March 16, 2006

Illinois Environmental Protection

)

Agency,

)

Complainant,

)

vs .

(IEPA

G

a

and

)

Stev

h ,

)

Responde is

)

0

TO DISMISS

Respondents move to dismiss due to the following relevant facts-

PETITION FOR REVIEW

1 . Property is not an open dump .

2. Respondent (s) do not operate

a

facility at Route 40 and Elm Street

in Greenville, IL. It is vacant land .

3. Kendall Couch has never made a complete inspection of said property

.

Response to

false

accusations of purported violations .

1. Respondent (s) have not caused or allowed an open dumping of waste

.

2. Respondent (s) did not cause or allow open burning

.

3. Respondent (s) have the right to store, on a temporary basis, certain clean

construction debris

.

Respondent (s) now respectfully request dismissal of administrative citation .

D

cc: Senator Frank Watson

cc: Representative Ron Stephens

l

ul-~

.459-05-AC)

IV

CLERK'S OFFICE

2 0 2006

STATE OF ILLINOIS

Pollution Control Board