STATE OF ILLINOIS
Pollution Control Board
AC: 2006-039
AC: 2006-040
AC: 2006-04 I
AC: 2007-025
Site Code:03 I6485 I
03
Respondents.
Complainant,
v.
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARIt~~~bX:,~P
CITY OF CHICAGO DEPARTMENT
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AUG 052007
OF ENVIRONMENT,
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SPEEDY GONZALEZ LANDSCAPING,
INC., et al.
NOTICE OF FILING
TO: Mr. Bradley P. Halloran
Illinois Pollution Control Board
100 West Randolph Street, Suite 11-500
Chicago, Illinois 6060 I
Ms. Jennifer
A.
Burke, Senior Counsel
City
of Chicago, Dept. of Environment
30 North La Salle Street, 9
th
Floor
Chicago, Illinois 60602
PLEASE TAKE NOTICE that we have this day filed with the Clerk
ofthe Illinois Pollution
Control Board, Respondent's Renewed
Mo' to Consolidate and Motion to Dismiss Actions.
Dated at Chicago, Illinois, this 6
th
day of Au u ,2007.
L------
Y J. LEVINE, P.c.
Atto ey r Respondents
Speedy onzalez Landscaping, Inc.,
Jose Gonzalez, and
1601- I759 East
l30
th
Street, LLC.
Jeffrey
J. Levine, P.C. #17295
20 North Clark Street, Suite 800
Chicago, Illinois 60602
(312) 372-4600
PROOF OF SERVICE
The undersigned, being first duly sworn on oath, deposes and says that he served a copy of
the Notice together with the above mentione
ocuments to the person to whom said Notice is
directed by hand delivery, this 6
th
day of Augus
007.
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
R E eEl VE
0
CLERK'S OFFICE
CITY OF CHICAGO DEPARTMENT
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OF ENVIRONMENT,
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Complainant,
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)
v.
)
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SPEEDY GONZALEZ LANDSCAPING,
)
INC., et al.
)
Respondents.
)
Site Code:03164851
03
AC: 2006-039
AC: 2006-040
AC: 2006-041
AC: 2007-025
AUG 0 [j 2007
STATE OF ILLINOiS
Pollution Control Board
RENEWED MOTION TO CONSOLIDATE ACTIONS
Now come Respondents, Speedy Gonzalez Landscaping, Inc., Jose Gonzalez, and 1601-1759
East 130" Street, LLC, by and through their attorney, Jeffrey J. Levine, P.C., and for their Renewed
Motion to Consolidate, state and assert as follows:
1. On or about December 20, 2006, Respondents sought to consolidate these matters for
hearing for purposes ofjudicial economy. Said motion was denied.
2. With the instant motion, Respondents, Speedy Gonzalez Landscaping, Inc., Jose Gonzalez,
and 1601-1759 East 130
th
Street, LLC, seek to consolidate cases 2006-039, 2006-040 and 2006-041.
3. The facts
in each case are the same. The allegations arose out of claims made at the same
property, largely
on the same date and involved the testimony of the same witnesses. The only
difference
in the cases are the identity of the Respondents. However, those Respondents are
interconnected. Jose Gonzalez owns both Speedy Gonzalez Landscaping, Inc., and 1601-1759 East
Both
Street, LLC. All Respondents are represented by the same counsel.
4. No differences exist in the proof presented by the Department of Environment between
the three respondents except their individual name.
5. During the individual hearings, the parties stipulated to allow the testimony of witnesses
in one action be used in other actions. Case 2007-25, involve a later date at the site.
6. Respondents seek to raise issues regarding the competency of witnesses, discovery
violations and outrageous government conduct before the Pollution Control Board and,
ifrequired,
on appeal
of any adverse decision by the Board.
7. The veracity oftestimony given by Complainant'switnesses is called into question when
the testimony is compared in the different actions. See: Motion
to Dismiss Complaints.
8. The multiple claims alleged, many ofthem baseless, and the failure to perform an adequate
investigation, were threatened by the inspector after he sought to "work out" prior allegations. These
are only revealed when the testimony is compared from each action. Consolidation
ofthese actions
would reveal to the Pollution Control Board, the full scope
of the scheme.
9. There is no valid reason not to consolidate these matters.
Wherefore, for the above and forgoing reasons, Respondent Speedy Gonzalez Landscaping,
Inc., prays that cases 2006-039, 2006-040 and 2006-041, be consolidated, that Case No. 2007-25,
also be consolidated with the others and for such further relief as is just and equitable.
ec ully Submitted,
effrey.
ine, P.c.
orne for Respondents
Sp
onzalez Landscaping, Inc.,
Jose Gonzalez, and
1601-1759 East 130
th
Street, LLC.
Dated: August
6, 2006
Jeffrey
J. Levine, P.C. #17295
20 North Clark Street, Suite 800
Chicago, Illinois 60602
(312)
372-4600
AUG 062007
STATE OF ILLINOIS
AC: 2006-039
Pollution Control Board
AC: 2006-040
AC: 2006-041
AC: 2007-025
Site Code:03164851 03
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Respondents.
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Complainant,
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
RECEIVED
CLERK'S OFFICE
v.
CITY OF CHICAGO DEPARTMENT
OF ENVIRONMENT,
SPEEDY GONZALEZ LANDSCAPING,
INC., et al.
MOTION TO DISMISS ACTIONS
Now come Respondents, Speedy Gonzalez Landscaping, Inc., Jose Gonzalez, and 1601-1759
East BOth Street, LLC, by and through their attorney, Jeffrey J. Levine, P.C., and for their Motion
to Dismiss Actions for Discovery Sanctions and Outrageous Governmental Conduct, state and assert
as follows:
I. The above captioned matters involve four related sets
of violations wherein the City of
Chicago, Department ofEnvironment has alleged that Respondents have committed numerous acts
in violation
of Section 21(p) of the Illinois Environmental Protection Act. With the instant motion,
Respondents seek dismissal
of the actions (and/or other relief), for discovery sanctions and
governmental misconduct. Respondents finally claim that false allegations, selective prosecution,
the failure to conduct an adequate investigation, selective responses in deposition testimony, the
failure to provide subpoenaed documents and false testimony
of witnesses result in a denial of
Respondents constitutional rights to Procedural Due Process.
2. Respondents hereby incorporate by reference their Post Hearing Briefs in the above
captioned matters as though set out herein in their entirety.
3. Inspector Rafael Macial knew Respondent Jose Gonzales growing up in his neighborhood.
When he had previously sought to money from Gonzalez by offering to "work out" claimed
violations, Macial promised to retaliate stating: "You'llpay for this." Macial, on March 22, 2006,
wrote numerous false allegations and ticket persons and entities who did not own or control the
property. This evidence indicated that Macial attempted to extort Mr. Gonzalez.
False Allegations
4. Raphael Macial, the inspector has testified that on occasions he has discussed "working
out" claims with alleged violators rather than issuing violations. See: AC 06-39, May 9, 2007, Tr.
126-28. Respondent'switness testified that the inspector Rafael Maciel had previously asked him
for money and when Gonzalez refused, Macial promised to retaliate stating: "You'll pay for
this."See:
AC 06-39, May 9, 2007, Tr. 181-82.
5. Mr. Macial testified that he has told certain individuals that he could help them avoid
citations. May
9, 2007, Tr. 126. He would say to individuals "Help me help you avoid a citation."
May
9, 2007, Tr. 127. He denied asking for bribes stating that based upon his credibility, he was
pretty sure that he had never taken a bribe. See: May
9, 2007, Tr. 124-27. Mr. Gonzalez testified that
he interpreted Mr. Macial'sprior offer to
"work it out" as a request for a bribe. May 9, 2007, Tr. 180-
83.
6. At the site Macial promised to ticket Mr. Gonzalez's landscaping company, which had
nothing to do with the property investigated, telling him:
".. '\'11see to it that you never get work from
the CTA again. See: AC 06-39, May
9, 2007, Tr. 204. Maciel ticketed Mr. Gonzalez personally, as
well
as his landscaping company. He told Gonzalez "...we're going to write you a ticket for
everything 1 could write you a ticket on." May
9, 2007, Tr. 193.
7. Similar to the complaint charging Speedy Gonzalez Landscaping Inc.(AC 2006-39), the
property in
AC 2006-40 was not owned in Mr. Gonzalez's name. However, throughout his
testimony, Mr. Macial repeatedly identified Respondent Jose Gonzalez as a property owner. See:
AC 06-40, May
9,2007, Tr. 35, 39-40, 64, 87, 100, 125-27. The fact that Mr. Gonzalez is not the
property owner,
is conceded at page 1, of the City'sPost-Hearing Brief in AC 2006-40.
7. The alIeged violations also contained baseless alIegations regarding securing the property,
salt unloading operations, ACM or asbestos, waste next
to residential homes and oil flowing into the
sewer. AC 06-39, May
9.2007, Tr. 68, 129-32. Macial contended that these charges were put into
his investigative report because Respondent Speedy Gonzalez Landscaping, Inc., committed the
additional offenses
CAC 06-39, May 9. 2007, Tr. 130), but he had no evidence that the offenses
occurred. AC 06-39, May 9. 2007, Tr. 68, 129-32. These alIeJations are listed as attachment
"B"
in Complainant'sInspection Reports. See: Complainant's Exhibits. Mr. Maciel concluded that he
had "no idea" why the violations were charged when there was no basis for them. AC 06-39, May
9.2007, Tr. 132.
Selective Prosecution
8. During the course ofthe limited investigation, Inspectors Macial and Chris Antonopoulos
discovered the entities responsible for a large amount
of debris on the site. Both investigators
testified regarding an agreement entered into regarding what has been deemed the "suspect CTA
waste" at the property in question. Mr. Antonopoulos described how the agreement was between Mr.
Gonzalez, Paschen Construction, E. King and a representative
ofthe CTA. The agreement calIed for
CTA waste material from the Brown Line construction, to be stored in roll-off truck boxes over the
weekend at the site in question. AC 2006-39, May 17, 2007, Tr. 31; May 9, 2007, Tr. 44, 59-60.
9. When the CID landfilI opened, the rolI-offboxes would be removed from the property and
brought to CID. AC 2006-39, May 17,2007, Tr. 31. Complainant's investigation revealed that,
either
E. King or Paschen Construction didn'tfollow the agreement to store the CTA waste in the
roll-off trucks.
It
was that entity who caused the CTA waste to be deposited at the property in
question. May 17,2007, Tr. 49.
10. The investigators collected manifests (See: Respondents Exhibit A), at the site which
indicate that the waste material came from the CTA at 567 West Lake Street. 2006 AC-39, May
9,
2007. Tr. 33-6. E. King was the hauler on the manifests. 2006 AC-39,May 9, 2007, Tr. 83-4. Mr.
Antonopoulos testified that Mr. Maciel had the hazardous waste manifests on the day of the
investigation. 2006 AC-39, May 17,2007, Tr. 44-5.
11. No tickets were issued to the CTA, Paschen Construction or E. King Trucking. The
investigators later allowed those entities to conclude their clean-up. AC 06-39, May
9, 2007, Tr. 204.
Rather than ticket all entities involved, Complainant selectively chose to ticket non-owner
Respondents Speedy Gonzalez Landscaping, Inc., (2006 AC-39) and Jose R.Gonzalez. (2006 AC-
40), making good on Macial's promise to Gonzalez
"...to write you a ticket for everything 1 could
write you a ticket on." 2006 AC 06-39, May
9, 2007, Tr. 193. The charging of Respondents and the
failure to even investigate the other entities that actually committed the dumping
of the debris,
demonstrates the selective and vindictive nature
of these prosecutions.
Failure to Conduct an Adequate Investigation
12. Complainant'sinvestigation revealed that, either E. King or Paschen Construction didn't
follow the agreement to store the waste in the roll-offtrucks.
It
was that entity who caused the CTA
waste to be deposited at the property in question. 2006 AC-40, May 17, 2007, Tr. 49. However,
neither the manifests nor any
of the other documents observed that day regarding other individuals
at the site are included in the investigation report. 2006 AC-40, May
9, 2007. Tr. 35-8.
13. No mention was made in the investigation report that Elaine King was present on site
discussing the agreement. 2006
ACAO,
May 9, 2007, Tr. 44-9. Macial testified that he selectively
excluded information in his investigation report, and that he had been taught to conduct
investigations in this manner. 2006 AC-40, May
9, 2007, Tr. 48-52.
14. Mr. Antonopoulos testified that an inspector'sjob is to determine where the waste came
from. 2006 AC-40, May 17,2007, Tr.
20. Antonopoulos said an investigation would have revealed
the entity that didn'tfollow the agreement and dumped the CTA debris. 2006 AC-40, May
17, 2007,
Tr. 33. He agreed that a ticket cannot be written without
proofofa violation. 2006 AC-40, May 17,
2007, Tr. 43. He testified that a more through investigation should have been performed because the
Department
of Environment didn't have all the facts. He further testified that he did not feel
comfortable charging individuals and entities when an adequate investigation had not been
performed. He believed that he would be remiss in his duties
if he had performed the type of
investigation performed in the instant case. 2006 AC-40, May 17,2007, Tr. 24-5.
15. Even Mr. Macial agreed that the investigation was not thorough. 2006 AC-40, May 9,
2007, Tr. 78. Macial testified that he just assumed that Mr. Gonzalez "was doing something illegal."
2006 AC-40, May
9, 2007, Tr. 83. Mr. Antonopoulos concluded that "...it was easier to ticket Mr.
Gonzalez than conduct an adequate investigation
..." 2006 AC-40, May 17,2007, Tr. 95. Finally,
Mr. Macial testified that his ability to read peoples credibility was part
ofhis investigation. 2006 AC-
39, May 9,2007, Tr. 117.
Selective Responses in Deposition Testimony
16. Contempt for the legal process is demonstrated by Mr. Maciel'sreference to his claimed
training
by the FBI regarding his ability to tell if someone was telling a lie. Mr. Maciel testified that
he had not disclosed this alleged training in his deposition testimony because
"he only gave
information that he thought was pertinent".
AC 06-39, Tr. 118. Complainants therefore, admitted
to failing to give truthful deposition testimony and only providing the deposition testimony which
they believed was "pertinent". Respondents were therefore precluded an opportunity to investigate
the class that Maciel claims to have taken regarding his ability to determine how to tell
if an
individual was telling the truth.
Failure to Provide Subpoenaed Documents
17. The investigator in this case, Rafael Maciel, testified that certain information was
transcribed into "field notes". Counsel for Complainant was not informed
ofthe existence of these
notes.
AC 06-39, May 9, 2007, Tr. 58-9. Mr. Maciel testified that Edward Collins "took the
information down".
18. On May 1,2007, Mr. Maciel, Mr. Collins and all other witnesses were subpoenaed to the
hearing. The Subpoenas also sought "any and all documents related" to the cases. See: May 1,2007,
Subpoenas, attached hereto and incorporated herein
as Group Exhibit A. These subpoenas are
indicative
of the subpoenas issued in all ofthe above captioned cases. The "field notes" referenced
by Mr. Maciel were never produced in discovery or pursuant to the subpoenas. Nor were the business
cards collected from individuals at the site ever produced pursuant to the subpoena. AC 06-39, May
9, 2007, Tr. 53-4. Complainants therefore selectively withheld documents sought pursuant to
subpoena.
False Testimony
of Witness
19. Mr. Maciel maintained at the hearing that the trucks on site were dumping material. 2006
AC-39, May
9. 2007, R. 42, 72, 74, 78. He later testified that he assumed this. 2006 AC-39, May
9,2007, Tr. 137. Mr. Macial initially testified that he could not determine whether trucks were
loading or unloading at the site. 2006 AC-39, May
9. 2007, Tr. 16. He testified that he concluded
that another entity's trucks were dumping at the site. 2006 AC-39, May
9. 2007, Tr. 72, 74. This
conclusion is contrary to his report, (2006 AC-39, May
9. 2007, Tr. 43, 46-7), and his prior
deposition testimony wherein he testified that the trucks were loading. 2006 AC-39, May 9, 2007,
Tr.74-6.
20. Maciel testified that he would impound a truck
if it was dumping but did not impound
the
E. King trucks on the lot. 2006 AC-39, May 9, 2007, Tr. 48. Neither Macial or anyone else saw
trucks dumping. 2006 AC-39,
May 9,2007, Tr. 81. He agreed that he testified both at the hearing
and
at his deposition that, rather than loads being dumped, the material was being removed and that
the trucks were loading. 2006 AC-39, May 9, 2007, Tr. 138. He then testified that a worker told him
that
"We're bringing it here."2006 AC-39, May 9, 2007, Tr.
141,
line 6. He then testified "I don't
recall ifhe did say that or not." 2006 AC-39, May 9, 2007, Tr.
141,
line 12.
21. Mr. Antonopoulos testified that an
E. King employee opened the gate and an E. King
truck was loaded up with debris and waste. 2006 AC-40, May
17,2007, Tr. 19-20. Mr. Macial's
testimony that the trucks were dumping was false.
It
is contradicted by his own testimony, his signed
investigation report and Mr. Antonopoulos' testimony.
21. Mr. Macial cannot be regarded as competent to testify as a witness.
If there was any
question
of Mr. Maciel'sfalse testimony, one need only review his testimony with reference to his
claimed training by the FBI regarding his ability to tell
if someone was telling a lie. AC 06-40, May
9, 2007, Tr. 116-24. Maciel could not give any specifics related to the alleged class that he attended.
He didn'trecall the name
ofthe course, the name ofthe teacher, the address ofthe course, and when
asked
if the check he paid with was a personal check, he stated that he paid for the course with a
money order.
22. Macial'stestimony changed from case to case on the same day. For instance in Case No.
AC 2006-39, Mr. Macial testified as follows:
Q.
Are vague answers an indication that someone'snot telling the truth, sir?
A.
No, that's not an indication. (AC 2006-39, May 9, 2007, Tr. 121-22).
However, in Case No. AC 2006-40, Macial gave the following testimony:
Q.
Is lack
of specificity an indicator as to whether or not someone is telling the
truth or not?
A.
That could be one, yes.
(AC 2006-39, May 9, 2007, Tr. 57).
23. Review
of his testimony regarding his alleged FBI training reveals the depths to which
Macial will go to support false testimony. However, Respondents could not prove that the testimony
was false because Maciel had not disclosed the information when asked in his deposition testimony.
Respondents were therefore prejudiced in presenting their defense to the trier
of fact.
Wherefore, for all the above and forgoing reasons, Respondents Speedy Gonzalez
Landscaping, Inc., Jose Gonzalez, and 1601-1759 East 130
th
Street, LLC, pray that their Motion to
Dismiss Actions for Discovery Sanctions and Outrageous Governmental Conduct be granted and for
such further relief as is
just and equitable.
J frey .
At
ey
~
Respondents
Spee
onzalez Landscaping, Inc.,
Jose Gonzalez, and
1601-1759 East
130'h Street, LLC.
Dated: August
6, 2006
Jeffrey J. Levine, P.C. #17295
20 North Clark Street, Suite 800
Chicago, Illinois 60602
(312) 372-4600
Before the Illinois Pollution Control Board
City of Chicago,
Department of Envtronment
ComplainantlPetitioner,
v.
Speedy Gonzalez landscaping.' Inc ..
Respondent.
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PCB AC 06-39
RECEIVED
CLERK'S OFFICE
MAY
0 12007
STATE OF ILLINOIS.
Pollution Control Board
SUB?OENA DUCES TECUM
TO: Mr. Chris Aotonopoulos
City of Chicago. Department of Environment
c/o Jennifer A. Burke
30 N. La,;Salle Str"et. Suite 900
Chicago.IL 60602
Pursuant to Section 5(e) ofthe Environmental Protection Act (415 ILCS5/5(e)
(2002)and 35 UL Ad@.Code WI, Subpart F, you are ordered to attend and give
testimony at the hearing/deposition in the above-captioned matter at
--7-~-~
8,09
a.m.on _.JM..
a.,Y-'--.29....
~~~
__
"7~~_2007
Suite 11":"500,lOO-WeFi:t
l?aDdC)lpb:~"T"eetJ
Cbi.c-~g~J
Illinois .606nf
You are also ordered to brii;lg with youdocuments relevant to the matter under
consideration and designated herein,
~y
and all documents related to the
above captioned matter.
,.at
Depa.....
hne.~t
of Envtronment
Speedy r...onz.aJez I,andscap1Qg." Inc.
Before the Illinois Pollution Control Board
City.of Chicago.
ComplainantJPetitioher,
v.
R.espondent.
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RECEIVED
. CLERK'S OFFICE.
MAY
01 2007
STATE OF ILLINOIS
Pollution Control Board
PCBAC 06-'-39
\
SUBPOENA DUCES TECUM
TO: Mr. Stan1ey Kaeh1ar
City of Chicago, Department of Environment
c/o Jennifer A. Burke
30 ,N.LaSSalle Street, Suite 900
Chicago, .IL 60602 ....
..,'
Pursuan,! to Section 5(e) oftheEnvironmental Protection Act (415 ILCS
515(e)
(2002»and 35:ULAd
lJ1
,Code 101,Subp(lrt F, you are ordere4 to attendandgiYe
'testimony.atthe
hearing/deposition in the above-captioned matter at
_~~~_~
8 :09
a.m.on _.",M",aLl/y':c...
:>.9~. ~~~--,'-~'-.,,-~~_
2007
.,.at
YO,u area.lso orderedtobril:lgwith'youdocumentsrelevant to the
matter~der
.
.',
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' -
.
ponsideration and designated herein, . any and all documents related to the
apo..
~e
captio:ned
ro.:at~er
.'
Before the Illinois Pollution Control Board'
City of Chicago.
Dep~.rtme,~t
of, Envi'ronment
ComplainantlPetitioner,
v.
Speedy Gonz.alez
I.:lDdscap1~g,·
Inc.
R.espondent
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PCBAC 06-39
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RECEIVED
. CLERK'S OFFice
MAY 01 2007
STATE OF ILLINOIS
Pollution Control Board
. SUBJ>OENA DUCES TECUM
TO:
M::.
Rafael Maciel
City of Chicago. Department of.Environment
c/o Jennifer A. Burke
30.N
.La~'Salle
Street. Suite 900
Chicago .IL 60602 ,..
..'
. .
Pursuant to Secpion 5(e) of.theEnvironmental Protection Act (4'15 ILCS
515(e)
(2002)) and 35l,l1. Adp:i..Cod,e IOl,Subp;uiF,
Y9U
are orderw to attend and
giYe
testimony at the heatingldepositionin the above-captioned matter at _.
_'+--_'+--'+--~
8:09
'il,
im.on
_·.:J:M",a~y',,"··
:L9~. --'----'--~--c----'--~~-
20
07
You are also
Qrdered.tobri~g
with'you documents relevant to ,the
matter~der
.
COl1s~deration
imddesignated herein, mu and all do"nnients related to the
apc;>ve captioned matter.
.,at
Respondent.
Dep~.rtment
of.EDvfrOnment
ComplainantlPetitioner,
Before the
Illinois Pollution Control Board
RECEIVED
CLERK'S OFFICE
MAY
0'2007
OF ILLINOIS
p~~~T;n
control Board
PCB
AG 06-40
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v.
City of Chicago,
lose. R
C..QDZa.1 ,:Z
SUBPOENA
.-
DUCES
-
TECUM
.
TO: Mr. Rafae'l Maciel
City of Chicago, Department of Environment
c/o Jennifer A. Burke
30 N.. La
~alle
St."eet, Suite 900
Chica.go, IL 60I!02,
( . ....
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'co".
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C 5/'5( )
l'lU'SUa'rltto :)ec(iOn 5 e) oftheEnvlronmentalrrotection Act 415
II..
S ..e
(2002)) and 35 Jll. AdgJ.,Code to1,Subpart F, yo!) are ordered to attend and ,give
'testimony
at the hearingldepositionin the above-captioned matter at _.
_~~,--~~
,at'
YB,ullie.also -ordered.tpbri'rlgwithypudocmnentsrelevailt to .the
mafter,~der
.' ,
·¢bils~derationanddesi.griatedh.ereiil;·.
llIly'and an dm;uments related totbe
.' a!>9ve captioned matter •.
Before the Illinois Pollution Control Board
City Of Chicago,
Dep?l??tme_~t
of, Envtronment
ComplaiIi.ant/PetitioIi.er,
v.
.lose R
C...onza.1 ez
Respondent.
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PCB
AC
06-40
RECEIVED
CLERK'S OFFICE
MAY 0 I 2007
STATE OF ILLINOIS
Pollution Control Board
SUBPOENA DUCES
TEcUM
TO: Mr. Stanley Kaehlar
City of Chicago. Department of Environment
c/o Jennifer A. Burke
30 II.. La Salle S l:re.et. Suite 900
Chi<;llgo. IL 60602. .. . ... ..
.....
C.
I.
()
l'ursullAt to i::ibction 5(e) of the Envrronmental Protection Act ('tISIL S5 5 e
(2QO~))and35W.Adm,Cod.e
lDl,Subp!UiF,¥ou are ord.emd to attend and iPVf\ .
testimony at the hearing/deposition
in
the above-captioned matter at _.-'-c---c...-----""-
'."0"":"
Yo.u arell1so ,qrderedto brijlgwith you documents relevant to the
matter~der
~011SWeration
anddesignatedherein;. any and aU docnments related ':0 the
ahove captioned matter.
Res!"ondent.
Depa.~tment
of. Envtronmpnt
Complainant/Petitioner,
Before the lllinois Pollution Control Board
RECEIVED
CLERK'S OFFICE .
MAY
01 2007
STATE OF ILLINOIS
Pollution Control Board
PCB
AC 06-40
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v.
City of Chicago,
loseR fdIDzaJpZ
SUBPOENA DUCES TECUM
TO: Mr. Chris Antonopoulos
City of Chicago, Department of Environment
c/o Jennifer A. Burke
30 N. La Salle
Str~et,
Suite 900
Chi~go,
IL
60602.
. .....
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I (
pursuant to
~ection
5(e) oftheEnvlronmental ProtectIOn Act (415 ILCS5 5 e)
(ZOOz»and
35111.Ad
m
.Code 101, Subpart
F,
you are ordered to attend and give
testirnonY'at
the hearingldepositioninthe above-captioned matter at __
~~_~
8:OQ
a.m.on _.",M...
a",Yc_.
.2-9~, -,-~
~_~_2007
,at
.. S1l1-te
]]';'5QO,
-lOO-,Wes,t
Randolpb:'Strpet. Ch1CQgo; 11]in01s .6060l
You are lliso orderedt9bring with you documents relevant to the matter under
cOllsideration and designated
herein, anyand all documents related to the
above captioned matter.
Before the minois Pollution Control Board
City ,of Chicago, '
)
)
Depa.rtme.nt of,
EDvtronment,
.
)
)
)
)
Complainant/Petitioner,
) ,
)
~
)
)
1601~1759
East,130thStreet,
L.L.C.~
)
)
)
)
)
Respondent.
)
PCB
l\C 06-41
RECEIVED
CLERK'S OFf':'CE
MAY
0 12007
STATE OF ILLINOIS
Pollution Control Board
SU13POENA DUCI.}S TECUM
TO: Mr. Stanley K'lehlaT
City of Chicago, Department of Environment
c/o Jennifer A. Burke
30 N. La Salle Street, Suite 900
Chicago, :IL ,60692 ' ",', ",
,"
'
Pursuant to Section 5{e) oftheEnVlronmental ProtectIOn Act (415 ILCS
515(
e)
(200:L))and
~5~ILA4nl.Code
101,SubP<U1F, you are ordere4 to attend and give
testimony at the hearingldepositioninthe above-captioned matter at
-~-c--~-~
8 :OJ}a,,m.on
_'c.r;M..
a.,Y:e-'
.;z9~, ---'-~~_~-,'-~~_
2007
¥o,u are also orderedtpbril,lgwitli ypudocuments relevant to the matter
~der
,ilt '
COllsideration 'anddesigriatedherllin; any 'IUd aU documents related to the
ap9ve captioned matter. '
Before the lllinois Pollution Control Board
City, of Chicago,
)
)
Depa.rhne.~t
of _F:!'vfrOmnpnt.
.
)
)
)
)
ComplairtantiPetitioner,
) ,
)
~
)
)
1601-1759 EastI30th'Street, ,L.t-C ••)
)
)
)
)
)
Respondent.
)
PCB
AC
06-41
RECEIVED
CLERK'S OFFICE
MAY 0 12007
STATE OF ILLINOIS
Pollution Control Board
SUI,lPOENA DUCl::;S
TECUM
TO:Mr. Rafael Maciel
City of Chicago, Department of Environment
c/o Jennifer A. Burke
30
N. LaSalle Street. Suite 900
Chicago. tL ,60602 ',',' ,.
,"
Pursua,nt to Sectio1l5{e) ofthe Environmental ProtectIOn Act (415 ILCS 5/5(e)
(2QO;2.»and 35:(11. AdID,Code lOl,Subp<Ui P, you are
orden~4
to attend and give
:testil11onyat the heatingld,eposit}<m in the above-captioned matter at __
~~~~
"
'.
8 :00 'a.
m
.
on
_'",M..
"..,yc..'
.29~. -'-~~~~~~~_
2007
¥o,U are also orderedtobri'tlgwith
,
.
you documents relevant to ,the matter under
consi.deration mdrlesignatedherein, any and aU documents related to the
"above captioned maHer. '
,at
Before the Illinois Pollution Control Board
City of Chicago,
)
)
Department of. Envtronment.
)
)
)
)
ComplainantlPetitiorter,
)
)
v.
)
)
1601-1759 East.130thStreet.
L.L.C.~
)
)
)
)
)
Respondent.
)
PCB
AC 06-41
RECEIVED
CLERK'S OFFICE
MAY
0 12007
STATE OF ILLINOIS
Pollution Control Board
SUBPOENA DUCES
TBcUM
TO: Mr. Chris Antonopoulos
City of Chicago. Department of Environment
c/o Jennifer A. Burke
30
N. La Salle Street, Suite 900
Chicago.IL606P2
...."
..."."
Pursuant to Section See) of.theEnvlronmental Protection Act (415 !LCS5/5(e)
(2002))an!l35
:Ul.
A@LCode IOJ,Subpart F, You are ordered to attend and give
testimony
at the hearing/deposition in the above-captioned matter at ----'..,.-0----'..,.--'---'-
8 :Op
a .ill.on
_".:J:M..
a'J!Y'--:t9~,
---'..,.---'..,.~~~_~~_
2007
Sui.t;e ] 1 . 500.
'100,-W¢~t
~8Ddillpb-'StT'eet.
ChiN'gO; I.Jlin()1s . 6060r;
¥o.u are also Qrdere(hohringWith youdocuments relevant to the matter under
coils~deration
and designated herl':in, any and aU documents related to the
al>ove captioned matter•.
, at
Before the Illinois Pollution Control Board
City ,of Chicago.
)
)
Depf';r;hne~t
of Envi'ronment
)
)
)
)
ComplainantlPetitioner,
)
)
v.
)
)
1601-1759 EastlJOth
Stre~t.
r.I..C. )
)
)
)
)
)
Respondent.
)
PCB
AC-0'i-25
RECEIVED
CLERK'S OFFiCE
MAY
01 2007
STATE OFILLINOIS
Pollution control Board
, SUBPOENA DUCES
TECUM
TO:Mr. Chris Antonopoulos
City of Chicago. Department of 'Enviroment
, c/o Jennifer A. Burke
30N. LaSalle
Str~et:.
Suite 900
Ch1pill!~ul\11,~10
~Jlc~Po~
See) ofthe Environmental Protection Act (41S
ILCSSiS(e)
(200;2») and
35~I1.Adm,Code
101, SubpllrtF, you are ordered to attend and give'
testimony at the hearingidepositionin the above-captioned matter at
-,--'--,----e,..-,-~
8 iQll 'a,..
tn.on
_.",M",a",y':.c"
,,-9~. -'-~
__
~'-:-c~~_2007
.,a£
Yo.u areil).so qrderedtobril,lg\vith"youdocuments relevant to the matter under
~onsi.deration
and designated herem; 81\Y 311d all docwnel1tS related to the
ap9ve captioned matter; .
Before the Illinois Pollution Control Board
City ,of Chicago,
)
)
Dep~;r;tme,~t
of, Envi'reinment
)
)
)
)
Complainant/Petitioner,
)
)
~
)
)
1601-1759 llast,l1Otb Stre'1t. I. I..C. )
)
)
)
)
)
Respondent.
)
PCB AC-0}l-25
\
RECEIVED
CLERK'S
OFFICE'
MAY
01 2007
STATE OF ILLINOIS
pollution Control Board
SUBPOENA DUCES TECUM
TO: Mr. Stanley Kaehlar
City of Chicago, Department of Environment
c/o Jennifer A. Burke
30N. LaSalle Street, Suite 900
Chil:ago, ,'IL
,1i060i
('" 'f"
'p'.
(" II..
S
I"
( )
t'UTsuAAt to Section 5 e) 0 -the EnVironmental , rotechon Act 415. C5 5 e
(200;l))
and 35ijl. AcipJ..Code 101, Submlrt F, You are ordere<;l to attend and give
tlilstimonyat
the hearingldepositioninthe above-captioned matter at
-~----c.--,-~
,'at
Yo.u are also Qrdered to
brillg
With youdocuments relevant to the
matter,~nder
:coiIsideration anddes$latedherein, "AY'and aU doc.nn"llts related to the
apove captioned matter. '
-~----~---
--- -------
Before the illinois Pollution Control Board
City of Chicago.
)
)
Depa,rtrne'?t of,
Envtronment
)
)
)
)
ComplairtantiPetitioner,
)
)
v.
)
)
1601-1759 East BOth Street, I..T.• C. )
)
)
)
)
)
Respondent.
)
SUBPOENA DUCES TECUM
TO: Mr. Rafael Maciel
City of Chicago. Department of Enviromnent
c/o Jennifer A. Burke
30N. La,Salle Street. Suite 900
,
Chi,P~~~~1o
S'C:>C~Pot
5(e) oftheEnvirorunental Protection Act (4'15 ILCS
515(e)
(2002-)) and 35:ij).AdI.rt,Code 101,Subp;mF, you are ordered to attend,andgivc
testirncmyat
the hearing/deposition
in
the above-captioned matter at
~~~~~~
8:op -a.:
m
.
On
_'",M..
a."Y-e-'
;z9~. ---'-~~-"-~'-c-~~_2007
,at
Y'ouarealso,Qrdered.tphri'llgWithyoudocumentsrelevant to the
matter~nder
l;.oils~deration
imddesignatedher,ein; "Ay and all documents related to the
ahove captioned matter:
