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STG/KDW/pmm/0386971 .01
Firm No. 14503
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PETITION FOR REVIEW
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY,
Complainant,
)
PR
v.
)
(IEPA No . 128-06-PR)
LAKE WILDWIND PARK, L.L.C.,
)
Defendants .
)
NOTICE OF FILING
TO : Michelle Ryan
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O
. Box 19276
Springfield, Illinois 62794-9276
YOU ARE HEREBY NOTIFIED that on July 27, 2006, there was filed with Clerk of the
Illinois Pollution Board, RESPONDENT LAKE
WILDWIND PARK, L.L.C.'s
APPEARANCE
and PETITION FOR REVIEW, a copy of which is attached and hereby
served upon you.
LAKE WILDWIND PARK, L .L.C.
Stephen T
. Grossmark
Kelly D. Waller
Tressler, Soderstrom, Maloney & Priess, LLP
Sears Tower, 22nd Floor
233 South Wacker Drive
Chicago, Illinois 60606-6399
(312) 627-4000
Attorneys for Respondent-LAKE WILDWIND PARK, L.L.C.
7485-'
CLEftS
IOFFICEV
E D
JUL 2 7 2006
PollutionOControlBoard
 
CERTIFICATE OF SERVICE
The undersigned, being first duly sworn on oath, deposes and says that he/she served the
foregoing Notice of Filing, Appearance and Petition for Review therein by mailing copies to the
parties listed at the addresses indicated above and by mailing same in the U
.S. Mail at 233 South
Wacker Drive, Chicago, Illinois on the 27th day of July, 2006
.
SUBSCRIBED AND SWORN TO BEFORE ME
this 27th day of July, 2006 .
rn.
NOTARY PUBLIC
MOW Seal
Phyllie M Michersr
Nobly Public State of Illinois
My Commlulon
Expires
06/14/07
 
STG/KDW/pmm/0386973 .01
Firm No . 14503
7485-1-17-722
BEFORE THE ILLINOIS
PETITION
POLLUTION
FOR REVIEWCONTROL
BOARD
RECEIVED
CLERK'S OFFICE
ILLINOIS ENVIRONMENTAL PROTECTION
)
JUL 2 7 2006
AGENCY,
)
Pollution
STATE OF
Control
ILLINOISBoard
Complainant,
)
PR
/
v .
)
(IEPA No. 128-06-PR)
LAKE WILDWIND PARK, L .L.C.,
)
Defendants.
)
APPEARANCE
The undersigned, as attorney, enters the appearance of the Respondent, LAKE
WILD WIND PARK, L.L.C
.
LAKE WILDWIND PARK, L .L.C
.
Stephen T
. Grossmark
Kelly D. Waller
Tressler, Soderstrom, Maloney & Priess, LLP
Sears Tower, 22nd Floor
233 South Wacker Drive
Chicago, Illinois 60606-6399
(312) 627-4000
Attorneys for Respondent -
LAKE WILDWIND PARK, L .L.C.
I certify that a copy of the within instrument was served on all parties who have appeared and
have not heretofore been found by the Court to be in default for failure to plead .
Kelly D
.
r, Attorney for Respondent,
LAKE
IND PARK, L.L.C.
 
PETITION FOR REVIEW
JURISDICTION
This Petition for Review is submitted pursuant to Section 31 .1 of the Illinois
Environmental Protection Act ("Act"), 415 ILCS 5/31 .1 .
FACTS
1 .
Lake Wildwind Park, L .L.C. ("Respondent" or "Lake Wildwind") admits that it is
the present owner and operator of a facility located at 120 Hollyhock Lane, Woodford County,
Illinois. Lake Wildwind neither admits nor denies the remaining allegations contained in
Paragraph 1 and affirmatively states that it does not possess sufficient knowledge to form a belief
as to the truth or falsity of said allegations and demands strict proof thereof
2 .
Lake Wildwind denies that said facility is an open dump operating without an
Illinois Environmental Protection Agency Permit
. Lake Wildwind neither admits nor denies the
remaining allegations contained in Paragraph 2 and affirmatively states that it does not possess
sufficient knowledge to form a belief as to the truth or falsity of said allegations and demands
strict proof thereof.
3 .
Lake Wildwind admits that it has operated a mobile home park at the facility . It
neither admits nor denies the remaining allegations of Paragraph 3 and affirmatively states that it
STG/KDW/pmm/0386790.01
Firm No. 14503
7485-1-17-722
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PETITION FOR REVIEW
RECEIVED
CLERK'S OFFICE
AGENCY,ILLINOIS
ENVIRONMENTAL PROTECTION )
JUL Z / 2006
)
Complainant,
)
STATE OF ILLINOIS
Pollution Control Boaro
v.
)
PR
LAKE WILDWIND PARK, L .L.C.
) (IEPA No . 128-06-PR)
l,A
p
' I /S
Respondent.
)
 
does not possess sufficient knowledge to form a belief as to the truth or falsity of said allegations
and demands strict proof thereof .
4. Lake Wildwind admits that on May 4, 2006, Jeff Port of the Illinois
Environmental Protection Agency's ("IEPA") Peoria Regional Office inspected the above-
described facility.
Lake Wildwind neither admits nor denies the remaining allegations
of
Paragraph 4 and affirmatively states that it does not possess sufficient knowledge to form a belief
as to the truth or falsity of said allegations and demands strict proof thereof
.
VIOLATIONS
Lake Wildwind denies each and every allegation contained in the introduction to this
section of the citation and Paragraphs 1 and 2, including for the reason that it did not cause or
allow any alleged violation .
CIVIL PENALTY
Lake Wildwind denies any and all allegations of this section including that a civil penalty
or any costs should be imposed against Lake Wildwind .
WHEREFORE the Respondent, LAKE WILDWIND PARK, L.L.C., petitions for review
of the matters set out in and raised by IEPA's Administrative Citation and requests that the
Illinois Pollution Control Board find that it has not been in violation of the Act as alleged in the
Administrative Citation, reverse the finding of the violations alleged therein and enter judgment
in its favor and against Complainant .
Respectfully submitted,
LAKE WILDWIND PARK, L.L.C
.
 
Stephen T . Grossmark
Kelly D . Waller
Tressler, Soderstrom, Maloney & Priess, LLP
Sears Tower, 22nd Floor
233 South Wacker Drive
Chicago, Illinois 60606-6399
(312) 627-4000
Attorneys for Respondent-LAKE WILDWIND PARK, L .L.C.

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