1. BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
      1. MOTION TO DISMISS
    2. ADMINISTRATIVE CITATION
 
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
)
)
)
)
AC 08-06
v.
)
)
)
(IEPA No. 271-07-AC)
SALAM H. NIJME and SHABAN
KARAM NIJME,
)
)
Respondents.
)
)
NOTICE OF FILING
To: Salam H. Nijme & Shaban Karam A. Nijme
312 Largo Drive
Belleville, IL 62221
PLEASE TAKE NOTICE that on this date I electronically filed with the Clerk of the
Pollution Control Board of the State of Illinois the following instrument(s) entitled MOTION TO
DISMISS.
Respectfully Submitted,
_________________________________
Michelle M. Ryan
Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
Dated: December 4, 2007
THIS FILING SUBMITTED ON RECYCLED PAPER
Electronic Filing: Received, Clerk's Office, December 4, 2007
 
1
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
)
)
)
)
AC 08-06
v.
)
)
)
(IEPA No. 271-07-AC)
SALAM H. NIJME and SHABAN
KARAM NIJME,
)
)
Respondents.
)
)
MOTION TO DISMISS
ADMINISTRATIVE CITATION
NOW COMES the Complainant, the Illinois Environmental Protection Agency (“Illinois EPA”),
by and through its attorney, Special Assistant Attorney General Michelle M. Ryan, pursuant to 35 Ill.
Adm. Code 108.402, and respectfully states as follows:
1.
On September 20, 2007, the Illinois EPA issued an Administrative Citation to
Respondents Salam H. Nijme and Shaban Karam Nijme, by certified mail, based on an
inspection conducted on August 22, 2007.
2.
On October 15, 2007, the Administrative Citation was sent back to the Agency from the
Postal Service as unclaimed. Illinois EPA later learned that the Respondents were out of the
country indefinitely.
3.
Because Salam H. Nijme and Shaban Karam Nijme were not timely served within 60
days as required by 415 ILCS 5/31.1(b), this Administrative Citation should be dismissed.
Electronic Filing: Received, Clerk's Office, December 4, 2007
WHEREFORE, the Illinois Environmental Protection Agency requests that the Board dismiss the
pending action against Salam H. Nijme and Shaban Karam Nijme.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Complainant,
DATED: December 4, 2007
_________________________________
Michelle M. Ryan
Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
2
Electronic Filing: Received, Clerk's Office, December 4, 2007
PROOF OF SERVICE
I hereby certify that I did on the 4
th
day of December, 2007, send by U.S. Mail with postage
thereon fully prepaid, by depositing in a United States Post Office Box a true and correct copy of the
following instrument(s) entitled MOTION TO DISMISS ADMINISTRATIVE CITATION
To: Salam H. Nijme & Shaban Karam A. Nijme
312 Largo Drive
Belleville, IL 62221
and an electronic copy of the same foregoing instrument on the same date via electronic filing
To: John Therriault, Acting Clerk
Pollution Control Board
James R. Thompson Center
100 West Randolph Street, Suite 11-500
Chicago, Illinois 60601
_________________________________
Michelle M. Ryan
Assistant Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
(217) 782-5544
Electronic Filing: Received, Clerk's Office, December 4, 2007

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