got
kind
6
of
sick,
real
bad,
and
he
left
a
lot
of stuff on me
7
to clean up.
8
So
I
was
--
mostly,
he
tried
to
do
what
9
he could do, but he couldn’t do a lot.
So them
10
items
that
you
see
there belong to that guy.
11
And
--
but we
--
“we,”
meaning
me,
and
a
12
crew
of mine,
we got some items out of there.
The
13
stuff that you see in the photos are no longer
14
there.
15
THE HEARING OFFICER:
Mr.
King?
16
MR. KING:
If Mr. Greer doesn’t have any other
17
questions for Ms.
Kelly,
I just have two quick
18
ones.
I’d
like
to
clarify
a
couple
things.
19
THE
HEARING
OFFICER:
Okay.
Do
you
have
any
20
other questions
of
--
21
MR. GREER:
Oh, yeah.
22
FURTHER CROSS-EXAMINATION
23
BY MR.
GREER:
24
Q.
About the stolen cars?
You said that
Page 41
1
there
was
stolen
cars
in
the
--
you were meaning
2
like
in
the
alley
there,
like
in
the
back
of
3
that
--
because
they were doing that also.
4
They were coming with vehicles,
parking
5
on
the
outside,
stripping
cars
out
there
also.
I
6
didn’t
--
when
you
said
the
back,
I
didn’t
really
7
know
the
back
of
what
you
--
8
A.
Well,
basically,
I went
to the
--
9
because
of
the
fact
that
I
had
a
complaint.
And
10
that’s what responds me to a site
--
11
Q.
Right,
exactly.
12
A.
--
if someone makes
a
complaint.
And
I
13
did
see
--
that
was
way
on
the
early
--
a couple
14
years
ago.
And
--
about the
--
and
I
did
see
a
car
15
back there stripped.
16
Q.
Yeah.
17
A.
That’s what led me to your site.
18
Q.
Exactly.
19
A.
But,
I
believe,
the
police,
20
basically
--
when the City
--
when
I let my
21
management
know
--
I believe the City
owns
the
lot
22
that’s
further west.
So when they sealed that
23
property
off,
and
the
company
that’s
south
of
you
24
sealed off their property,
the stolen cars
--
the
Page42
1
people
that
were
stealing
the
cars
back
there
--
2
they
were
--
they
weren’t
able
to
get
back
there
to
3
do that anymore,
so that stopped.
4
Q.
Right.
5
A.
And
then
we
continued
with
the
6
inspections
of your
--
of your property
--
of that
7
property
--
of your property.
8
Q.
Exactly,
right.
9
MR.
GREER:
I can understand what she’s
10
talking about,
right.
Yeah.
11
We
had
a
lot
of
that theft also in our
12
yard,
you
know.
So
I
can
--
I
can
relate
to
that
13
statement.
So
--
14
BY MR.
GREER:
15
Q.
Let
me
see.
And
you
said
--
you
said
16
Frank
King
was
the
owner?
17
A.
No, not at that yard.
18
Q.
You
was
just
stating
--
19
A.
When
I
was
talking
to
Frank
King
at
the
20
60
--
before.
21
Q.
65th?
22
A.
Yeah,
65th Street
site.
23
MR. GREER:
Okay.
At this particular
time
I
24
have no further questions
at this moment.
Page 43
THE
MR.
BY MR.
KING:
HEARING
OFFICER:
Okay.
Mr.
King,
redirect?
KING:
Yes
REDIRECT EXAMINATION
Q.
Mr. Greer asked you about if you had
spoke
to
Don.
Who
is
Don?
A.
Columbus
Don.
name
two different
ways.
or Columbus Dan
MR. GREER:
Right
BY
THE
WITNESS:
A.
And
I
met
him,
initially,
at
the
site.
And
he
--
his
property
is
on
the
west
side,
on
Flournoy.
The
City
took
over
his
property.
had
an
auto
junkyard,
so
he
stated
that
he
wanted
to
have
an
auto junkyard at this
site
And
I
informed
him
that
he
could
not
have
an
auto
junkyard
at
this
site
until
that
site
was
cleaned
up
And so he
--
one other time he stated
that he would be cleaning the site up
BY MR. KING:
He
Oh,
my
--
they have
his
It’s
either
Columbus
Don
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Q.
Was
that
site
ever
permitted
as
a
waste
Page 44
1
handling disposal
--
or waste disposal
facility?
2
A.
That
area,
601,
it
was
in
our
3
department.
I don’t know how many years ago it
4
was,
but
it
was
once
permitted
as
an
auto
junkyard.
5
Q.
But
was
it
ever
permitted
as
a
waste
6
disposal or a waste handling facility?
7
A.
No.
8
Q.
Thank you.
9
MR.
KING:
No
further
redirect.
10
THE
HEARING
OFFICER:
Thank
you.
Any
further
11
recross,
Mr.
Greer?
12
RECROSS-EXAMINATION
13
BY MR.
GREER:
14
Q.
When he says “waste,”
I don’t
--
I
15
don’t
--
waste
meaning
--
waste meaning
like cars
16
or something?
Heavy vehicles,
is that considered
17
waste?
18
A.
(No
audible
response.)
19
Q.
I’m
asking
--
20
A.
Oh,
you’re
asking
me?
Okay.
21
Q.
Whether
it’s
the
heavy
cars
that
are
22
considered
waste,
or
are
the
--
because
that’s what
23
he had in there.
He had like
--
he had like cars,
24
pickup
trucks,
and
just
like
what
a
--
somewhat
a
Page 45
wrecking outfit would have,
like
C & D
--
before
C
&
D
--
like
A-Reliable.
You
know
there
was
a
place,
he had something
like that
So waste
--
it
may
look
like
it
was
waste because
it was going out to be recycled for a
recycling outfit,
like Cozzi’s or either General
Iron.
It may look like waste,
but it
was
like
--
that
was
his
way
of
living
from
his
sources
That’s
the
way
he operated over there on
the
west
side.
So,
waste,
I
really
can’t
--
I
don’t
-
A.
Well,
on
that,
the
definition
of
waste
is,
basically,
when
you
don’t
have
a
permit
--
Q.
Oh.
A.
--
from our department
to have an auto
junkyard,
then the storage of the material
is
considered waste.
Because
it’s dismantled
cars,
you have waste tires that was on the ground, you
have 55-gallon metal
drums that were scattered all
over,
you
had
gasoline tanks
from vehicles,
you had
a
lot
of
mounded
soil
that
was
mixed with
--
Q.
Right
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
A.
--
C & D waste,
along with litter,
Page 46
debris,
household
garbage.
When this type of
material
is all scattered all over the ground and
it’s
not
--
it’s
not
stored
in
the
site
according
to
the
City’s
regulations
of
being
18
inches
off
the
ground.
And
the
ground
has
to
be kept clean.
No
waste
liquids from these autos
--
Q.
Exactly
A.
lot
of
that
--
poured
into
the
ground.
You
had
a
So,
therefore,
that’s
why
it
was
considered
an
open
dump,
because
it
was
not
permitted,
and
this
material
was
stored
all
on
the
ground,
which
is
against
City
ordinances.
Q.
To
my
understanding,
that
--
the
reason
why
it
was
probably
scattered
that
way
is
because,
in
order
to
load
something
to
get
it
out,
it
would
have
to
be
like
consolidated
to
a
fact
that
you
would have to get it all together and put it
in
--
these
recycling
outfits,
they
don’t
take
everything.
You can’t just give them everything.
They
will
refuse
the whole load,
and we
have to bring the whole
thing back to them and load
it
on
that
site.
And
in
the
process
of
going
to
a
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
they
So
Page 47
recycling know as General
Iron,
Cozzi,
there
is
steps
that
you
would
have
to
take
The
gas
tanks
was
on
the
ground
because
can go to recycling
A.
Right
Q.
That would blow the whole thing.
they
take
them
off,
too,
like
put
them
in
a
container,
drain
the
liquid.
So
it
was
a
process
he was probably taking.
But they probably
--
you
know,
they
probably
was
there
because
he
was
loading
A.
Okay
Q.
He told
me
he
was
loading
everything.
But
he
had
got
stopped,
so
--
he’s
not
even
here
even
to
state
his
case,
but that’s all
I can say on
his behalf
--
know.
A.
Q.
Right
--
because
that’s what he
told
me,
you
A.
But
it’s
--
it says
in
the
ordinance
you
cannot
put
that
material
on
the
ground.
When
you
unload
it
--
that’s
why
the
City
requires
you
have
a
--
the
lot
has
to
be paved with concrete
And when you are dismantling the car,
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 48
1
you
have
to
put
that
material
on
that
concrete
and
2
drain the material into 55-gallon drums or some
3
type
of
AST,
above
ground
storage
tank,
that
has
a
4
secondary
storage
around
it
so
that
the
liquids
do
5
not
go
into
the
ground.
6
Q.
Exactly.
7
A.
And
then,
once
you
get
finished
8
dismantling
the
car, you’re supposed to have racks
9
where
that
material
is
stored
and
kept
until
you
10
remove
it,
or
either
you
sell
it
to
the
public.
11
Whatever
is
usable
--
was
nonsaleable,
you
take
to
12
a scrap metal dealer.
Therefore,
you would keep
13
the
yard
clean.
14
Q.
Yeah.
I don’t think he really never got
15
to the point
of getting any racks,
because he might
16
have
found
out
--
he had told me he
had
a
permit
to
17
move there.
That’s the reason why he moved his
18
stuff
there.
But
he
never,
probably,
got
to
the
19
part to even build any racks.
20
If he found out that he could have what
21
he
had
in
order
to
get
what
he
wanted,
it
would
22
have to be clean.
So you can’t
get
it
unless
you
23
do it.
24
So,
I guess
--
in other words,
you can’t
Page 49
1
get
the
permit
or
what
the
City
wants
to
issue
you,
2
until you clean
the, you know,
the premises up.
3
A.
Right.
4
Q.
So, you know,
that’s what
I looked at.
5
And,
right now,
we is in this process
of still
6
cleaning some items
that he left.
So
it’s
7
three-quarters percent clean now.
8
So
we’re
in
the
process
of
9
getting
--
getting the whole
thing resolved by
10
cleaning everything up that he
did
leave
there.
11
THE
HEARING
OFFICER:
Any
other
questions
of
12
Ms.
Kelly?
13
MR.
GREER:
No, not at this time.
14
THE HEARING OFFICER:
You may step down or
15
aside.
Okay.
Thank
you.
16
Mr.
King?
17
MR. KING:
I
--
18
THE HEARING OFFICER:
You know what
--
did you
19
have any re-redirect,
Mr. King?
I’m sorry.
20
MR.
KING:
No.
21
THE HEARING OFFICER:
Okay.
Thank you.
22
Are
you
going
to
call
any
more
23
witnesses,
or
are
you
going
to
rest?
24
MR. KING:
No,
I have no
--
Page 50
he’
5
THE
HEARING
OFFICER:
Okay.
All
right.
MR. KING:
I have no further
--
I’m done with
my case
THE
HEARING
OFFICER:
Thank
you
Mr. Greer,
I know
--
it’s your case in
chief now.
I know you’ve testified
to some
extent,
kind of out of turn, but that’s fine
Do
you
wish
to
give
further
testimony,
or
do
you
have
any
witnesses
to
call?
MR.
GREER:
No.
As
I
was
saying
at
the
minute
--
with the court reporter,
I
was
saying
that
my
witness
was
Don
King,
that
Ms.
Kelly
--
Inspector Kelly knows.
She kind of knows this guy,
I don’t know well or not,
but she briefly spoke to
him.
And
that
was
my
witness.
And
he’s
--
very
ill,
so
he
couldn’t
make
it
today.
THE HEARING OFFICER:
Okay
MR.
KING:
So
my
witness
is
not
here.
THE
HEARING
OFFICER:
Okay.
Do
you
want
to
give
any
further
statement,
I
guess?
And,
if
so,
Mr.
King
is
more
than
allowed
to
cross-examine
you
if he so chooses
MR. GREER:
Like that
--
with the APC control,
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2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 51
1
with
the
pollution,
and
the environment,
I was kind
2
of
baffled,
meaning
that
I
had
got
like
3
$1,500
--
well,
$3,000
--
$3,000 worth of fines
4
from
the
Department
of Administrative Hearing.
5
THE
HEARING
OFFICER:
No.
I think that
6
was
--
correct
me
if
I’m
wrong,
it’s
the
Department
7
of the Environment,
from the City.
Correct?
8
Is that correct,
Mr. King?
I think
9
you’re
referring
to
the
administrative
citation
10
3-14?
11
MR.
GREER:
Well
--
12
MR.
KING:
If
I
can
clarify
this
a
little
--
13
THE
HEARING
OFFICER:
Thank
you.
14
MR.
KING:
--
I
will
represent
that
the
City
15
has
the
Department
of
Environment
and
the
16
Department
of Administrative Hearings, which
is a
17
separate department.
18
THE HEARING OFFICER:
Okay.
I’m confused.
19
MR.
KING:
The
Department
of
Environment
20
inspects and occasionally
issues notices
of
21
violation,
tickets,
citations.
They
all
sort
of
22
mean the same thing.
23
And
those
are
adjudicated
in
the
24
Department
of Administrative
Hearings, which
is,
you
I
Page 52
basically,
sort of a city court.
It has, you know,
court rooms and hearing officers
And they will issue orders that are,
know,
enforceable under the state
law.
And,
as
said
earlier,
I
believe
that
Mr.
Greer
had
been
issued some other violation notices under that that
were adjudicated in that forum,
and he may have,
I
think,
it looks like
-
MR.
GREER:
The Department
of the Environment.
MR.
KING:
--
an order from the Department
of
Administrative Hearings
that may have imposed the
fine
THE
HEARING
OFFICER:
Thank
you
MR.
KING:
I think that’s what he is talking
about
now.
up.
THE
HEARING
OFFICER:
Thanks
for
clearing
that
MR.
GREER:
The
Department
of
the
Environment
--
that
was
the
first
issue.
The
Department
of
the
Environment,
they
also
had
the
$3,000 worth of
fines.
So
once
I
--
once
I
looked
at
the
Department
of Environment
fines and the Department
of Administrative
Hearing,
I just gathered that
the
1
2
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18
19
20
21
22
23
24
I
Page 53
City
is
just
--
they
are
working
with
the
City
on
this thing,
on these same citations
So
I really mean the Department of
Environment with the $3,000 worth of tickets.
And
then
I
got
the
pollution
also,
with
$1,500
or
whatever
the
tickets
are
don’t
really
know
that.
I
really
didn’t
look
at
--
when
I
looked
at
it,
I
got
kind
of
upset,
you
know,
with
seeing
the
fines.
So
I
don’t
even
know
how
much.
But
I
know
it
was
two
tickets,
and
it’s
close
to
$3,000
for
the
IPC
control
and
environment
And
I
thought
it
was
double
jeopardy.
didn’t
know
because
it’s
like
environment
has
something,
pollution.
And
so
I’m
like
--
and
then
I
got
the
attorneys
for
the
City
on
the
environment
that
is wanting $3,000 also on the same case.
Yep.
I don’t know
if
you
want
to
see
a
document of it, but
I have something in here.
And
prior to this,
this case right here,
this yard that
we speak
of,
the citations that was being wrote on
the
property,
was
going
to
the
wrong
address.
And
that
was
another
issue
that
came
up
And
had
I
known
that
it
was
that
bad
--
I
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3
4
5
6
7
8
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10
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19
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21
22
23
24
Page 54
1
we
were
told
that
the
cleanup
on
State
Street
was
a
2
must,
regardless of anything, you do that first.
3
Because
the
mayor,
that’s
what
he
wanted
--
that’s
4
what he wanted first.
5
So
this
is
something
from
the
--
from
6
the
attorneys
on
--
I don’t know if you want to see
7
it.
8
THE
HEARING
OFFICER:
Well,
Mr.
King,
do
you
9
want
to
take
a
look
at
it
and
I’ll
take
a
look
at
10
it?
I
don’t
know
if
you
want
to
put
it
into
11
evidence,
but
while
we
are
on
the
topic
of
12
exhibits,
I will need the Complainant’s Exhibit
13
No.
1 back.
I think,
Mr. Greer,
that you have in
14
your possession.
15
MR.
GREER:
Oh,
No.
1?
16
MR.
KING:
This here.
17
THE
HEARING
OFFICER:
All
right.
So
I
can
18
mark that
--
19
MR.
GREER:
I’ve
got
my
photos
at
home
that
20
was
attached
to
that.
21
THE
HEARING
OFFICER:
I’m
just
looking
at
a
22
letter
dated
October
26th,
2003
to Mr.
Greer from
23
the
firm
of
Baker,
Miller,
Markoff
&
Cransy*,
24
regarding
--
it
says,
“A judgment has been
Page
55
registered
in
the
Circuit
Court
of
Cook
County
against
you
in
the
amount
of
$3,525,
on
behalf
of
the
City
of
Chicago
Okay.
What
did
you
want
me
to
do
with
this,
Mr. Greer?
MR.
GREER:
I just want you to put that in the
minutes
so
the
court reporter will have
it.
That’s
all
--
that’s all
And
the
reason
--
that’s
the
only
way
I
knew that the environment was citating me,
once
I
received that information.
Had
I not received
that,
I
still wouldn’t have known that the
environment had citated me any tickets
--
THE HEARING OFFICER:
Okay.
And
I have
a
couple of things
-
MR.
GREER:
--
that document at that time.
THE
HEARING
OFFICER:
Mr.
King?
MR.
KING:
I
looked
over
the
document
that
Mr.
Greer
has
tendered
to
you.
And,
as
I
understand
it,
that
appears
to
be
a
demand
letter
from a law firm that does collections for the City,
based on a circuit court judgment that would have
been entered on an administrative determination
in
the City’s Department of Administrative Hearings.
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2
3
4
5
6
7
8
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16
17
18
19
20
21
22
23
24
Page 56
As
I understand
it,
what Mr.
Greer is
saying that he never got the citation underlying
that judgment.
It was probably a default judgment.
However,
it’s
--
I don’t think there’s
any
question
that
you
were
served
with
the
administrative citation that’s up today.
And
that
--
whatever that’s based on,
was
a completely
separate proceeding
And
I
--
it
doesn’t
have anything to do
with
this
citation
that’s
up
today.
Or,
you
know,
separate
citations,
separate
violations,
separate
proceeding.
And,
I
suppose,
that
I
would
object
to
entering that
into evidence,
simply because it’s
irrelevant
to
this
that
it
is
going
on
here.
THE
HEARING
OFFICER:
A
couple
of
things.
I
agree with Mr.
King,
it is irrelevant
to the case
at
hand.
Secondly,
the
letter,
and
this
is
a
communication
from
a
debt
collector
--
as it states
below on the letter itself
--
doesn’t
give
any
indication of the address of the site where
the
--
MR. GREER:
It has the case number on there.
THE HEARING OFFICER:
Well,
it has a case
number,
but
I don’t know if it’s the same site.
Mr.
Greer,
what
I could do,
if you’re
1
2
3
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5
6
7
8
9
10
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12
13
14
15
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17
18
19
20
21
22
23
24
Page 57
1
still insistent on bringing this into evidence,
2
I could take it as an offer of proof, but
I would
3
sustain the City’s objection that
it is
4
irrelevant.
And that means that
I would take it
5
with
the
case,
I
will
mark
it Respondent’s Exhibit
6
No.
1,
and
when
the
Board
takes
a
look
at
it,
they
7
may overrule me.
8
Would
you
--
9
MR. GREER:
No, that’s
okay.
I just put it in
10
the
minutes.
11
It’s just that
--
the state’s attorney
12
was
saying
that
it’s
kind
of irrelevant, but known
13
to
the
fact
that
it’s
still
$3,000
that
is
cited
14
for
the
environment
on
that
location.
15
THE HEARING OFFICER:
Okay.
Do you want me to
16
take
it as your exhibit?
No?
17
MR. GREER:
No,
don’t take it as an exhibit.
18
THE
HEARING
OFFICER:
Okay.
All
right.
19
Thanks.
The
record
will reflect what we’ve been
20
talking about,
regardless.
21
Gee,
I
forgot
where
we
were.
Mr. Greer,
22
you’re still in your case in chief,
I believe.
23
MR. GREER:
My case in chief?
24
THE HEARING OFFICER:
Well,
yeah.
You’re
Page
58
pursuing your argument
MR.
GREER:
Oh,
yeah,
exactly.
That was
--
I
think that was about
it at this point
THE HEARING OFFICER:
Okay.
So do you rest?
You have nothing more to say,
other than a closing
argument?
MR.
THE
MR.
like to
THE
MR.
GREER:
No, nothing else
to say.
HEARING OFFICER:
Okay
Mr.
King,
rebuttal
KING:
Well,
I do have one question I’d
ask Mr. Greer
by
way
of
cross-examination.
HEARING OFFICER:
I’m sorry
KING:
Well,
two questions,
I suppose.
CROSS
-
EXAMINATION
BY MR.
KING:
Q.
Mr.
Greer,
you
said earlier,
I believe,
“We
stopped
the
fly
dumping
that
had
been
occurring
at
the
site
along”
--
I
think
you
said
Wallace
Street?
A.
Well,
if
you
got
the
“we
stopped,”
I
don’t
want
to
say
we
stopped,
but
we
slowed
it
down
Q.
A.
Who is
“we”?
We, meaning,
a crew that works with me
7
1
2
3
4
5
6
7
8
9
10
11
12
13
14
1S
16
17
18
19
20
21
22
23
24
Page
59
1
in
that
lot.
I
have
like little workers that
2
work
--
handles
the
stuff
on
the
ground,
moving
the
3
freight off the ground,
and getting the tires
in
4
one
place.
And
there’s
a
guy
that watches the
5
yard.
I
got
a
yard
guy.
6
Q.
Okay.
And
you
described
how
you
had
7
someone in a car keeping watch and
--
8
A.
Well,
not
all
the
time.
Most
of
the
9
time he will drive back there,
and it’s not an
10
everyday thing.
11
Because
I told him if
--
something
12
happened
with
this
guy,
he
was
approached
with
a
13
gun.
I
told
him
okay,
look,
“Come
randomly.”
You
14
know, don’t make it an everyday thing.
15
So
this
is
a
guy
that
--
that
I
--
that
16
I
know
personally,
that
works
with
me
on
the
lot.
17
He
stops
by,
and
if
he
see
a
truck
or
something,
18
he,
“Hey,”
you
know,
he
kind
of
slough
him
off.
19
Q.
Well,
my question about that
is, when
20
did he start doing that?
When did you
--
when did
21
that begin?
22
A.
Well,
on this premises we speaking of
23
now,
this inspector there,
and the head
--
is one
24
top
guy
and
zone
--
well,
this
is
environment.
And
Page 60
1
this
guy
that’s
in
the
environment
is
--
not
2
environment,
streets
and
sanitation,
I’m
sorry.
3
Streets
and
sanitation,
Cole
Steller.
4
Q.
Well,
I’m
asking
about
you
and
your
5
crew,
and
your
man,
taking
steps
to
deter
the
fly
6
dumpers?
7
A.
Right.
8
Q.
When did they start doing that?
9
A.
Right.
They started doing
it
when
the
10
time
that
--
like
I
was
saying,
I
was
getting
to
11
the part
--
Cole Steller
is
a
streets
and
12
sanitation guy.
He noticed the tires that was
13
dumped in there.
14
He came and told us
--
he said,
“Gosh,
15
you
guys
got
a
lot
of stuff.”
So I’m just using
16
that,
because
if
you
talk
to
this
guy,
he
can
give
17
you
the
date
because
he
had
wrote
it down.
He put
18
me
on
the
list
for cleanup back there,
Cole
19
Steller.
20
Now,
it
started
back
--
gosh,
when we
21
started
the
cleanup
over
there
last
year
sometime.
22
Maybe
the
--
the
middle
of
2003.
It
was
during
23
the
--
it was during
the
--
maybe
in October
--
24
October sometime.
Page 61
1
Q.
All right.
2
A.
It
was
during
the
warm
months
of
--
it
3
was
like
--
it
was
like
in
June
sometime.
June
4
July,
August,
stuff like that,
in that period of
5
time.
6
Because
I can
remember
myself
being
on
7
the
site
--
on the site
that
we
was
cleaning
8
for
--
well,
right across from the City.
And this
9
guy
Don
--
Columbus
Don
was
over there in the house
10
on
the
inside cleaning up the stuff that he had.
11
And
he
was
saying
that,
“Hey,
a
lot
of
12
guys dumped tires.”
I said,
“Okay, what we do is
13
we
get
somebody
over
here
and
watch.”
14
So
if
--
when
you
spoke
to
Don,
it
was
15
around
in
the
--
them
was
the
hot
months
that
he
16
went over there,
wasn’t
it kind of warm outside,
if
17
you can remember?
18
MS.
KELLY:
What
do
you
want
--
19
MR.
GREER:
When
you
--
20
MS. KELLY:
When
I
first met
him?
21
MR. GREER:
No, when you first talked to him
22
about moving the stuff out he had told you about.
23
He
was
going
to
--
I think
it
happened
the
same
24
time.
I
can’t
really
--
I don’t
remember
the
exact
Page 62
1
date,
but
I
know
it
was
warm
out.
2
MS.
KELLY:
Oh.
3
MR.
GREER:
You
didn’t
need
a
jacket.
4
MS.
KELLY:
Right.
5
MR. GREER:
You didn’t need a big heavy
6
coat.
7
MS.
KELLY:
You
mean
--
oh,
you
mean
the
last
8
time
when
I
saw
him
and
talked
to
him?
That
was
9
like
--
yeah.
That
was
around
June.
10
MR.
GREER:
Something like that,
yeah.
11
THE
HEARING
OFFICER:
Mr.
King?
12
MR.
KING:
Mr.
Greer
has
been
asking
Ms.
Kelly
13
these
questions.
If
his
testimony
is
that
she
14
would know when this occurred, maybe we should just
15
put
her
back
on
and
I’ll
ask
her.
16
THE
HEARING
OFFICER:
Yeah.
I mean,
that’s
17
fine.
I’m here to ensure an orderly hearing,
and
18
it’s
not
really
going
that
way
when
Mr.
King
asks
19
you
questions,
Mr.
Greer,
and
you
don’t
really
ask
20
Ms. Kelly.
21
MR. GREER:
All right.
22
THE
HEARING
OFFICER:
But
that’s
all
fine.
23
It’s
not
--
you’re not here every day.
24
So
if
you
want
to
do
that
with
--
Page 63
Ms.
Kelly,
you
can
come
back
on
the
stand,
I
guess.
This
is
kind
of
out
of
the
ordinary,
but
--
you
know,
anyway,
Mr.
Greer,
do
you
--
you can ask
Ms.
Kelly the questions
MR. GREER:
Yeah
FURTHER
RECROSS
-
EXAMINATION
BY MR.
GREER
Q.
The
time
you spoke
to Don,
do you know
the
date
when
you
spoke
to
him
about
the
cleanup
or
--
A.
The last time
I spoke
--
no,
I don’t
know
the
exact
date.
But
it’s
one
of the reports
in
the
office.
But
it
was
--
it
was
around
June
or
May.
Yeah,
the
warmer
months
MR.
GREER:
No further questions.
THE HEARING OFFICER:
Okay.
Thank you.
Just
there for a minute,
Ms. Kelly.
MS. KELLY:
Okay
THE HEARING OFFICER:
Mr. King?
FURTHER CROSS-EXAMINATION
stay
BY MR. KING:
Q.
And tell me
if
I understand your
testimony
correctly
then.
You’re
saying
that
that
was
when
you
put
into
place
this
program
of
having
1
2
3
4
5
6
7
8
9
10
H~)
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 64
someone
out
there
to watch for fly dumpers?
A.
Once
the
continuous
--
well, not
continuous
--
but once the dumping tires
started,
that’s when
I assisted.
Back in June,
yeah,
someone to come back there and watch
momentarily
Q.
going on?
A.
Q.
A.
Q.
A.
permanent,
goes back
Q.
A.
there.
How long did that go on?
Or is it still
It’s
going
on
now
You
have
--
It never
--
--
someone watching?
I don’t have somebody back there
every day,
but there’s somebody that
there randomly
Okay.
And
I’m
one
of
the
guys,
myself,
go
back
MR.
KING:
All right.
No further cross of
Mr. Greer
THE HEARING OFFICER:
Okay,
thanks.
All
right
Mr.
Greer,
have
you
rested,
now,
your
case in chief?
I guess
we
jumped
the
gun
last
time
1
2
3
4
5
6
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8
9
10
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12
13
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22
23
24
Page
65
1
we tried
--
2
MR.
GREER:
Yes,
I rested.
I rested.
3
THE HEARING OFFICER:
Okay.
4
So now it’s Mr.
King,
do you have any
S
rebuttal
you
want
to
present?
6
MR. KING:
No.
7
THE HEARING OFFICER:
All right.
8
Ms.
Kelly,
you
may
step
down.
Thank
you
9
very much.
10
MS. KELLY:
Okay.
11
THE
HEARING
OFFICER:
We’re
going
to
go
off
12
the
record
in
a
moment.
We’re
going
to
discuss
a
13
post-hearing briefing schedule.
14
But,
I
guess,
from
my
knowledge,
15
Mr.
King,
Mr.
Greer,
are
you
going
to
opt
for
a
16
closing
argument
--
statement,
argument,
or
are
you
17
just
going
to
submit
your post-hearing briefs and
18
leave it at that?
Mr. King?
19
MR.
KING:
I prefer just to submit a
20
post-hearing brief.
21
MR.
GREER:
Exactly.
22
THE HEARING OFFICER:
Let’s go off the record
23
for
a
second.
Thanks.
24
(WHEREUPON,
discussion
was
had
Page 66
off
the
record.)
THE HEARING OFFICER:
Back on the record.
We’ve been talking about post-hearing brief
scheduling.
The parties have indicated that they
wish to waive their closing arguments
We have decided that the transcript
will be available April
15th.
And with that
said,
Complainant’s
brief
is due on or before
May
14th
Mr. Greer’s brief is due on or before
June
18th.
Mr. King’s reply,
if
any,
is
due
on
or
before
July
9.
And
I’m
setting
public
comment
due
date
is April
30th,
2004.
And,
again,
this is all
in the year 2004
There has been no members of the public
here;
but,
in
any
event,
we
said
it.
And,
before
I
forget,
I am supposed to make
a credibility
determination.
And
based
on
my
judgment,
legal
knowledge,
and
observations,
I
find
that
there
is
no issue of credibility with the witnesses that
testified here today
want
to
thank
everybody
for
their
And if that’s all, have
a safe trip
safe
walk
across
the
street,
whatever
civility.
home,
or
a
I
1
2
3
4
S
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 67
1
the
case.
Thank you very much.
2
MR.
KING:
Thank you.
3
MR.
GREER:
Thank you.
4
(WHICH WERE all the matters heard
in
S
the above-entitled cause on this date.)
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page
68
1
STATE
OF
ILLINOIS)
2
)
SS:
3
COUNTY
OF
COOK
4
I,
SHARON
BERKERY,
a
Certified
Shorthand
S
Reporter of the State of Illinois,
do hereby
6
certify
that
I
reported
in
shorthand
the
7
proceedings had at the hearing aforesaid,
and that
8
the
foregoing
is
a true,
complete,
and correct
9
transcript
of
the
proceedings
of
said
hearing
as
10
appears from my stenographic notes so taken
and
11
transcribed under my personal direction.
12
IN WITNESS WHEREOF,
I
do
hereunto
set
my
13
hand
at
Chicago,
Illinois,
this
8th
day
of
14
April,
2004.
17
Certified Shorthand Reporter
18
19
C.S.R.
Certificate
No.
84-4327.
2 0
~
;~,
~F~C~AL
SEAL.
~
21
~
~ARON
GERKERY
~
~U8LIC, STATE
r.
~ ~
tLLgg~o~g
22
~
.
N
E*~RES:O?,22j05
23
24
