REC~Iveo
CLERKS OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARI4OV
Ii
8
21105
STATE OF ILLINOIS
PAUL
FREEMAN and FREEMAN
)
Pollution Control Board
ENVIRONMENTAL SERVICES, INC.
)
k
Illinois Corporation,
)
Petitioner,
)
Petition for Review of
I
Notice ofAdministrative Citation
v.
)
)
ILLINOIS POLLUTION CONTROL BOARD
and PEOPLE OF THE
STATE OF ILLINOIS,
)
IEPA No. 350-05-AC
)
Respondents.
PETITION
FOR REVIEW
Petitioner,
PAUL FREEMAN
and
FREEMAN
ENVIRONMENTAL SERVICES,
INC.
through
their undersigned attorney
files this
Petition for Review of Administrative
Citations and
states as follows:
By this Petition forReview, Petitioners Paul Freeman and Freeman Environmental Services,
Inc. state that there should be a finding that there has been no violation based upon the following:
A.
Petitioners
did not cause or allow the alleged violations
B.
The alleged violations was the result of uncontrollable circumstances
and
seek a determination
with respect to
the Administrative Citation in
this cause and a reduction
in the proposed civil penalties in
accordance with 415 ILCS
5/31/1.
WHEREFORE, the Petitioners request that this Board set this
matter forhearing regarding
the
IIEPA’s
findings of Administrative
Citation
and
impositions
of civil
penalties
and
after the
hearing, enter
an
Order
reversing the decision of the IEPA
with
respect
to
the Administrative
Citation
and civil
penalties; Petitioners further requestthat this Board grant such other and furtherrelief as this Board
deems just and appropriate.
Respectfully submitted,
•
PAUL FREEMAN and FREEMAN
ENVIRONMENTAL SERVICES, INC.
Petitioner
By:
(LkE~&/~L-
2~4~O~
Robert C.
Wilson, its
attorney
Prepared by:
Robert C. Wilson
Attorney at Law
P0 Box
544
117
West Poplar Street
Harrisburg IL 62946
618-252-1776
618-252-8222
-
fax
ARDC #3128411
G:~Documents\PH
-
WPDOCS\iepapetition.wpd
2
RECEIVED
BEFORE
THE
ILLINOISPOLLUTIONCONTROLBOARDCLERKS OFFICE
NOV
082005
PAUL FREEMAN and FREEMAN
)
ENVIRONMENTAL SERVICES, INC.
Pollution Control Board
Illinois Corporation,
)
)
Petitioner,
)
Petition for Review of
)
Notice of Administrative Citation
v.
)
)
ILLINOIS POLLUTION CONTROL BOARD
and PEOPLE OF THE
STATE OF ILLINOIS,
)
IEPA No. 350-05-AC
)
Respondents.
)
NOTICE OF FILING
AND
PROOF OF SERVICE
Theundersigned certifies that an original and nine copies of Petitioners’ Petition for Review
was served upon the Clerk of the Illinois Pollution
Control Board, and one
copy was
served upon
the following party of record in this cause by enclosing same in envelopes addressed to:
Dorothy Gunn, Clerk
Attn: Division ofLegal Counsel
Illinois Pollution Control Board
.
Illinois Environmental Protection Agency
James R. Thompson Center
1021 N. Grand Ave. East
100W. Randolph
St., Suite 11-500
P.O. Box
19276
Chicago, IL
60601
Springfield,
IL 62794-9276
with
postage fully prepaid, ap~l
by
depositing
said envelopes
in
a U.S.
Post Office Mail
Box
in
Harrisburg, Illinois on the3~day ofNovember, 2005, before 5:30 p.m..
PAUL FREEMAN and FREEMAN
ENVIRONMENTAL SERVICES, INC. ,Petitioner,
By:
o
ert C. Wi
on, its attorney
Preparedby:
Robert C. Wilson
Attorney atLaw
P0 Box 544
117 West Poplar Street
Harrisburg IL 62946
618-252-1776
618-252-8222
-
fax
ARDC #3128411
G:\Documents\PH
-
WPDOCS\iepapetition.wpd
3
RECE~VED
CLERK’S OFFICE
BEFORE
THE
ILLINOISPOLLUTIONCONTROL BOARD
NOV
082005
PAUL FREEMAN and FREEMAN
)
STATE
OF ILLINOIS
ENVIRONMENTAL SERVICES, INC.
)
Pollution
Controi
Board
•
Illinois Corporation,
)
•
)
Petitioner,
)
Petition for Review of
Notice of Administrative Citation
v.
)
)
ILLINOIS POLLUTION CONTROLBOARD
and PEOPLE OF THE STATE OF ILLINOIS,
)
IEPA No. 350-05-AC
)
Respondents.
)
NOTICE
OF APPEARANCE
I, Robert C. Wilson, Attorney at Law, herebyenter my appearance on behalfofPetitioner, PAUL
FREEMAN and FREEMAN ENVIRONMENTAL SERVICES, INC. in the above
entitled cause.
Robert C. Wilson
Prepared by:
Robert C.
Wilson
Attorney at Law
P0 Box 544
117 West Poplar Street
Harrisburg IL 62946
618-252-1776
618-252-8222
-
fax
ARDC #3128411
G:\Documents\PH
-
WPDOCSMepapetition.wpd
4
