To :
Stephen F . Hedinger
Hedinger Law Office
2601 South Fifth Street
Springfield, IL 62703
Illinois Environmental Protection Agency
1021 North Grand Avenue East
PSpringfield,
.O. Box 19276Illinois
62794-9276
(217) 782-5544
Dated
: February 23, 2006
NOTICE OF FILING
Mark S
. Cochran
Bellatti, Barton, Hamill & Cochran, LLC
Suite A
944 Clock Tower Drive
Springfield, Illinois 62704 -
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution Control
Board of the State of Illinois the following instrument(s) entitled COMPLAINANT'S RESPONSE
TO RESPONDENT HARRISON'S MOTION FOR SUMMARY JUDGMENT
.
Respectfully submitted,
1J L
~AL~ 10
Miche e M. Ryan
Special Assistant Attorney General
THIS FILING SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVED
CLERK'S OFFICE
ILLINOIS ENVIRONMENTAL
FEB 2 7 2006
PROTECTION AGENCY,
Complainant,
AC 05-08
Pollution
STATE OF
Control
ILLINOIS
Board
V .
TED HARRISON and GERALD S
. GILL,
Respondents.
(IEPA No
. 330-04-AC)
RECEIVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CLERK'S OFFICE
FEB 2 7 2006
ILLINOIS ENVIRONMENTAL
)
STATE OF ILLINOIS
PROTECTION AGENCY,
Pollution Control Board
Complainant,
)
AC 05-08
V .
)
(IEPA No . 330-04-AC)
TED HARRISON and GERALD S . GILL, )
Respondents.
)
COMPLAINANT'S RESPONSE TO
RESPONDENT HARRISON'S MOTION FOR SUMMARY JUDGMENT
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 Ill . Adm . Code 101
.516(a), and respectfully requests that the Board deny Respondent
Harrison's Motion for Summary Judgment for the reasons provided in support thereof below
.
Summary judgment is appropriate when the record shows that there is no genuine issue of
material fact and that the movant is entitled to judgment as a matter of law . People v
. Poland, et al.,
PCB No
. 98-148 (November 16, 2000) p .6, citing Dowd & Dowd, Ltd
. v. Gleason, 181111.2d 460,
693 N.E.2d 358 (1998)
; 35111. Adm. Code 101 .516(b)
. Summary judgment should only be granted
when the movant's right to relief is "clear and free from doubt ." Id.
(citations omitted).
A genuine issue of material fact appears in paragraph 2 of Respondent's Motion
. Said
paragraph claims that "Respondent Harrison did not cause or allow the deposition ofwaste materials
alleged by the administrative citation
." This statement directly contradicts the pleadings in this case,
which allege that Respondent Harrison is the former owner and operator of the site, who caused or
I
allowed open dumping of waste in a manner resulting in litter and deposition of construction or
demolition debris
. Administrative Citation at 1-2
. These allegations in the Citation are supported by
the inspection report dated May 23, 2004, which itself is supported by affidavit
. Therefore, the fact
of whether Respondent Harrison caused or allowed open dumping at the site i s clearly in dispute
. As
the ultimate fact in the case, it is unquestionably material
. As such, it is apposite that the Board deny
Respondent's motion on this issue alone .
Respondent's motion goes on to claim that Respondent Harrison did not own the property on
May 23, 2004, the date of the inspection resulting in the Administrative Citation
. Motion at 119, 10,
12, 15
. This fact is not in dispute, as acknowledged in the May 23, 2004 inspection report attached
to the Administrative Citation
. However,
.the ownership of the property on May 23, 2004 has never
been the basis for the allegations against Respondent Harrison
. Rather, as indicated in the May 23,
2004 inspection report, wastes including general refuse, lumber, scrap metal, vehicles, used tires,
concrete, bricks, and chemical wastes in containers were originally observed on the site on May 20,
2002, when Respondent Harrison owned the property
. Inspection Report dated May 23, 2004, p
. 8.
Although progress had been made in removing these wastes in the two years between inspections,
"much waste remain[ed] to be removed"
on May 23, 2004. Id.
at 9. Respondent Harrison admitted
in the Real Estate Agreement ("Agreement") with Respondent Gill that he stored "rubber tires and
junk" on the site
. Motion, Exh . 1, ¶9
. It is these wastes, for which Respondent Harrison originally
had sole responsibility, that form the basis for the allegations against Respondent Harrison
. Illinois
EPA need not prove ownership of a site in order to show a violation of 415 ILCS 5/21(p)
. Illinois
EPA v. Coleman,
PCB No
. AC 04-18 (June 17, 2004) p . 6.
2
Respondent Harrison further claims that the Agreement between him and Respondent Gill
resolves his liability to the State
. Motion at ¶¶l 1-13 . The State was not a party to the Agreement
between the Respondents, and therefore cannot be bound by said contract
. See People's Sav. &Loan
Ass 'n v. Brinkoetter, 263 111
. App . 391 (3d Dist . 1931). Nor can the parties to that contract claim any
authority to either waive the State's right (and duty) to enforce the Environmental Protection Act, or
to grant each other a release from liability for violating environmental laws
. The fact that the
Agreement restricts the buyer's future legal recourse against the seller does not make it legal for
Respondent Harrison to leave open dumped waste on the site when he sold it
. The fact that the
Agreement states that Respondent Harrison would continue for several weeks after the closing date
to remove all of the wastes indicates that the parties were aware of Respondent Harrison's liability_
for the wastes .
Respondent Harrison does not deny that violations existed at the site on May 23, 2004, and
indeed cannot, because said violations are supported in the record by the inspection narrative, photos
and affidavit included with the filing of the Administrative Citation
. Rather, Respondent Harrison
claims that he is not responsible for the violations, because he had no "right to do anything" on the
site after September 30, 2002, and that he "would have been a criminal trespasser" if he had
attempted to do so
. Motion at ¶¶12 & 15
. The trespassing conclusion does not necessarily follow,
because Respondent Gill had every right to permit Respondent Harrison to access the site
. It is a
reasonable inference that Respondent Gill would have been willing to do so to allow Respondent
Harrison to remove the open dumped waste he was supposed to have removed the site
. In point of
fact, Respondent Harrison was observed at the site removing materials from Respondent Gill's shed
on November 6, 2003 . See Exhibit A, p
. 4 and supporting affidavit of David Jansen (attached)
. On
3
December 3, 2003, Respondent Harrison told Illinois EPA inspectors who again observed him on the
site that he was working on cleaning up the waste and removing materials that he had left on the
property now owned by Respondent Gill . Id.
at 5 It is therefore indisputable that Respondent
Harrison continued to exercise control over and manage the wastes he left on the site for more than a
year after selling the property to Respondent Gill
.
Respondent also raises the issue that "the inspector did not directly observe Mr
. Harrison do
anything on the date of the inspection ." Motion at ¶2
. However, 415 ILCS 5/31
.1(b) requires only
that Illinois EPA "on the basis of direct observation, determine that any person has violated any
provision of subsection (o) or
(p)" prior to issuing an Administrative Citation . Illinois EPA did
make such a determination regarding Respondent Harrison, based on the inspection conducted on
May 23, 2004, as indicated in the Administrative Citation
.
. There is no legal requirement that the
individual be "caught in the act" of committing the offense, and the Board has often found a
Respondent in violation of Section 21(p) without such evidence
. E.g., Coleman, supra
; Illinois EPA
v
. Bencie, PCB No, AC 04-77 (February 16, 2006)
; Illinois EPA v . Groff
PCB No. AC 05-20
(October 20, 2005) ; Illinois EPA v
. Brown, PCB No. AC 04-82 .
Illinois EPA has presented a factual basis that would arguably entitle it to judgment against
Respondent Harrison in this matter
. See Briggs, supra
at 6 (citation omitted)
. Therefore, summary
judgment in favor of Respondent Harrison is inapposite
.
4
WHEREFORE, the Illinois Environmental Protection Agency requests that the Board deny
Respondent Harrison's Motion for Summary Judgment
.
DATED : February 23, 2006
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P .O
. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant
5
Michelle M . Ryan
Special Assistant Attorney General
IN THE MATTER OF :
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
AFFIDAVIT
Ted Harrison Oil Co.
)
IEPA DOCKET NO.
Respondent
.
)
Affiant, David C
. Jansen, being first duly sworn, voluntarily deposes and states as
follow :
1
. Affiant is a field inspector employed by the Land Pollution Control
Division of the Environmental Protection Agency and has been so
employed at all times pertinent hereto
.
2
. On November 6, 2003, between approximately 1
:25 PM and 2 :00 PM,
Affiant conducted an inspection of a disposal site operated without an
Agency permit, located in Cass County, Illinois and known as Ted
Harrison Oil by the Illinois Environmental Protection Agency
. Said site
has been assigned site code number LPC# 0170255004 by the Agency
.
3
. Affiant inspected said Ted Harrison Oil open dump site by an on-site
inspection which included walking and photographing the site
.
4
. As a result of the activities referred to in paragraph 3 above, Affiant
completed the Inspection Report form attached hereto and made a part
hereof, which, to the best of Affiant's knowledge and belief, is an accurate
representation of Affiant's observations and factual conclusions with
respect to said Ted Harrison Oil open dump
.
aA,t
Subscribed and Sworn To before me
This-23 day of
'4'bw ~, moo
:'
NOTARY
CYNTHIA
OFFICIAL
PUBLIC, STATE
L
.
SEAL
WOLFE
OF ILLINOIS
Asp4-14i
MY COMMISSION
.p-11 ;1.7
;.
.}4dObSA%EXPIRES
3.2o 2oor
-I
ILLINOIS ENVIRONMENTAL PROTECTION . AGENCY
Open Dump Inspection Checklist
3ounty: LASS.
LPC#:
0170255004
_ocatipn/Site Name
: VIRGINIA/TED HARRISON OIL-
Date:
11/66/2003 Time
: From 1:05
pm
To
1:20
pm
Previous Inspection Date : ,06/19/2003
Inspector(s) : DAVID C. JANSEN
Weather
: 50 F, sunny, dry
Vo . of Photos Taken : # 6
-Est. Amt
. of Waste : 250
yds3 Samples Taken: Yes #
Interviewed :. TED HA RRISQN
Complaint # :
?e'sponsisle'Party
Vlailing Addees`s(es)
and Phone
Vumber(s):
.e"vised O6/1 87200i'
Mr. Ted Harrison
-Box 3185
Quihcy,
IL
.62301
EXHIBIT
IA
(Open Dump -
1)
Region : '5 -
Springfield
RELEASABLE
MAR 1 8 Z004
REVIEWER MM
Gerald Gill-
RECEIVED
100 Redbud Road
Box 200
DEC 2 3 2003
Virginia, IL 62691
1
EPA-DLPC
'SECTION
DESCRIPTION
VIOL
,ILLINOIS,EN-VIRONMENTAL PROTECTION ACT REQUIREMENTS
1 :, .8(a)
CAUSE, THREATEN OR ALLOW AIR POLLUTION IN ILLINOIS
2: 9(e)
j 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
ORALLOW OPEN DUMPING
6.- 21 (d)
CONDUCT ANY WASTE-STORAGE, WASTE-TREATMENT, OR WASTE- DISPOSAL
OPERATION:
.(1)
Without'a Permit
"
(2)
In Violation of Any Regulations or Standards Adopted by the Board
'DISPOSE, TREAT, STORE,
.bk ABANDON ANY WASTE, OR TRANSPORT ANY
~~
7. 21(e)
.21(P)
CAUSE OR ALLOW-THE OPEN DUMPING OF ANY WASTE
IN A MANNER WHICIi RESULTS
- .
(1)
Litter
~2)
Scavengihg
(3)'
Open Burning
., -
v(4)
Deposition of
Waste in Standing or Flowing Waters ,
_.
(5)
Proliferation of Disease Vectors
(g)
Standing or Flowing Liquid Discharge from the Dump Site"
.
LPC
#
0170255004
Inspection Date :
11/06/2003
C-
Sigr ature of Inspector(s)
Informational Notes
1 . [Illinois] Environmental Protection Act : 415 ILCS 5/4
.
2. Illinois Pollution Control Board : 35 III. Adm . Code, Subtitle G .
~J
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
.
.evised 06/18/2001
(Open Dump - 2)
(7
)
Deposition of General Construction or Demolition Debris ; or Clean Construction or
NI
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
10. 812 .101(a)
FAILUREOPERATE TOA
LANDFILLSUBMIT
AN APPLICATION FOR A PERMIT TO DEVELOP AND
FIR
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 :
BOL/FOS SPRINGFIELD REGION
MEMORANDUM
DATE:
TO
:
-December 15, 2003
Pc
t
DLPC/Divisioh File
i
SUBJECT: LPC # 01702550040-LCasss County
Region Manager
DE
2,3 2053
Virginia/Ted Harrison Oil
/E'p
FOS -File
a
~(pC
On November 6, 2003, I went to the above referenced Illinois EPA permitted LUST soil-
treatment- facilily located northeast of Virginia, IL (see attached aerial photo) to briefly
check_on its status on the way back from an inspection near Havana ., I arrived at the site
at about I :05=p.m.. It, was about 50°F, sunny, and dry . No one was on site .
When'I arrived I walked around the entrance'gate
. The truck seen in previous inspections
was parked outside the gate. The soil treatment cell looked as if it had been recently
tilled and there'weie'vehicle tracks down the center of the cell . I detected no petroleum
odor in the air as I walked over
the west border of the treatment cell . It looked like a thin
layer of soil had been removed from the west edge of the treatment cell . There was no
water ponded on . the treatment cell (see attached digital photo # -001) The top of the
leachate collection tank could be seen partially buried on the hillside sloping down from
the west edge of the treatment cell
. It was not leaking water out of its top, as had been
seen previou"sly . Some soil erosion was noted in the slope uphill and downhill from the
leachate tank.
South of the treatmenrcell a John Deere towed .scraper used for moving layers of soil was
.parked . It looked like the scraper had been moved recently . At the north ehtrance to the
site, the same vehicles previously observed during the last inspection were still parked
.there'.. Several of the large trucks observed still contain on rim used tires, and off-rim, .
.used•tires that still have not beeh prevented from accumulating water (see attached digital
photo # -002).
-.If Mr
. Ted Harrison intends to keep these tires, he will have to store them in accordance
with the-tire regalationg and provide notice to the Illinois EPA that he is operating a tire
stor=age facility
. Without his compliance with the tire storage requirements, the'tires must
be properly removed by an Illinois EPA registered used tire hauler and disposed at an
Illinois EPA registered used tire processor.
The site owner/operator has been referred to the IAGOrfor enforcement action for failure
to comply with the site's permit.
f1lieh left the permitted site at about 1 :20 p.m .,
and went to the part of the property •that
Ted Harrisori sold to Gerald dill (see attached aerial photo)
. There I met Ted Harrison,
Swho'was cieahing'materials out of the large on-site maintenance shed . He :told me that he
wanted to use some of the used tires stored in the open on the trucks located at the
LPC # 0170255004 - Cass County
Virginia/Ted Harrison Oil
Page 2
entrance to the permitted site
. He said some of the used tireson those trucks would be
removed and placed under cover inside a semi-truck trailer . He said Pherigo Salvage had
been removing used tires from the Gill property
.
He said that he had got the scraper at the permitted site to operate briefly before it broke
down again, and it currently needed a hose repaired
. He said while the scraper was
operating, soil was removed from the west edge of the site .
At the entrance to the Gill property, there were some white goods and other debris on the
ground. The waste in the ravine near the entrance southwest of the shed appeared
unchanged since the last inspection
. Parked further away from the entrance was a large
Area Disposal roll-off box filled with refuse
.
There were some tire sidewalls and used tires still dumped on the ground along the fence
line northeast of the shed (see attached digital photo # -003)
. Most of the tires that had
been previously seen along this fence line had been removed . Also northeast of the shed,
were some previously observed semi-truck trailers and miscellaneous debris that
apparently belong to Mr
. Harrison . The materials in the semi-truck trailers are apparently
in the process of being sorted and removed by Mr . Harrison .
Just northeast of the shed there was a large pit, with the excavated dirt piled off to the
side (see attached digital photo # -006)
. Inside the pit some old lumber, burnt wood,
landscape waste, and sheet metal had been discarded (see attached digital photo # -004)
.
The pit was about 25 feet long by 10 feet wide by 10 to 12 feet deep . Mr
. Harrison told
me that Mr. Gill dug the pit and discarded the refuse there
. In the event that Mr. Harrison
talked to Mr. Gill prior to me, I told him to tell Mr
. Gill that such disposal was not
allowed and that the waste needed to be removed and placed in the roll-off box for proper
disposal at an Illinois EPA permitted landfill. Northeast of the pit was a pile of junk
metal and tires (see attached digital photo # -005).
I left the site at about 2 :00 p.m.
On November 7, 2003 at about 4 :00 p.m., I telephoned Mr
. Gill, who resides at 100 Redbud
Road, Box 200, Virginia, IL 62691, and left a message on his voice mail to remove the waste
from the pit and place it in the roll-off box, and not to bury any waste on his property
. He did
not return my phone call
.
I returned to the Gill property on December 3, 2003, accompanied by Charlie King,
BOL/FOS Springfield Region, to determine if the refuse previously observed in the pit
had been removed
. We arrived at about 12:45 pm
. It was about 40°F, cloudy and wet.
We met Mr
. Harrison at the site who told us that Mr
. Gill had removed the refuse from
the pit, and placed it into a roll-off box for disposal at a landfill
. The pit had been
backfiiled with soil, and there was only a mound of dirt where the pit had been . Two of
the three old truck semi-trailers that had been parked northeast of the large metal shed on
LPC # 0170255004 - Cass County
Virginiafred Hairison Oil
Page 3
site had been moved from their original position, and parked close by . There was .
scattered debris on the ground around where the semi-truck trailers had been previously
located
. Some tires had been added to the pile of junk previously shown in photo # -005=
taken on November 60'.
The waste discarded in the ravine southwest of the large shed
appeared untouched since the November 6` h inspection . The metal roof on an old house
trailer parked
. near the adjacent entrance gate had been peeled off the top of the trailer and
was 6wt1ie ground:
Mr
. Harrison told us that he had been working on cleaning up the waste and removing
materials that he had left on the property now owned by Mr . Gill. He also said he had
finally gotten the scraper at the permitted site repaired, but the ground in the treatment
cell-was
too muddy to be moving any soil with the scraper
.
We,left the site at about 12 :55 pm .
cc:
DLPC/FOS -= Spfirigfield Region
DLC,'Greg Rich ardson
IAGO, Del Haschemeyer
IC # 0170255004 - Cass County
rginia/fed Harrison Oil Company
)S File
,ril 5, 1998 USGS aerial photo
'C # 0170255004- Cass County
rginiafed Harrison Oil Company
)S File
rri15, 1998 USGS aerial photo
Illinois Environmental Protection Agency
Bureau of Land
LPC # 0170255004
- Cass County
Virginia/Ted Harrison Oil
FOS File
Date
: 11/06/03
Time: 1 :09 pm
Direction : N
Photo by : D.C. Jansen
Photo File Name:
0170255004-11062003-001
Comments : South end of IL EPA
permitted soil treatment area, with
junk trucks at north entrance to site
in background
Date: 11/06/03
Time: 1 :14 pm
Direction
: W
Photo by : D.C. Jansen
Photo File Name :
017025500411062003-002
Comments : junk trucks filled with
used tires at north entrance to
permitted site
DIGITAL PHOTOGRAPHS
Illinois Environmental Protection Agency
Bureau of Land
LPC # 0170255004
- Cass County
Virginia/Ted Harrison Oil
FOS File
Date: 11/06/03
Time: -1 :50 pro
Direction
: NE
Photo by
: D.C
. Jansen
Photo File Name
:
017025500411062003-003
Comments
: tire sidewalls
discarded along fence line on
Gerald Gill property formerly
owned by Ted Harrison
DIGITAL PHOTOGRAPHS
Illinois Environmental Protection Agency
Bureau of Land
LPC # 0170255004 -
Cass County
Virginia/Ted Harrison Oil
FOS File
Date
: 11/06/03
Time: 1 :53 pm
Direction
: SW
Photo by : D.C
. Jansen
Photo File Name
:
017025500411062003-004
Comments
: wood and metal inside
pit excavated to dispose refuse,
located NE of shed on Gerald Gill
property formerly owned by Ted
Harrison
Date:
11/06/03
Time:
1 :54 pm
Direction: NE
Photo by: D.C
. Jansen
,Photo File Name
:
017025500411062003-005
Comments
: pile of junk metal and
tires located NE of shed on Gerald
Gill property formerly owned by
Ted Harrison
DIGITAL PHOTOGRAPHS
Illinois Environmental Protection Agency
Bureau of Land
LPC # 0170255004 - Cass County
Virginia/Ted Harrison Oil
FOS File
Date: 11/06/03
Time:
1
:58 pro
Direction : NE .
Photo by : D.C. Jansen
Photo File Name
:
017025500411062003-006
Comments : pit excavated to
dispose refuse, and pile of junk
metal and tires depicted in photo #
-005 in background
0 170255004-11062003
. doc
DIGITAL
PHOTOGRAPHS
PROOF OF SERVICE
I hereby certify that I did on the 23' d
day of February 2006, send by U .S
. Mail with postage
thereon fully prepaid, by depositing in a United States Post Office Box a true and correct copy of the
following instrument(s) entitled COMPLAINANT'S
RESPONSE TO RESPONDENT
HARRISON'S MOTION FOR SUMMARY JUDGMENT
To : Stephen F
. Hedinger
Hedinger Law Office
2601 South Fifth Street
Springfield, IL 62703
Mark S . Cochran
Bellatti,
.Barton, Hamill & Cochran, LLC
Suite A
944'Clock,Tower Drive
Springfield, Illinois 62704
and the original and nine (9) true and correct copies of the same foregoing instruments 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
Carol Sudman
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
P .O. Box 19274
Springfield, Illinois 62794-9274
Michelle 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
THIS FILING SUBMITTED ON RECYCLED PAPER
