1. NOTICE OF FILING
      2. PROOF OF SERVICE
BEFORE
THE ILLINOIS POLLUTION CONTROL BOARD
R E
C
E
IV ED
CLERK’S OFFICE
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
V.
KEN EDWARDS,
Respondent.
)
APRil2005
)
STATE OF ILLINOIS
)
Pollution
Control Board
ACp~(~
)
)
(IEPA No
52-05-AC)
)
)
)
)
)
)
)
To:
Ken Edwards
3655 Edwardsville Road
Edwardsville,
IL
62025
NOTICE OF FILING
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk ofthe Pollution
Control Board ofthe State ofIllinois the following instrument(s) entitled MOTION TO DISMISS.
Respectfully, submitted,
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box
19276
Springfield, Illinois 62794-9276
(217) 782-5544
Dated:
April 7, 2005
Assistant Attorney General
THIS
FILING
SUBMITI’ED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL
ADMINISTRATIVE CITATION
APR
112005
STATE OF ILLINOIS
Pollution Control Board
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Complainant,
)
AC
1) ~
)
v.
)
(IEPA No. 52-05-AC)
)
KEN EDWARDS,
)
)
Respondent.
)
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 James M. Kropid, pursuant to 35 Iii.
Adm.
Code
108.402, and respectfully states as follows:
(1)
On March 14, 2005, the Illinois
EPA issued an Administrative Citation to Respondent
Ken Edwards, based on
au
inspection conducted on January 24, 2005.
(2)
OnApril 7, 2005, the Administrative Citation was sent back to the Illinois EPA from the
United States Postal Service, as unclaimed.
(3)
Because Ken Edwards was not timely served within 60 days as required by 415 ILCS
5/31.1(b), this Administrative Citation should be dismissed.
ThIS
FILING SUBM1Y~ED
ONRECYCLED PAPER
WHEREFORE, the Illinois Environmental Protection Agency requests that theBoard dismiss the
pending action against Ken Edwards.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
DATED:
April 7, 2005
/
~
Jame~”1vrKropid
Spe~al
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
SUBMITFED ON RECYCLED PAPER
PROOF OF SERVICE
Ihereby certif~’
that I did on the 7th dayofApril, 2005, sendby U.S. Mail, with postagethereon
fullyprepaid, by depositing in, a United States Post Office Box the following instrument(s) entitled
MOTION TO DISMISS
To:
Ken Edwards
3655 Edwardsville Road
Edwardsville, IL 62025
and the original and nine (9) true and correct copies ofthe same foregoinginstruments 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
J~mesM. Kropid
~pecial Assistant AttorneyGeneral
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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