Lisa Madigan
AI'I ORNEY GENERAL
The Honorable Dorothy Gunn
Illinois Pollution Control Board
James R. Thompson Center, Ste. 11-500
100 West Randolph
Chicago, Illinois 60601
Dear Clerk Gunn
:
Enclosed for filing please find the original and ten copies of a Motion for Default for J&S
Companies, Inc., in regard to the above-captioned matter. Please file the original and return a file-
stamped copy to me in the enclosed, self-addressed envelope .
Thank you for your cooperation and consideration
.
OFFICE OF THE ATTORNEY GENERAL
STATE OF ILLINOIS
January 30, 2006
Re
:
People
v.
J & S Companies, Inc., et al.
PCB 06-33
RECEIVED
CLERKS OFFICE
FES 0 12006
STATE OF ILLINOIS
Pollution Control Board
KLG/pp
Enclosures
Very tryly yours,
Kristen Laughridge Gale
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
(217) 782-9031
500 South Second Street, Springfield, Illinois 62706
•
(217) 782-1090
• TTY: (217) 785-2771
•
Fax: (217) 782-7046
100 West Randolph Street, Chicago, Illinois 60601
• (312) 814-3000
• TTY: (312) 814-3374
• Fax: (312) 814-3806
1001 East Main, Carbondale, Illinois 62901
• (618) 529-6400
• TTY: (618) 529-6403
•
Fax: (618) 529-6416
RECEIVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD CLERK'S OFFICE
PEOPLE OF THE STATE OF
)
FES 0
12006
ILLINOIS,
)
STATE OF ILLINOIS
Pollution Control Board
Complainant,
)
vs .
)
PCB No. 06-33
(Enforcement)
J & S COMPANIES, INC ., a Missouri
)
corporation, and FIRST CHOICE
)
CONSTRUCTION, INC ., an Illinois
)
corporation,
)
Respondents
.
)
NOTICE OF FILING
To
:
J & S Companies, Inc
.
J & S Companies, Inc
.
c/o C T Corporation System, R.A .
c/o Daniel J . McAuliffe, R.A .
208 S. LaSalle St., Ste. 814
7777 Bonhamme Avenue, Ste . 2004
Chicago, IL 60604-1101
Clayton, MO 63105
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
Control Board of the State of Illinois, a MOTION FOR DEFAULT FOR J&S COMPANIES, INC
., a
copy of which is attached hereto and herewith served upon you
.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN,
Attorney General of the
State of Illinois
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: January 30, 2006
MATTHEW J. DUNN, Chief
Environmental Enforcement/Asbestos
Litigation
$1sion
BY-
%~ v
0
/ KRISTEN LAUGHRIDGE GALE
Assistant Attorney General
Environmental Bureau
CERTIFICATE OF SERVICE
I hereby certify that I did on January 30, 2006, send by First Class Mail, with postage
thereon fully prepaid, by depositing in a United States Post Office Box a true and correct copy
of the following instruments entitled NOTICE OF FILING and MOTION FOR DEFAULT FOR
J&S COMPANIES, INC .,
To
:
J & S Companies, Inc.
J & S Companies, Inc
.
c/o C T Corporation System, R.A .
c/o Daniel J . McAuliffe, R.A .
208 S. LaSalle St., Ste. 814
7777 Bonhamme Avenue, Ste. 2004
Chicago, IL 60604-1101
Clayton, MO 63105
and the original and ten copies by First Class Mail with postage thereon fully prepaid of the
same foregoing instrument(s)
:
To :
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
Suite 11-500
100 West Randolph
Chicago, Illinois 60601
A copy was also sent by First Class Mail with postage thereon fully prepaid to
:
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
Springfield, IL 62794
This filing is submitted on recycled paper
.
K~ 'ISTEN LAUGHRIDGE GALE
assistant Attorney General
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD 14
eRK
,S
E
OVI
E®
FEB 0 1 2006
Pollution
OF
Control Bo
ILLINOIS
STATE
PEOPLE OF THE STATE OF ILLINOIS,
)
vs .
)
No. PCB 06-33
(Enforcement - Land)
Complainant,
.J & S COMPANIES, INC., a Missouri
corporation, and FIRST CHOICE
CONSTRUCTION, INC., an Illinois
corporation,
Respondents
.
MOTION FOR DEFAULT FOR J&S COMPANIES, INC
.
Complainant, PEOPLE OF THE STATE OF ILLINOIS, by Lisa Madigan, Attorney
General of the State of Illinois, pursuant to pursuant to Section 2-1301 of the Code of Civil
Procedure, 735 ILCS 5/2-1301 (2004) and Section 101 .204(d) of the Board's Procedural Rules,
35 III. Adm. Code 101 .204(d), hereby moves for Default Judgment against the Respondent,
J&S COMPANIES, INC. In support of this Motion, Complainant states as follows
:.
1
.
On September 1, 2005, the Plaintiff filed a Complaint with the Court, stating a
cause of action against the Respondent, J&S COMPANIES, INC . for Waste Disposal Violations
and Demolition Debris Violations
.
2
.
The complaint was signed for receipt on September 7, 2005 by the Respondent's
Agent. A copy of the executed certified mail receipt is attached
.
3
.
The Respondent, J&S COMPANIES, INC., has not filed an Answer or other
responsive pleading and has therefore failed to timely appear, answer or otherwise plead as
required by Section 101 .204(d) of the Board's Procedural Rules, 35 III . Adm. Code 101 .204(d) .
1
5 .
Due to Defendant's failure to answer, or otherwise respond to Plaintiff's
Complaint, Plaintiff is entitled, pursuant to Section 2-1301 of the Illinois Code of Civil Procedure,
735
ILCS
5/2-1301 (2004), to have a finding of default entered against Defendant .
6 .
The Illinois Attorney General is authorized by Section 42 of the Act, 415
ILCS
5/42 (2004), pursue civil penalties for violations of the Act :
(a) Except as provided in this Section, any person that violates any provision
of this Act or any regulation adopted by the Board, or any permit or term or
condition thereof, or that violates any determination or order of the Board
pursuant to this Act, shall be liable to a civil penalty of not to exceed $50,000 for
the violation and an additional civil penalty of not to exceed $10,000 for each day
during which the violation continues ; such penalties may, upon order of the
Board or a court of competent jurisdiction, be made payable to the
Environmental Protection Trust Fund, to be used in accordance with the
provisions of the Environmental Protection Trust Fund Act .
The uncontested allegations of the Complaint as well as the affidavits filed with this Motion
demonstrate that Defendant has committed violations of the Act .
7
.
By violating the Illinois Environmental Protection Act, the Defendant, J&S
Companies, Inc. is subject to civil penalties under Section 42(a) of the Act, 415
ILCS
5/42(a)
(2004) and to injunctive relief under Section 42(e) of the Act, 415
ILCS
5/42(e) (2004). The
People request a civil penalty of $25,000 based upon the facts cited above .
8
.
The Illinois General Assembly has recognized specific threats posed by improper
waste disposal. In section 20 of the Act, 415
ILCS
5/20 (2004), the Act in pertinent part states
as follows
:
Sec. 20 (a) The General Assembly finds :
(1) that economic and population growth and new methods of
manufacture, packaging, and marketing, without the parallel growth of
facilities enabling an ensuring the recycling, reuse and conservation of
natural resources and solid waste, have resulted in a rising tide of scrap
and waste materials of all kinds ;
(2) that excessive quantities of refuse and inefficient and improper
methods of refuse disposal result in scenic blight, cause serious hazards
2
to public health and safety, create public nuisances, divert land from
more productive uses, depress the value of nearby property, offend the
sense, and otherwise interfere with community life and development
;
9 .
In this case, the improper disposal of demolition waste presented a real and
serious threat to the health and general welfare of the general public.
in addition to degrading
the quality of the land of the State. As noted in the complaint, the attached affidavit of IEPA
Inspector Christopher Cahnovsky, and the attached December 30, 2003 inspection report, the
demolition debris was improperly disposed of a at site which was not permitted by the Illinois
EPA as a sanitary landfill nor met the requirements of the Act and regulations and the
standards promulgated thereunder .
WHEREFORE, the Complainant, People of the State of Illinois, respectfully requests
that this Court enter a default order and, after proper notice, following a hearing if necessary,
enter a default judgment and assess a penalty against the Respondent, J&S COMPANIES,
INC .
Respectfully submitted ;
PEOPLE OF THE STATE OF ILLINOIS,
ex reL
LISA MADIGAN,
Attorney General of the
State of Illinois
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: January 30, 2006
MATTHEW J. DUNN, Chief
Environmental Enforcement/Asbestos
Litigation Division
BY .
R TEN LAUGHRIDGE GALE
Environmental Bureau
Assistant Attorney General
3
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEOVED
CLERK'S OFFICE
PEOPLE OF THE STATE OF ILLINOIS,
~
FEB
12006
Complainant,
)
STATE OF
ILLINOIS
Pollution Control Board
vs .
)
No. PCB 06-33
(Enforcement - Land)
J & S COMPANIES, INC ., a Missouri
)
corporation, and FIRST CHOICE
)
CONSTRUCTION, INC., an Illinois
)
corporation,
)
Respondents .
)
AFFIDAVIT OF CHRISTOPHER CAHNOVSKY
Upon penalties as provided by law pursuant to Section 1-109 of the Code of Civil
Procedure, the undersigned certifies that the statements set forth in this instrument are true and
correct, except as to matters therein stated to be on information and belief and as to such matters
the undersigned certifies as aforesaid that I verily believes the same to be true
:
1
.
I, CHRISTOPHER CAHNOVSKY, am employed by the Illinois Environmental
Protection Agency ("Illinois EPA"), as Regional Manager in the Field Operations Section of the
Bureau of Land ("BOL"). I have been employed by the Illinois EPA as Regional Manager for
five years. Prior to promotion to Regional Manager, I was an Environmental Protection
Specialist conducting solid waste field inspections since May 1990
.
2 .
As part of my duties in the Bureau of Land, I am responsible for supervision of
Agency personnel in all aspects of solid waste related activities, including review and
commenting on all solid waste inspection reports prior to submittal to the main office. I also
perform field inspections for the BOL Collinsville Region of solid waste facilities including but
not limited to site visits, interviews, and records review . I have personally been involved in
approximately over 1,200 field inspections
.
3 .
I have a bachelor's degree in Animal Science from Southern Illinois University at
Carbondale and a master's degree in Environmental Science/Studies from Southern Illinois
University at Edwardsville. I have a Professional Certification of a Certified Hazardous
Materials Manager from the Institute of Hazardous Material Management.
4 .
As a general basis for the opinions and conclusions I provide below, I can state
that general construction and demolition debris means non-hazardous, uncontaminated materials
resulting from the construction, remodeling, repair, and demolition of utilities, structures, and
roads, limited to the following : bricks, concrete, and other masonry materials ; soil, rock ; wood,
including non-hazardous painted, treated, and coated wood and wood products ; wall coverings ;
plaster; drywall; plumbing fixtures; non-asbestos insulation ; roofing shingles and other roof
coverings; reclaimed asphalt pavement ; glass; plastics that are not sealed in a manner that
conceals waste; electrical wiring and components containing no hazardous substances ; and
piping or metals incidental to any of those materials, as defined by Section 3 .160(a) of the Act,
415 ILCS 5/3 .160(a).
5
.
I am familiar with the Illinois Attorney General's case involving and the
allegations against J&S Companies, Inc. In support of the People's Motion for Default Judgment,
I provide the following factual statements, personal observations, and opinions and conclusions
based upon my experience and expertise
.
6 .
On December 30, 2003, I conducted an inspection at 7401 Bunkum Road in East
St. Louis, St. Clair County, Illinois. As part of the regular practice of business at the Illino s
EPA, I created an inspection report of what I observed during the inspection . The inspection
report was created during and after the inspection . Upon completion of the inspection report, it
was kept in the course of regularly conducted business activity at the Illinois EPA. The
inspection report I created is attached hereto as Exhibit 1
.
7 .
Photographs #1 through #12 of the attached inspection report were taken by me
and truly and accurately depict the conditions that I observed at the Site on December 30, 2003
.
8
.
I certify all factual statements, observations, and photographs within the
inspection report
.
FURTHER AFFIANT SAYETH NOT .
Subscribed and Sworn to before me
this
a
3 "day of .avttutrj
, 2006 .
NOTARY PUBLIC
:,
"OFFICIAL SEAL"
i
PAULA OTTENSMEIER
NOTARY PUBLIC-STATE OF ILLINOIS
MY COMMISSION EXPIRES NOV. 9. 2007
/Iiiilllllll .. . lllllll1I
CHRISTOPHER CAHN VSKY
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Revised 06/18/2001
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
Open Dump Inspection Checklist
(Open Dump - 1)
RE
C~~~I~Vy~°Y~
'~ I
rt
SECTION
DESCRIPTION
VIOL
ILLINOIS ENVIRONMENTAL PROTECTION ACT REQUIREMENTS
1
.
9(a)
CAUSE, THREATEN OR ALLOW AIR POLLUTION IN ILLINOIS
i
2
.
9(c)
CAUSE OR ALLOW OPEN BURNING
3 .
12(a)
CAUSE, THREATEN OR ALLOW WATER POLLUTION IN ILLINOIS
4 .
12(d)
CREATE A WATER POLLUTION HAZARD
5 .
21 (a)
CAUSE OR ALLOW OPEN DUMPING
012
6 .
21(d)
CONDUCT ANY WASTE-STORAGE, WASTE-TREATMENT, OR WASTE- DISPOSAL
OPERATION
:
(1)
Without a Permit
113
(2)
In Violation of Any Regulations or Standards Adopted by the Board
OR
DISPOSE, TREAT, STORE, OR ABANDON ANY WASTE, OR TRANSPORT ANY
1113
7 .
21(e)
WASTE INTO THE STATE AT/TO SITES NOT MEETING REQUIREMENTS OF ACT
8 .
21(p)
CAUSE OR ALLOW THE OPEN DUMPING OF ANY WASTE IN A MANNER WHICH RESULTS
IN ANY OF THE FOLLOWING OCCURRENCES AT THE DUMP SITE
:
(1)
Litter
~4
(2)
Scavenging
(3)
Open Burning
(4)
Deposition of Waste in Standing or Flowing Waters
(5)
Proliferation of Disease Vectors
(6)
Standing or Flowing Liquid Discharge from the Dump Site
County :
St. Clair
LPC# :
1630455275
Region
:
6 - Collinsville
Location/Site Name
:
East St. Louis/McKnight,
')I
r,,,M `
Date
:
12/30/2003
Time: From
9:50
To
10:2
Previous Inspection Date
:
.
Weather :
Inspector(s) :
Chris Cahnovsky
-45 F soil conditions were wet
No. of Photos Taken : #
12
Est. Amt. of Waste
:
650
yds3
Samples Taken
:
Yes #
No
Interviewed
:
Jim McKnight
Complaint # :
Jim McKnight - Classic MFG, Inc
.
J&S Demolition Division
Responsible Party
7401 Bunkum Road
902 Cherokee Street
Mailing Address(es)
and Phone
East St. Louis, Illinois 62204
St. Louis, Missouri 63118
Number(s) :
618/398-5966
314/776-4000
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LPC # 1630455275
Inspection Date :
12/30/2003
Signa
of Inspector(s)
Informational Notes
1
.
[Illinois] Environmental Protection Act : 415 ILCS 5/4 .
2 .
Illinois Pollution Control Board : 35 111 . Adm. Code, Subtitle G
.
3 .
Statutory and regulatory references herein are provided for convenience only and should not be construed as legal
conclusions of the Agency or as limiting the Agency's statutory or regulatory powers
.
Requirements of some statutes
and regulations cited are in summary format . Full text of requirements can be found in references listed in 1 . and 2
.
above .
4 .
The provisions of subsection (p) of Section 21 of the [Illinois] Environmental
Protection Act shall be enforceable either
by administrative citation under Section 31 .1 of the Act or by complaint under Section 31 of the Act
.
5 .
This inspection was conducted in accordance with Sections 4(c) and 4(d) of the [Illinois]
Environmental Protection Act:
415 ILCS 5/4(c) and (d) .
6 .
Items marked with an "NE" were not evaluated at the time of this inspection
.
Revised 06/18/2001
(Open Dump - 2)
(7)
Deposition of General Construction or Demolition Debris ;' or Clean Construction or
Demnlitinn Debris
~~
9 .
55(a)
NO PERSON SHALL
:
(1)
Cause or Allow Open Dumping of Any Used or Waste Tire
(2)
Cause or Allow Open Burning of Any Used or Waste Tire
35 ILLINOIS ADMINISTRATIVE CODE REQUIREMENTS
SUBTITLE G
FAILURE TO SUBMIT AN APPLICATION FOR A PERMIT TO DEVELOP AND
~~
10 .
812.101(a)
OPERATE A LANDFILL
11 .
722.111
HAZARDOUS WASTE DETERMINATION
12 .
808.121
SPECIAL WASTE DETERMINATION
13 .
809.302(a)
ACCEPTANCE OF SPECIAL WASTE FROM A WASTE TRANSPORTER WITHOUT A
WASTE HAULING PERMIT, UNIFORM WASTE PROGRAM REGISTRATION AND
PERMIT AND/OR MANIFEST
OTHER REQUIREMENTS
14.
APPARENT VIOLATION OF : ( ) PCB ;
(
CIRCUIT COURT
CASE NUMBER :
ORDER ENTERED ON :
15 .
OTHER :
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1630455275 - St. Clair County
East St. Louis/McKnight
Date of Inspection: December 30, 2003
Prepared by: Chris Cahnovsky
NARRATIVE
On December 30, 2003, I conducted an inspection at 7401 Bunkum Road in East St
.
Louis, Illinois. This address is the location of Classic Manufacturing, Inc . owned by Jim
McKnight. Mr. Jim McKnight was present during this inspection
.
I observed about .68 piles of general construction and demolition debris along the
entrance road to the property. I also observed about 22 piles of general C&D debris
behind the Classic Mfg . building. This general C&D debris consisted of brick, metal,
plaster, paper, wood, pipe chase, wire and rebar . The paper appeared to be records
associated with a school .
Mr. McKnight stated that this waste was from the Landsdowne Jr. High School and was
dumped here by First Choice Trucking . Mr. Knight~gave First Choice permission to
dump on his property. Apparently, Mr. McKnight asked First Choice for brick to use as a
road base. The material I observed during this inspection was what First Choice brought
Mr. McKnight. Mr. McKnight stated that he dealt with Mike Bowman of First Choice
Trucking .
According to a February 6, 2003 Construction Contract obtained by the St . Clair County
Health Department (SCCHD), the East St . Louis Board of Education - District 189
contracted J & S Companies, Inc. of St. Louis, Missouri to demolish the Landsdowne Jr .
High School (Attachment 1). Through some means, First Choice brought waste from the
Landsdowne demolition site to the McKnight Property. This waste meets the definition
of general construction and demolition debris pursuant to Section 3 .160a of the Illinois
Environmental Protection Act and should have gone to a permitted landfill
.
This site first came to the attention of the Illinois EPA on November 21, 2003 when a
drive-by inspection was conducted by Mike Grant and Tom Miller of the Illinois EPA
.
The SCCHD conducted an inspection at this site on November 25, 2003 . The Health
Department contacted J&S Demolition about the waste . Apparently, J & S was aware
that First Choice was hauling waste to the McKnight property .
On December 3, 2003, Ron Robeen and Alan Grimmet with the Illinois EPA's Bureau of
Air conducted an inspection at this site . During this inspection, Mr . Grimmet took two
samples for asbestos . One sample was taken of white pipe chase waste and the other was
of mastic adhering to floor pieces. The samples were sent to Philips Service Corporation
in Columbia, Illinois on December 3, 2003. On December 5, 2003, the Agency received
the results of the analysis (Attachment 2) . The mastic tested negative for asbestos and the
white pipe chase tested positive for asbestos, 12 percent chrysotile
.
Uiwk
:
:
(t
2011!
REVIEWER MD
1630455275 - St. Clair County
East St. Louis/McKnight
Page 2 of 3
On December 19, 2003, I received a call from Sean Boles of J&S . Mr. Boles was aware
that material from Landsdowne was going to the McKnight Property . He stated that he
received a letter from Mr. McKnight asking that the material be dumped on his property .
Mr. Boles faxed me a copy of the letter (Attachment 3) . The letter was addressed Sean
Boles from Jim McKnight. The letter stated that the brick dumped on the McKnight
property was going to be used as a driveway base. This letter was dated December 5,
2003. This date is after the waste had already been dumped on site
.
I asked Mr. McKnight why the letter was dated after the waste had already been dumped
on his property. He stated that Mike Bowman called him and asked him to write the
letter to J&S. Mr. McKnight agreed that the letter was sent after the waste had been
dumped on-site. He also agreed that the waste had to be sorted and cleaned prior to use as
a road base
.
Mr. Boles stated that the removal of the asbestos was under a different contract and not
preformed by J&S . He stated that all known asbestos was removed from the building
prior to demolition under the supervision of IE Consultants in St . Louis. He was not
aware that the waste that went to the McKnight property was general C&D, not "clean
fill". He stated that he was not on the job site
.
Potentially responsible parties to this open dumping
Classic Manufacturing, Inc
.
Jim McKnight
7401 Bunkum Road
East St . Louis, Illinois 62204
618/398-5966
First Choice Trucking
First Choice Construction, Inc
.
Mike Bowman
1932 Townsley Lane
East St. Louis, Illinois 62204
618/398-2875
J & S Companies, Inc .
J & S Demolition Division
902 Cherokee Street
St. Louis, Missouri 63118
1630455275 - St. Clair County
East St. Louis/McKnight
Page 3 of 3
East St. Louis Board of Education
School District 189
Nathaniel J Anderson, Superintendent
1005 State Street
East St. Louis, Illinois 62201
618/583-8200
International Engineering Consultants, Inc .
6420 South Sixth Street
Springfield, Illinois 62707
217/529-8027
The following apparent violations were observed during this inspection
:
9(a) ;
21(a) ;
21(4)(1)(2) ;
21(e) ;
21(p)(1) ;
21(p)(7) and
812.101(a) .
cnc/mcknighmarr.doc
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7401 Bunkum Road
Classic MFG, Inc
.
Runlnim Road
State of Illinois
Environmental Protection Agency
Facility Diagram
Sand Plant
Date of Inspection
:
12/30/2003
Inspector :
Chris Cahnovsky
Site Code
:
1630455275
County :
St. Clair
Site Name:
East St. Louis/McKnight
Time :
9:50-10:20
LPC #1630455275 - St. Clair County
East St. Louis/McKnight
FOS File
DATE: December 30, 2003
TIME : 9:50-10:20
DIRECTION : East
PHOTO by : Chris Cahnovsky
PHOTO FILE NAME :
1630455275-12302003-001
COMMENTS :
DATE: December 30, 2003
TIME: 9:50-10:20
DIRECTION : East
PHOTO by : Chris Cahnovsky
PHOTO FILE NAME :
163045527512302003-002
COMMENTS :
DIGITAL PHOTOGRAPH PHOTOCOPIES
LPC #1630455275 - St. Clair County
East St. Louis/McKnight
FOS File
DATE: December 30, 2003
TIME: 9:50-10:20
DIRECTION : East
PHOTO by: Chris Cahnovsky
PHOTO FILE NAME
:
163045527512302003-003
COMMENTS :
DATE : December 30, 2003
TIME: 9:50-10:20
DIRECTION: Southeast
PHOTO by: Chris Cahnovsky
PHOTO FILE NAME :
163045527512302003-004
COMMENTS :
DIGITAL PHOTOGRAPH PHOTOCOPIES
LPC #1630455275 - St. Clair County
East St. Louis/McKnight
FOS File
DATE: December 30, 2003
TIME: 9:50-10:20
DIRECTION : East
PHOTO by: Chris Cahnovsky
PHOTO FILE NAME :
1630455275-12302003-005
COMMENTS :
DATE : December 30, 2003
TIME: 9:50-10:20
DIRECTION : North
PHOTO by : Chris Cahnovsky
PHOTO FILE NAME :
163045527512302003-006
COMMENTS :
DIGITAL PHOTOGRAPH PHOTOCOPIES
LPC #1630455275 - St. Clair County
East St. Louis/McKnight
FOS File
DATE: December 30, 2003
TIME: 9:50-10:20
DIRECTION : North
PHOTO by : Chris Cahnovsky
PHOTO FILE NAME :
163045527512302003-007
COMMENTS :
DATE : December 30, 2003
TIME : 9:50-10:20
DIRECTION: Southwest
PHOTO by : Chris Cahnovsky
PHOTO FILE NAME :
163045527512302003-008
COMMENTS:
DIGITAL PHOTOGRAPH PHOTOCOPIES
LPC #1630455275 - St. Clair County
East St. Louis/McKnight
FOS File
DATE: December 30, 2003
TIME : 9:50-10:20
DIRECTION : West
PHOTO by: Chris Cahnovsky
PHOTO FILE NAME :
1630455275-12302003-009
COMMENTS :
DATE: December 30, 2003
TIME : 9:50-10:20
DIRECTION : South
PHOTO by: Chris Cahnovsky
PHOTO FILE NAME :
163045527512302003-010
COMMENTS:
DIGITAL PHOTOGRAPH PHOTOCOPIES
LPC #1630455275 - St. Clair County
East St. Louis/McKnight
FOS File
DATE: December 30, 2003
TIME: 9:50-10:20
DIRECTION: Northwest
PHOTO by : Chris Cahnovsky
PHOTO FILE NAME :
163045527512302003-011
COMMENTS :
DATE : December 30, 2003
TIME: 9:50-10:20
DIRECTION : Northwest
PHOTO by: Chris Cahnovsky
PHOTO FILE NAME :
163045527512302003-012
COMMENTS :
DIGITAL PHOTOGRAPH PHOTOCOPIES
