ILLINOIS POLLUTION CONTROff~ D
RECEIVED
AL
CLERK'S
JUN 042ov
OFFICE
ILLINOIS ENVIRONMENTAL
)
PROTECTION
AGENCY,
STATE OF
ILLINOIS
)
Pollution
Control Board
Complainant,
)
AC 07-53
v.
)
(IEPA No . 58-07-AC)
(Administrative Citation)
RENEE C. LO
)
Respondent.
)
PETITION FOR WITHDRAWAL OF ORDER ENTERED ON MAY 17, 2007
Renee C. Lo, by her attorneys, Miller & Hendren, LLP, for her Motion in the above
cause, states that :
1 .
Her Response to Citation with Entry of Appearance was forwarded on May 10,
2007 as confirmed by the appended true copy .
2.
Said order entered on May 12, 2007 apparently did not consider the timely
response provided.
WHEREFORE, Respondent respectfully requests that the order be vacated and that
consideration be given to the Response provided and submitted a second time for the within
purpose.
t1
C t
Respectfully submi ted by Renee C
. Lo
By Miller & He en, LLP, her attorneys
of Counsel
CERTIFICATE OF SERVIC
n
R i G I N
/ {
f EIOVED
Illinois Pollution Control Board
James
R. Thompson Center
JUN 0 4 2007
100 W . Randolph St
., Suite 11-500
STATE OF
ILLINOIS
Chicago, IL 60601
Pollution Control Board
The undersigned, for and on behalf of Renee C
. Lo, Respondent, hereby certifies that on
this date, the above address was duly provided a copy of her Petition for Withdrawal of Order
Entered May 17, 2007, 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
.
May 30, 2007
Prepared by :
Miller & Hendren, LLP
P.O
. Box 980
Champaign, IL 61824-0980
Tel (217) 352-2171
Fax (217) 352-3839
rle
Prepared by :
Miller & Hendren, LLP
PO Box 980
Champaign, IL 61824-0980
Tel (217) 352-2171
Fax (217) 352-3839
RECEIVEDCLERK'S
OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
JUN 0 4 2007
AL.
glf(uttruIm
ATE OF,,tLLINOISprd
any ~Or~Y
IEPA No. 58-07 AC
S U bn
S/
and
01980250Q5 Champaign County
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
)
v
RENEE C. LO
))
Respondent
)
RESPONSE TO CITATION AND ENTRY OF APPEARANCE
Renee C. Lo, by her attorney, Miller & Hendren, LLP, for her Response to the
Citation herein made, states thee
:
1 .
She has cleared the subject property, and will continue to clean up
debris deposited on her land by trespassers .
2.
Prior to the entry of this citation Respondent had cleared the subject
premises several occasions from unauthorized dumping of garbage, old furniture
and trash on this property .
3.
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 .
4.
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 Citations be vacated on
the grounds that she will expend every effort to clear dumping by trespassers
.
Respectfully submitted,
-K'9G
C
fo
By : Mill
& Hendren, LLP,
He Attorneys
Counsel
BEFORE THE ILLINOIS POLLUTION CONTROL
CLERKS
IMEIVED
OFFICE
ILLINOIS ENVIRONMENTA
JUN 0 4 2007
PROTECTION AGENCY,
LOL('
R
1
GIN A
!
STATE OF ILLINOIS
Pollution Control Board
Complainant,
)
LPC #0198205005 Champaign, Illinois
v .
)
(IEPA No . 58-07-AC)
RENEE C . LO
)
Respondent .
)
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 Renee C. Lo, Respondent, hereby certifies that on
this date, the above addresses were duly provided a copy of her 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 .
May 10, 2007
Prepared by :
Miller & Hendren, LLP
P .O . Box 980
Champaign, IL 61824-0980
Tel (217) 352-2171
Fax (217) 352-3839
