BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,)
Complainant,)
V.
)
PCB 04-226
)
(Enforcement-Land)
P & J SUPER AUTO BODY SHOP, INC.)
an Illinois corporation, and JULIO)
GALLEGOS, an Illinois resident,)
Respondents.)
NOTICE OF FILING
TO:
See Attached Service List.
PLEASE TAKE NOTICE that today, on October 11, 2005, the People of the State of
Illinois filed with the Illinois Pollution Control Board by electronic filing a Stipulation and
Proposal for Settlement and Motion for Relief from Hearing Requirement, true and correct
copies of which are attached and hereby served upon you.
Respectfully submitted,
LISA MADIGAN
Attorney General
State of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/
Asbestos Litigation Division
BY:
SZ tI
at
-M4
BRIDG0-T M. CA
L
N~
Assistant Attorney General
Environmental Bureau
188 W. Randolph Street, Suite 2001
Chicago, Illinois
60601
(312) 814-0608
THIS FILING IS SUBMITrED ON RECYCLED PAPER
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
SERVICE LIST
Mr. Ross J. Helfand
555 Skokie Boulevard, Suite 595
Northbrook, Illinois 60062
Ms. Melanie Jarvis
Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
Mr. Bradley Halloran
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
1 00 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE
STATE OF ILLINOIS,)
Complainant,)
V.
)
PCB 04-226
)
(Enforcement-Land)
P & J SUPER AUTO BODY SHOP, INC.)
an Illinois corporation, and JULIO)
GALLEGOS, an Illinois resident,)
Respondents.)
MOTION FOR RELIEF FROM HEARING REOUIREMENT
NOW COMES Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General of the State of Illinois, and pursuant to Section 3 1
(c)(2) of the
Illinois Environmental Protection Act ("Act"), 415 ILCS 5/3 1(c)(2)(2004), moves that the
Illinois Pollution Control Board ("Board") grant the parties in the above-captioned matter relief
from the hearing requirement imposed by Section 31(c)(1) of the Act, 415 ILCS
5/31(c)(1)(2004).
In support of this motion, Complainant states as follows:
1.
The Complaint in this matter alleges: Used Tire Violations, in violation of Section
55(c) of the Act, 415 ILCS 5/55(c)(2004); Failure to Post Written Notice for Used Tire
Recycling, in violation of Section
55.8(a)(3)
of the Act, 415 ILCS 5/55.8(a)(3)(2004); Allowing
Used Tires to Accumulate for More than 90 Days, in violation of Section 55.8(b) of the Act, 415
ILCS
5155.8(b)(2004).
2.
Complainant is filing this Motion and a Stipulation and Proposal for Settlement
with the Board.
3.
The parties have reached agreement on all outstanding issues in this matter.
4.
This agreement is presented to the Board in a Stipulation and Proposal for
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
Settlement filed this same date.
5.
All parties agree that a hearing on the Stipulation and Proposal for Settlement is
not necessary, and respectfully request relief from such a hearing as allowed by Section 3 1
(c)(2)
of the Act, 415 ILCS 5/3 1(c)(2)(2004).
WHEREFORE, Complainant, PEOPLE OF THE STATE OF ILLINOIS, hereby requests
that the Board grant this motion for relief from the hearing requirement set forth in Section
3 1(c)(1) of the Act, 415 ILCS
513 1(c)(1)(2004).
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN
Attorney General
State of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/
Asbestos Litigation
Divi'
BY:
&t
/W
w
m
BRI~E)
M. CARLSON
Assistant Attorney General
Environmental Bureau
188 W. Randolph St., 20th Floor
Chicago, Illinois
60601
(312) 814-0608
DATE: October 11, 2005
THIS FILING IS SUBMITT'ED ON RECYCLED PAPER
2
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,)
Complainant,)
)
PCB
04-226
V.
)
(Enforcement
-
Land)
P&J SUPER AUTO BODY SHOP, INC., an
)
Illinois corporation, and JULIO GALLEGOS, an
)
Illinois resident,)
Respondents.
STIPULATION AND PROPOSAL FOR SETTLEMENT
Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA MADIGAN, Attorney
General of the State of Illinois, the Illinois Environmental Protection Agency ("Illinois EPA"),
and P&J SUPER AUTO BODY SHOP, INC. and JULIO GALLEGOS ("Respondents"), have
agreed to the making of this Stipulation and Proposal for Settlement ("Stipulation") and submit it
to the Illinois Pollution Control Board ("Board") for approval.
The parties agree that the
statement of facts contained herein represents a fair summary of the evidence and testimony
which would be introduced by the parties if a hearing were held.
The parties further stipulate that
this statement of facts is made and agreed upon for purposes of settlement only and that neither
the fact that a party has entered into this Stipulation, nor any of the facts stipulated herein, shall
be introduced into evidence in any other proceeding regarding the claims asserted in the
Complaint except'as otherwise provided herein.
If the Board approves and enters this
Stipulation, Respondents agree to be bound by the Stipulation and Board Order and not to contest
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
their validity in any subsequent proceeding to implement or enforce their terms.
I.
JURISDICTION
The Board has jurisdiction of the subject matter herein and of the parties consenting
hereto pursuant to the Illinois Environmental Protection Act ("Act"),
415
ILCS
5/I et seq.
(2002).
HI.
AUTHORIZATION
The undersigned representatives for each party certify that they are fully authorized by the
party whom they represent to enter into the terms and conditions of this Stipulation and to legally
bind them to it.
III.
STATEMENT
OF
FACTS
A.
Parties
1
.
On June 29, 2004, a Complaint was filed on behalf of the People of the State of
Illinois by Lisa Madigan, Attorney General of the State of Illinois, on her own motion and upon
the request of the Illinois EPA, pursuant to Section 31 of the Act, 415 ILCS 5/31(2002); against
the Respondents.
2.
The Illinois EPA is an administrative agency of the State of Illinois, created
pursuant to Section 4 of the Act, 415 TLCS 5/4 (2002).
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
3.
Respondent P & J SUPER AUTO BODY SHOP, INC. ("P & J") was an Illinois
corporation that was authorized to do business in the State of Illinois until January 2, 2004, when
the corporation was involuntarily dissolved by the Illinois Secretary of State.
4.
Respondent JULIO GALLEGOS was and is an Illinois resident and is the
President of P & J.
B.
Site Description
1
.
At all times relevant to the Complaint, Respondent P & J owned and operated a
tire retail business located at 6809 North Clark Street, Chicago, Cook County, Illinois ("Site").
2.
At all times relevant to the Complaint, Respondent Julio Gallegos was the owner
and operator of P & J. Gallegos is the president and registered agent of P & J, and directs the
day-to-day operations of the Site, including the direction and placement of used tires at the Site.
3.
The Site is an automotive repair services facility and a new and used tire retailer
that stores and sells new and used tires.
The Respondents also accept tires for recycling.
4.
On or before April 24, 2003, or at a time better known to Respondents, the
Respondents commenced a retail tire business which stored more than fifty (50) used tires on-
Site.
The Respondents had not notified the Illinois EPA of the tire storage activity as of the date
of an April 2003, Illinois EPA inspection.
Respondents had failed to post a written notice
identifying that they received used tires for recycling.
Respondents had not kept tire
accumulation documentation to ensure that the used tires were not accumulating on-Site for more
than 90 days.
As of the most recent Illinois EPA inspection on June 4, 2004, Respondents stored
approximately
250
used tires on-Site.
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
C.
Allegations of Non-Compliance
Complainant contends that the Respondent has violated the following provisions of the
Act and Board regulations:
Count I:
Failure to notify Illinois EPA of operation of tire storage site within 30
days of commencing business, in violation of Section 55(c) of the Act,
415 ILCS 5/55(c)(2002).
Count 11:
Failure to post written notice for used tire recycling, in violation of
Section 55.8(a)(3) of the Act, 415 ILCS 5/55.8(a)(3)(2002).
Count HII:
Allowing used tires to accumulate for more than 90 days, in violation of
Section 55.8(b) of the Act, 415 ILCS 5/55.8(b)(2002).
D.
Admission of Violations
The Respondent admits to the violation(s) alleged in the Complaint filed in this matter
and referenced within Section llI.C herein.
IV.
APPLICABILITY
This Stipulation shall apply to and be binding upon the Complainant and the Respondent,
and any officer, director, agent, or employee of the Respondent, as well as any successors or
assigns of the Respondent.
The Respondents shall not raise as a defense to any enforcement
action taken pursuant to this Stipulation the failure of any of its officers, directors, agents,
employees or successors or assigns to take such action as shall be required to comply with the
provisions of this Stipulation.
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
1.
No change in ownership, corporate status or operator of the facility shall in any way alter
the responsibilities of the Respondents under this Stipulation and Proposal for Settlement.
In the
event of any conveyance of title, easement or other interest in the facility, the Respondents shall
continue to be bound by and remain liable for performnance of all obligations under this
Stipulation.
2.
In the event that the Respondents propose to sell or transfer any real property or
operations subject to any Order accepting and adopting the terms of this Stipulation and Proposal
for Settlement, the Respondents shall notify the Complainant 30 days prior to the conveyance of
title, ownership or other interest, including a leasehold interest in the facility or a portion thereof
The Respondents shall make the prospective purchaser or successor's compliance with any Order
accepting
and
adopting the termns of this Stipulation a condition of
any
such sale or transfer and
shall provide a copy of this Stipulation and any Order accepting and adopting the terms of this
Stipulation to any such successor in interest.
This provision does not relieve the Respondent
from compliance with any regulatory requirement regarding notice and transfer of applicable
facility permits.
3.
The Respondents shall notify each contractor to be retained to perform work required by
any Order accepting and adopting the terms of this Stipulation of each of the requirements of said
Order relevant to the activities to be performed by that contractor, including all relevant work
schedules and reporting deadlines, and shall provide a copy of this Stipulation and any Order
accepting and adopting the terms of this Stipulation to each contractor already retained no later
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
than 30 days after the date of adoption of this Stipulation.
In addition, the Respondents shall
provide copies of all schedules for implementation of the provisions of this Stipulation to the
prime vendor(s) supplying the control technology systems and other equipment required by any
Order accepting and adopting the terms of this Stipulation.
V.
COMPLIANCE WITH OTHER LAWS AND REGULATIONS
This Stipulation in no way affects the responsibilities of the Respondents to comply with
any other federal, state or local laws or regulations including-, but not limited to, the Act and the
Board regulations, 35 III. Adm. Code, Subtitles A through H.
VI.
IMPACT ON THE PUBLIC RESULTING
FROM
ALLEGED
NON-
COMPLIANCE
Section 33(c) of the Act, 415 TLCS 5/33(c)(2002), provides as follows:
In making its orders and determinations, the Board shall take into consideration
all the facts and circumstances bearing upon the reasonableness of the emissions,
discharges, or deposits involved including, but not limited to:
I.
the character and degree of injury to, or interference with the protection of
the health, general welfare and physical property of the people;
2.
the social and economic value of the pollution source;
3.
the suitability or unsuitability of the pollution source to the area in which it
is located, including the question of priority of location in the area
involved;
4.
the technical practicability and economic reasonableness of reducing
or
eliminating the emissions, discharges or deposits resulting from such
pollution source; and
5.
any subsequent compliance.,
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
In response to these factors, the parties state the following:
1
.
Human health and the environment were minimally threatened by the
Respondents' violations.
The used tires were indoor and protected from rodents and rain.
2.
There is a social and economic benefit to the auto body shop operated y
Respondents.
3.
Operation of the facility was suitable for the area in which it occurred.
4.
Notifying the Illinois EPA of the tire storage site and documenting the
accumulation of used and waste tires is both technically practicable and economically reasonable.
Posting written notification informning customers of the proper method of the disposal of used
tires is also technically practical and economically reasonable.
5.
P & J has notified the Illinois EPA of its ongoing tire storage activities, posted
written notice that P & J will accept used tires for recycling in accordance with Section
55.8(a)(3) of the Act, 415 TICS 5/55.8(a)(3)(2002), are removing stored used tires from the site
within 90 days through use of a registered tire transporter and documenting their accumulation in
accordance with Section
55.8
(b) of the Act, 415 TICS 5/55.8(b)(2002).
VII.
CONSIDERATION OF SECTION 42(h) FACTORS
Section 42(h) of the Act, 415 TICS 5/42(h) (2002), provides as follows:
In determining the appropriate civil penalty to be imposed under ...
this Section,
the Board is authorized to consider any matters of record in mitigation or
aggravation of penalty, including but not limited to the following factors:
1.
the duration and gravity of the violation;
7
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
2.
the presence or absence of due diligence on the part of the respondent in
attempting to comply with requirements of this Act and regulations
thereunder or to secure relief therefrom as provided by this Act;
3.
any economic benefits accrued by the respondent because of delay in
compliance with requirements, in which case the economic benefits shall
be determined by the lowest cost alternative for achieving compliance;
4.
the amount of monetary penalty which will serve to deter further violations
by the respondent and to otherwise aid in enhancing voluntary compliance
with this Act by the respondent and other persons similarly subject to the
Act;
5.
the number, proximity in time, and gravity of previously adjudicated
violations of this Act by the respondent;
6.
whether the respondent voluntarily self-disclosed, in accordance with
subsection i of this Section, the non-compliance to the Agency; and
7.
whether the respondent has agreed to undertake a "supplemental
environmental project," which means anl environmentally beneficial
project that a respondent agrees to undertake in settlement of an
enforcement action brought under this Act, but which the respondcnt is not
otherwise legally required to perform.
In response to these factors, the parties state as follows:
I1.
The Respondents failed to notify the Illinois EPA of their operation of a tire
storage/disposal site. The Respondents failed to post written notification to customers that P & J
accepted used tries for recycling.
The Respondents allowed waste tires to accumulate for more
than 90 days.
Upon the Illinois EPA's request, Respondents failed to provide tire accumulation
documentation.
The violations began on or about April 24, 2003, and continued for a time better
known to Respondents.
Respondents' actions were a substantial deviation from the requirements
imposed by the Act, but represented minor potential harm to the environment.
8
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
prescribed below.
The penalty described in this Stipulation shall be paid by certified check,
money order or electronic funds transfer payable to the Illinois EPA, designated to the Illinois
Environmental Protection Trust Fund and be submitted to:
Illinois Environmental Protection Agency
Fiscal Services Section
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
The name and number of the case and Respondents' Federal Employer Identification
Number (FEIN4),
shall appear on the check.
A copy of the certified check, money order or record
of electronic funds transfer and any transmittal letter shall be sent to:
Ms. Bridget M. Carlson
Assistant Attorney General
Environmental Bureau
188 W. Randolph St.,
201h
Floor
Chicago, Illinois 60601
Ms. Melanie Jarvis
Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
2.
Pursuant to Section 42(g) of the Act, 415 ILCS 5/42(g) (2002), interest shall
accrue on any payment not paid within the time period prescribed above at the maximum rate
allowable under Section 1003(a) of the Illinois Income Tax Act,
35
TLCS 5/1003 (2002).
Interest
on any unpaid payment shall begin to accrue from the date the payment is due and continue to
accrue
until the date payment is received.
When partial payment(s) are made, such partial
payment shall be first applied to any interest on unpaid payment then due and owing.
All interest
10
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
on payment owed shall be paid by certified check, money order or electronic
finds
transfer,
payable to the Illinois EPA, designated to the Illinois Environmental Protection Trust Fund and
delivered to the address and in the manner described above.
3.
For purposes of payment and collection, Respondents may be reached at the
following address:
Ross J. Helfand
Attorney
555 Skokie Boulevard, Suite 595
Northbrook, Illinois
60062
P & J Super Auto Body Shop, Inc.
Registered Agent: Julio Gallegos
4200 West Palmer
Chicago, Illinois
60639
Julio Gallegos
2900 West Cermnak Road
Chicago, Illinois 60623
4.
In the event of default of this Section VMI.A, the Complainant shall be entitled to
all available relief including, but not limited to, reasonable costs of collection and reasonable
attorney's fees.
B.
Future Use
Notwithstanding any other language in this Stipulation to the contrary, and
in
consideration of the mutual promises and conditions contained in this Stipulation, including the
Release from Liability contained in Section VJII.D,'below, the Respondents hereby agree that
this Stipulation may be used against the Respondents in any subsequent enforcement action or
permit proceeding as proof of a past adjudication of violation of the Act and the Board
I1I
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
2.
The Respondents were diligent in attempting to come back into compliance with
the Act and Board regulations, once the Illinois EPA notified it of its noncompliance.
The
Respondents will continue to document used tire accumulation and used tire removal from the
Site.
3.
Respondent's economic benefit from alleged non-compliance was nominal and
the penalty obtained in this matter includes any economic benefit received.
4.
Complainant has determined, based upon the specific facts of this matter that a
penalty of Ten Thousand Dollars ($10,000.00) will serve to deter further violations and will aid
in future voluntary compliance with the Act and Board regulations.
5.
To Complainant's knowledge, Respondents have no previously adjudicated
violations of the Act.
6.
The Respondents failed to self-disclose the violations at issue in this matter.
7.
The settlement of this matter does not include a supplemental environmental
project.
ViII.
TERMS OF SETTLEMENT
A.
Penalty Payment
1.
The Respondents shall pay a civil penalty in the sum of Ten Thousand Dollars
($10,000.00) within thirty (30) days from the date the Board adopts and accepts this Stipulation.
The Respondents stipulate that payment has been tendered to Respondents' attorney of record in
this matter in a form acceptable to that attorney.
Further, the Respondents stipulate that said
attorney has been directed to make the penalty payment on behalf of the Respondents, within
thirty (30) days from the date the Board adopts and accepts this Stipulation, in a manner
9
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
Regulations promulgated thereunder for all violations alleged in the Complaint in this matter, for
purposes of Section 39(a) and (i) and/or 42(h) of the Act, 415 ILCS 5/39(a) and(i) and/or
5/42(h)(2002).
Further, Respondents agree to waive any rights to contest, in any subsequent
enforcement action or permnit proceeding, any allegations that these alleged violations were
adjudicated.
C.
Cease
and
Desist
The Respondents shall cease and desist from future violations of the Act and Board
Regulations that were the subject matter of the Complaint as outlined in Section 1I1.C
("Allegations of Non-Compliance") of this Stipulation.
D.
Release
from
Liability
in consideration of the Respondents' payment of the $10,000.00 penalty and any specified
costs and accrued interest, completion of all activities required hereunder, to Cease and Desist as
contained in Section VII.C and upon the Pollution Control Board's acceptance and approval of
the terms of this Stipulation and Proposal for Settlement, the Complainant releases, waives and
discharges the Respondents from any further liability or penalties for violations of the Act and
Board Regulations that were the subject matter of the Complaint herein.
The release set forth
above does not extend to any matters other than those expressly specified in Complainant's
Complaint filed on June 29, 2004. The Complainant reserves, and this Stipulation is without
prejudice to, all rights of the State of Illinois against the Respondents with respect to all other
matters, including but not limited to, the following:
12
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
a.
criminal liability;
b.
liability for future violation of state, federal, local, and common laws and/or
regulations;
C.
liability for natural resources damage arising out of the alleged violations; and
d.
liability or claims based on the Respondents' failure to satisfy the requirements of
this Stipulation.
Nothing in this Stipulation is intended as a waiver, discharge, release, or covenant not to
sue for any claim or cause of action, administrative or judicial, civil or criminal, past or future, in
law or in equity, which the State of Illinois or the Illinois EPA may have against any person, as
defined by Section 3.315 of the Act, 415 ILCS 5/3.315, or entity other than the Respondents.
E.
Right of Entry
In addition to any other authority, the Illinois EPA, its employees and representatives,
and
the Attorney General, her agents and representatives, shall have the right of entry into and upon
the Respondent's facility which is the subject of this Stipulation, at all reasonable times for the
purposes of carrying out inspections.
In conducting such inspections, the Illinois EPA, its
employees and representatives, and the Attorney General, her employees and representatives may
take photographs, samples, and collect information, as they deem necessary.
F.
Correspondence, Reports and Other Documents
Any and all correspondence, reports and any other documents required under this
Stipulation, except for payments pursuant to Sections VIILA ("Penalty Payment") of this
1
3
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
Stipulation shall be submitted as follows:
As to the Complainant
Ms. Bridget Carlson
Assistant Attorney General
Environmental Bureau
188 W. Randolph St., 20h Floor
Chicago, Illinois 60601
Ms. Melanie Jarvis
Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
As to the Respondents
Ross J. H-elfand
555 Skokie Boulevard, Suite
595
Northbrook, Illinois
60062
P & J Super Auto Body Shop, Inc.
Registered Agent: Julio Gallegos
4200 West Palmer
Chicago, Illinois
60639
Julio Gallegos
2900 West Cermak Road
Chicago, Illinois
60623
G.
Enforcement of Board Order
1.
Upon the entry of the Board's Order approving and accepting this Stipulation and
Proposal for Settlement, that Qrder is a binding and enforceable order of the Illinois Pollution
Control Board and may be enforced as such through any and all available means.
1
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
2.
Respondent agrees that notice of any subsequent Proceeding to enforce the Board
Order approving and accepting this Stipulation and Proposal for Settlement may be made by mail
and waives any requirement of service of process.
3.
The parties agree that, if the Board does not approve and accept this Stipulation
and Proposal for Settlement, then neither party is bound by the terms herein.
4.
It is the intent of the Complainant and Respondent that the provisions of this
Stipulation and Proposal for Settlement and any Board Order accepting and approving such shall
be severable, and should any provision be declared by a court of com-petent jurisdiction to be
inconsistent with state or federal law, and therefore unenforceable, the remaining clauses shall
remain in full force and effect.
THE REMAINDER OF THIS PACE INTENTIONALLY LEFT BLANK
15
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
WHEREFORE, Complainant and Respondents request that the Board adopt and accept
the foregoing Stipulation and Proposal for Settlement as written.
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN
Attorney General
State of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/
Asbestos Litigation Division
BY:
Assistant Attorney General
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY
BY:
DATE:
Y
•3
& e
S
Acting Legal Counsel
P & J SUPER AUTO BODY, INC. AND
J-ULIO GALLEGOS
DATE:
BY:
-
jL--,-1"
LOGLEGOS
4
President and Individually
1
6
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
CERTIFICATE OF SERVICE
I, BRIDGET M. CARLSON, an Assistant Attorney General, certify that on the 11Ith day
of October 2005, I caused to be served by First Class Mail the foregoing Stipulation and
Proposal for Settlement and Motion for Relief from Hearing Requirement to the parties named
on the attached Service List, by depositing same in postage prepaid envelopes with the United
States Postal Service located at 100 West Randolph Street, Chicago, Illinois 60601.
BRID(y
M. CARLSON
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, OCTOBER 11, 2005
