Prepared by :
Miller & Hendren, LLP
P .O. Box 980
Champaign, IL 61824-0980
Tel (217) 352-2171
Fax (217) 352-3839
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
MAY 1
4
2007
Pollution
STATE OF
Control
ILLINOISBoard
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
>
Complainant,
LPC #0198205006
V .
)
(I EPA No. 1 13-07-AC) Champaign County, IL.
ADOLPH M . LO
)
Respondent .
)
RESPONSE TO CITATION AND ENTRY OF APPEARANCE
Adolf M
. Lo, by his attorneys, Miller & Hendren, LLP, for his
Response to the Citation
herein made, states that :
I .
He has cleared the subject property, and will continue to clean up debris deposited
on his land by others
.
2 .
Prior to the entry of this Citation, Respondent had cleared
the subject premise on
at least two occasions from unauthorized dumping on his property
.
3 .
The residence property was then broken into, with windows
smashed, plumbing
and fixtures removed, leaving the house in deplorable condition,
and with rejects and
garbage items strewn on the land .
4 .
The condition reviewed by the environmental inspection
was caused by unknown
parties on several occasions, with an effort each time by
the Respondent to clear the
property .
5 .
Assurance is hereby given that Respondent will timely act
each time to correct
known violations of environmental regulations by those
trespassers .
WHEREFORE, Respondent respectfully requests that the Citation
be vacated on the
grounds that he will expend every effort to clear dumping
by trespassers
.
Respectfully submitted,
ADMINISTRATIVE CITATION
RECEIVEDCLERK'S
OFFICE
Adolph
By
Hendren,LLP, His Attorneys
~-'-
unsel
RECEIVEDCLERK'S
OFFICE
May 10, 2007
Prepared by :
Miller & Hendren, LLP
P.O. Box 980
Champaign, IL 61824-0980
Tel (217) 352-2171
Fax (217) 352-3839
CERTIFICATE OF SERVICE OF
:
A .
Notice of Filing of Response to Citation ;
B
.
Notice of Entry of Appearance thereto .
To:
Clerk of Illinois Pollution Control Bard
State of Illinois Center
100 West Randolph, Suite 115
Chicago, IL 60601
and to
Illinois Environmental Agency's Division
Legal Counsel
1021 North Grand East
P .O. Box 19276
Springfield, IL 62794-9276
The undersigned, for and on behalf of Adolf M
. Lo, Respondent, hereby certifies that on
this date, the above addresses were duly provided a copy of his Response to the above entitled
Citation, by forwarding copies thereof to each by depositing the same in the U
.S. Mail Service in
Champaign, Illinois, properly addressed, and with appropriate postage affixed
.
/,
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
MAY 1 4 2007
ILLINOIS ENVIRONMENTAL
)
Pollution
STATE OF
Control
ILLINOIS
Board
PROTECTION AGENCY,
)
Complainant,
)
LPC #0198205006
v.
)
ADOLPH M
. LO
)
Respondent .
)
(IEPA No . 113-07-AC)
