BEFORE THE POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
ADMINISTRATIVE CITATION
COUNTY OF JACKSON
)
Complainant,
)
)
v
)
AC 06-21
)
Site Code: 0778035009
DAN KIMMEL
)
Respondent.
)
PETITION FOR REVIEW
NOW COMES the firm of Gilbert, Kimmel, Huffman, Prosser & Hewson, Ltd., to
enter its appearance on behalf of the Respondent, Dan Kimmel, and to Petition the
Illinois Pollution Control Board for review of the Administrative Citation of the
Complainant, County of Jackson; and support thereof, states as follows:
1.
Respondent admits the allegations of paragraph 1 of the Complainant’s
Administrative Citation.
2.
Respondent denies the allegations of paragraph 2 of the Complainant’s Citation.
3.
Respondent denies the allegations of paragraph 3 of the Complainant’s Citation, as
written.
4.
Respondent has insufficient information to either admit or deny the allegations of
paragraph 4 of the Complainant’s Citation and therefore denies same and demands
straight proof thereof.
WHEREFORE, Respondent request that this matter be set for hearing before the
Illinois Pollution Control Board, and for such other and further relief as is fair and just.
Webb H. Smith /s/
Webb H. Smith
IARN #06189552
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 10, 2006
PROOF OF SERVICE
The undersigned hereby certifies that a copy of the foregoing was served upon the
attorney(s) of record by enclosing same in an envelope addressed as follows:
State of Illinois Pollution Control Board
Attn: Clerk
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601-3218
Daniel Brenner
Assistant State’s Attorney
Jackson County Courthouse
Murphysboro, IL 62966
with postage fully prepaid, and deposited in a U.S. Post Office mailbox in Carbondale,
Illinois, on the 10
th
day of March, 2006.
_Webb H. Smith /s/
Webb H. Smith
Gilbert, Kimmel, Huffman, Prosser & Hewson, Ltd.
Attorneys at Law
102 Orchard Drive
Carbondale, IL 62901
TEL (618) 457-3547
FAX (618) 457-8017
gkhp@gkhplaw.com
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, MARCH 10, 2006