1. NOTICE OF FILING
      2. AFFIDAVIT
      3. PROOF OF SERVICE
RECE
WED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
JUN
1
0
2004
STATE OF ILLINOIS
Pollution Control
Board
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
)
Complainant,
)
AC 03-13
)
V.
)
(IEPA No.
565-02-AC)
)
DAN CADWALLADER,
)
)
Respondent.
)
NOTICE OF FILING
To:
John Grivetti, Esq.
Box
251
Wenona, Illinois 61377
-
PLEASE TAKE NOTICE that on this date Imailed for filingwith the Clerk ofthe Pollution Control Board ofthe
State ofIllinois the followinginstrument(s) entitled COMPLAINANT’SSTATEMENT OF HEARING COSTS.
Respectfully submitted,
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:
June
7, 2004
THIS
FILING SUBMITfED ON RECYCLED PAPER
RECE~VED
CLERK’S OFFICE
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
JUN
10200k
STATE OF ILLINOIS
ILLINOIS ENVIRONMENTAL
)
Pollution Control Board
PROTECTION AGENCY,
)
)
Complainant,
)
AC
03-13
)
V.
)
(JEPA No. 565-02-AC)
)
DAN CADWALLADER,
)
)
Respondent.
)
COMPLAINANT’S STATEMENT
OF HEARING COSTS
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 108.502
and the Order ofthe Pollution Control Board (“Board”) in this case dated May 20, 2004, and presents its
Statement ofCosts forthis case as follows:
Mileage (Springfield-Hennepin and return) 264 miles ~
$.36/mile
$95.04
Copying/clerical/mailing
fees (estimated)
$30.00
TOTAL CLAIMED:
$125.04
WHEREFORE,
the
Complainant requests that the Board
order the
defendant to pay
$125.04 to
Illinois EPA forits hearing costs in this case.
ILLINOIS EPA, Complainant,
DATED:
June
7, 2004
________________________
Special Assistant Attorney General
1021 North Grand Avenue East
Springfield, IL 62702-4059
(217) 782-5544
STATE OF ILLINOIS
)
)
SS
COUNTY OF SANGAMON
)
AFFIDAVIT
I, Michelle M.
Ryan, being first duly sworn upon oath, depose and state as follows:
1.
I am employed by the Illinois Environmental ProtectianAgency (“Illinois EPA”), as
Assistant Counsel for the Bureau ofLand.
2.
As part ofmy duties, Iam responsible forthe preparation ofAdministrative Citations
issued
by the Illinois
EPA
and
the negotiation
and
litigation of appeals
filed pursuant
to
such
Administrative Citations.
As part ofmy job experience, I have also submitted travel vouchers for
reimbursement.
3.
Ihavereviewed the Illinois EPA DivisionofLegal Counsel File 565-02-AC,
which
relates
to AC 03-13,
Illinois EPA
v.
Dan Cadwallader,
for the purpose of determining the costs
expended by Illinois EPA.
4.
I was the Illinois EPA attorney assigned to handle the hearing for AC 03-13, which
was held in Hennepin.
I was required
to
travel
from
Springfield to Hennepin and back for the
hearing.
The Illinois
Department ofTransportation map of the State ofIllinois
indicates that ;he
distance between Springfield and Hennepin is
132 miles.
Based on my
own
job experience, I am
aware that the approved mileage reimbursement rate in December 2003 was
$.36 per mile.
5.
As the attorney currently assigned to handle Administrative Citations,
Jam
aware that
Illinois EPA incurs costs for copyingdocuments, preparation ofdocuments formailing
and
service,
and certified and first class mailings.
Based upon my review ofFile 565-02-AC, I estimatethat these
costs expended by Illinois EPA on this Administrative Citation through the hearing-dateapproximate
$30.00.
FURTHER AFFIANT SAYETH NOT.
~efleM.RyanJ~~
Subscribed and Sworn to before
me this
7th
day of
June,
2004.
OFFICIAL
SEAL~
*
CYNTHIA L. WOLFE
~
X
NOTARY
PUBLIC, STATE OF IWNOIS
Notary Public
2
PROOF OF SERVICE
I hereby certifythat I did on the
7th
dayofJune
,
2004, send by U.S. Mail, with postage thereon
fully prepaid,
by depositing
in
a
United States
Post Office Box
a
true and
correct
copy
of the
following instrument(s) entitled COMPLAINANT’S STATEMENT OF
HEARING COSTS
To:
John Grivetti, Esq.
Box 251
Wenona, Illinois 61377
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
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
THIS FILING SUBMITTED ON RECYCLED PAPER

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