ILLINOIS POLLUTION CONTROL BOARD
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
v.
HAROLD GRAVES,
Respondent.
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AC 06-22
(Administrative Citation)
MOTION TO WITHDRAW PETITION TO
CONTEST THE ADMINISTRATIVE CITATION
NOW COMES
Respondent, HAROLD GRAVES, by his attorneys, Brown, Hay
&
Stephens, LLP, and hereby submits his Motion to Withdraw Petition to Contest Administrative
Citation, and in support thereof states
as follows:
1.
On January 27, 2006, an Administrative Citation was served upon the
Respondent.
2.
On March 3, 2006, a Petition to Contest the Administrative Citation was filed by
the Respondent.
3.
As the Respondent has paid the fines associated with the Administrative Citation,
Respondent is filing this Motion in order to withdraw his Petition to Contest the Administrative
Citation and to seek a dismissal
of this Administrative Citation.
4.
At any time prior to the entry of a decision by the Illinois Pollution Control
Board, an Administrative Citation recipient may withdraw his Petition to Contest. 35 Ill. Admin.
Code 108.208.
Electronic Filing, Received, Clerk's Office, July 20, 2007
5.
If an Administrative Citation recipient withdraws his Petition to Contest prior to
hearing, the Illinois Pollution Control Board will consider the Administrative Citation non-
contested.
35 Ill. Admin. Code 108.406.
6.
As Respondent has paid the fines associated with this Administrative Citation,
pursuant
to 35 Ill. Admin. Code 108.500, Respondent seeks dismissal of this Administrative
Citation.
WHEREFORE, HAROLD GRAVES respectfully requests that the Illinois Pollution
Control Board grant his Motion to Withdraw Petition to Contest Administrative Citation and
dismiss the Administrative Citation.
HAROLD GRAVES, Respondent
By:
lsi
Claire A. Manning
One
of His Attorneys
BROWN, HAY
&
STEPHENS, LLP
Claire A. Manning
Registration No.
3124724
Charles Y. Davis
Registration No.
6286010
205
S. Fifth Street, Suite 700
P.O. Box 2459
Springfield, IL 62705
(217) 544-8491
Fax: (217) 544-9609
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Electronic Filing, Received, Clerk's Office, July 20, 2007
CERTIFICATE OF SERVICE
The undersigned certifies that a copy ofthe foregoing instrument was served upon:
Michelle M. Ryan
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
John
T. Therriault
Illinois Pollution Control Board
James
R. Thompson Center
100
W. Randolph Street, Suite 11-500
Chicago, IL 60601
by enclosing the same in an envelope addressed to such party at the above address, with postage
fully prepaid, and
by depositing said envelope into a U.S. Post Office mailbox in Springfield,
Illinois, at 5:00 p.m., on this 20th day
of July, 2007.
Is/Claire
A.
Manning
July 19, 2007\klm\F:\CHUCK DAVIS\CLIENTSIHARJOY\MOTION TO WITHDRAW PETITION TO CONTEST THE AC.DOC
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Electronic Filing, Received, Clerk's Office, July 20, 2007