1. NOTICE OF FILING
      2. RECE~VE.
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
R E C E ~V E D
CLERK’S OFFICE
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
OCT
-
8
2004
)
~-O
STATEOFILLINOIS
Complainant,
)
AC
(J5~
Pollution Control
Board
)
v.
)
(JEPA No. 412-04-AC)
)
JOHN GROFF and ROBERT GROFF,
)
)
Respondents.
)
NOTICE
OF FILING
To:
Robert Groff
2503
Barton Road
Sandoval,IL 62882
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
Control Board ofthe State ofIllinois the following instrument(s) entitled MOTION TO DISMISS.
Respectfully submitted,
\JJJhJj~tJ1t~
Miche e 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: October
5,
2004
THIS
FILING
SUBMIYFED
ON RECYCLED
PAPER
RECE~VE.
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD CLERK’S OFFICED
ADM1NESTRATIVE CITATION
OCT
82004
STATE OF
ILUNOIS
Pollution Control
Board
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
AC
&‘
)
v.
)
(IEPA No. 412-04-AC)
)
JOHN GROFF and ROBERT GROFF,
)
)
Respondents.
)
MOTION TO DISMISS
ADMINISTRATIVE CITATION
NOW COMES the Complainant, the Illinois Environmental Protection Agency (“illinois EPA”),
by and through its
attorney, Special Assistant Attorney General Michelle M. Ryan, pursuant to 35
1l1
Adm. Code
108.402, and respectfully states as follows:
(1)
OnAugust
25,
2004, the Illinois EPA issued an Administrative Citation to Respondent
Robert Groff, based on an inspection
conducted on July 29, 2004.
(2)
On September 10, 2004, the Administrative
Citation was sent back to the Illinois EPA
from the United States Postal Service, as unclaimed.
(3)
Because Robert Groff was not timely served within 60 days as required by 415
IILCS
5/31.1(b),
this Administrative Citation should be dismissed.
THIS FILING SUBMITI’ED ON RECYCLED
PAPER
WHEREFORE, theIllinois Environmental Protection Agencyrequests thatthe Board dismiss the
pending action against Robert Groff.
ILLINOIS ENVIRONMENTAL
H
PROTECTION AGENCY,
-
Complainant,
DATED:
October
5,
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
L
THIS FILING SUBMI1TED ON
RECYCLED PAPER
PROOF OF SERVICE
I hereby certify that I did
on the 5th
day of October, 2004,
send by U.S. Mail with postage
thereon fully prepaid, by depositing in a United States Post Office Box a true and correcteopy ofthe
following instrument(s) entitled MOTION TO DISMISS
To:
Robert-Groff
2503 BartonRoad
Sandoval,IL 62882
and
the original and nine (9) true
and
correct copies ofthe sameforegoing instrumentson thesame
date byU.S.
Mail with postage thereon fully prepaid
To:
DorothyGunn, 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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