BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN, Attorney General
of
the State of Illinois,
Complainant,
v.
THOMAS P. MATHEWS, an individual,
Respondent.
)
)
)
)
)
)
)
)
)
)
)
No. 07-133
(Enforcement-Water)
NOTICE OF FILING
TO:
James
A.
Campion
Campion, Curran, Dunlop
&
Lamb P.C.
8600 U.S. Highway 12, Suite 201
Crystal Lake, Illionis 60012
PLEASE
TAKE NOTICE that today I have filed with the Office of the Clerk of the
Illinois Pollution Control Board by electronic filing the following First Request for Admission
of
Facts and Genuineness of Documents, a copy of which is attached and hereby served upon you.
Respectfully submitted,
DATE: January
15,2008
BY:
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN,
Attorney General
of the
State
of Illinois
Andrew
tLLr~
Armstrong
Assistant Attorney General
Environmental Bureau
69
W. Washington St., 18th Floor
Chicago, Illinois 60602
312-814-0660
Electronic Filing - Received, Clerk's Office, January 15, 2008
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN, Attorney General
of
the State of Illinois,
Complainant,
v.
THOMAS P. MATHEWS, an individual,
Respondent.
)
)
)
)
)
)
)
)
)
)
)
No.. 07-133
(Enforcement-Water)
COMPLAINANT'S FIRST REQUEST
FOR ADMISSION OF FACTS AND GENUINENESS OF DOCUMENTS
TO RESPONDENT THOMAS
P. MATHEWS
Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA MADIGAN,
Attorney General
of the State of Illinois, pursuant to Sections 101.616 and 101.618 of the
Illinois Pollution Control Board'sProcedural Regulations,
35
Ill.
Adm. Code 101.616
and
101.618, and Illinois Supreme Court Rule 216, hereby serves the following Request
for Admission
of Facts upon Respondent THOMAS P. MATHEWS, to be answered in
writing, under oath, within twenty-eight (28) days after the service
of the request. Failure
to respond to the following requests to admit within twenty-eight (28) days may have
severe consequences. Failure to respond to the following requests will result in all the
facts requested being deemed admitted as true for this proceeding.
If you have any
questions about this procedure, you should contact the hearing officer assigned to this
proceeding or an attorney.
INSTRUCTIONS
1.
With respect to any requested admission which Respondent refuses to
answer because
of a claim of privilege, provide a statement signed by an attorney
representing Respondent setting forth as to each:
1
Electronic Filing - Received, Clerk's Office, January 15, 2008
a.
the nature of the claim of privilege;
b.
the statute, rule,
or decision which is claimed to give rise to
the claim
of privilege;
c.
all facts relied upon in support
of the claim of privilege;
d.
an identification
of all documents related to the claim of
privilege;
e.
an identification
of all persons having knowledge of any
facts related to the claim
of privilege; and
f.
an identification of all events, transactions, or occurrences
related to the claim
of privilege.
2.
For all requested admissions which Respondent denies or which
Respondent can neither admit nor deny, pursuant to Supreme Court Rule 216(c),
Respondent is required to provide Complainant with a sworn statement denying
specifically the matters
of which admission is requested or setting forth in detail the
reasons why Respondent cannot truthfully admit or deny those matters.
DEFINITIONS
1.
Agency.
2.
Facts.
"Illinois EPA" shall mean the Illinois Environmental Protection
"Present" shall mean as
of the filing date of this Request for Admission of
3.
"Respondent" shall mean Thomas P. Mathews.
4.
"The Site" shall encompass all contiguous parcels of property owned by
Respondent at the intersection of Westmoor Drive and East Oakwood Drive in Wonder
Lake, McHenry County, Illinois, including, but not necessarily limited to, parcels
owned
by Respondent with the Permanent Property Index numbers ("PIN numbers") of 09-18-
452-007, -008, -009, -010, -011, -012, -013, -014, -015, -016, -017, -018, -019 and 09-18-
456-001,-002,-003,-004.
5.
All terms not specifically defined herein shall have their logical ordinary
meaning, unless such terms are defined in the Illinois Environmental Protection Act, 415
ILCS 5/1
et seq.,
or the regulations promulgated thereunder, in which case the
appropriate statutory or regulatory definitions shall apply.
FACTS
FACT NO. 1
Admit that soil is solid matter.
RESPONSE:
2
Electronic Filing - Received, Clerk's Office, January 15, 2008
FACT NO. 2
Admit that stone is solid matter.
RESPONSE:
FACT NO. 3
Admit that Respondent has owned the Site from at least April 22, 2005 through
the present.
RESPONSE:
FACT NO. 4
Admit that Respondent has exercised control over the'Site from at least April 22,
2005 through the present.
RESPONSE:
FACT NO. 5
Admit that there were one or more piles of soil, stone, and/or other fill materials
on the Site on April 22, 2005.
RESPONSE:
FACT NO. 6
Admit that there were one or more piles of soil, stone, and/or other fill materials
on the Site from April 22, 2005 to April 27, 2005.
RESPONSE:
3
Electronic Filing - Received, Clerk's Office, January 15, 2008
FACT NO. 7
Admit that there were one or more piles of soil, stone, and/or other fill materials
on the Site on April 27, 2005.
RESPONSE:
FACT NO. 8
Admit that there were one or more piles of soil, stone, and/or other fill materials
on the Site from April 27, 2005 to May 5, 2005.
RESPONSE:
FACT NO. 9
Admit that there were one or more piles of soil, stone, and/or other fill materials
on the Site on May 5, 2005.
RESPONSE:
FACT NO. 10
Admit that there were one or more piles of soil, stone, and/or other fill materials
on the Site from May 5, 2005 to July 28, 2005.
RESPONSE:
FACT NO. 11
Admit that there were one or more piles of soil, stone, and/or other fill materials
on the Site on July 28, 2005.
RESPONSE:
4
Electronic Filing - Received, Clerk's Office, January 15, 2008
FACT NO. 12
Admit that there were one or more piles of soil, stone, and/or other fill materials
on the Site from July 28, 2005 to August 5, 2006.
RESPONSE:
FACT NO. 13
Admit that there were one or more piles of soil, stone, and/or other fill materials
on the Site on August 5, 2006.
RESPONSE:
FACT NO. 14
Admit that there were one or more piles of soil, stone, and/or other fill materials
on the Site from August 5, 2006 to August 30, 2006.
RESPONSE:
FACT NO. 15
Admit that there were one or more piles of soil, stone, and/or other fill materials
on the Site on August 30,2006.
RESPONSE:
FACT NO. 16
Admit that there were one or more piles of soil, stone, and/or other fill materials
on the Site from August 30, ,2006 to May 11, 2007.
RESPONSE:
5
Electronic Filing - Received, Clerk's Office, January 15, 2008
FACT NO. 17
Admit that there is a ditch situated immediately to the south
of the Site.
RESPONSE:
FACT NO. 18
Admit that there is a ditch situated immediately to the south of the Site through
which water flows intermittently.
RESPONSE:
FACT NO. 19
Admit that there is a ditch situated immediately to the south
of the Site through
which water flows intermittently in the direction
of Wonder Lake.
RESPONSE:
FACT NO. 20
Admit that there is a storm ditch on the western edge
of the Site.
RESPONSE:
FACT NO. 21
Admit that there is a storm ditch on the western edge of the Site through which
water flows intermittently.
RESPONSE:
6
Electronic Filing - Received, Clerk's Office, January 15, 2008
--~--------------.
FACT NO. 22
Admit that there is a storm ditch on the western edge
of the Site through which
water flows intermittently in the direction of Wonder Lake.
RESPONSE:
FACT NO. 23
Admit that Exhibit A is a genuine copy
of a letter sent on July 8, 2005 by
Respondent to Beverly Booker of the Illinois EPA.
RESPONSE:
FACT NO. 24
Admit that Exhibit B is a genuine copy
of a letter, and the attachments thereto,
sent by facsimile machine on December 21,2005 by Respondent to Jim Day
of the
Illinois EPA.
RESPONSE:
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN,
Attorney General
of the
State
of Illinois
MATTHEW
J. DUNN, Chief
Environmental Enforcement!
Asbestos Litigation Division
ROSEMARIE CAZEAU, Chief
Environmental Bureau
Assistant Attorney General
7
Electronic Filing - Received, Clerk's Office, January 15, 2008
By:
---~--~----------,
Assistant
Ar;l1::;T~
Attorney General
Environmental Bureau
69 West Washington Street, 18th Floor
Chicago, Illinois 60602
(312) 814-0660
8
Electronic Filing - Received, Clerk's Office, January 15, 2008
EXHIBIT A
Electronic Filing - Received, Clerk's Office, January 15, 2008
T. Po MATHEWS
7314 Hancock Drive
P. O. Box 189
Wonder Lake,
IL 60097
Tel: 815-653-2062
Fax: 815-653-2081
July 8, 2005
Ms. Beverly Booker
Illinois EPA
Bureau of Water
CAS #19
P. O. Box 19276
Springfield, IL 62794-9276
Re:
Violation
Notice W-2005-00313
Facility
ill
ILU000714 - T. P. Mathews Property
Dear Ms. Booker:
Org: Records Unit
cc: Beverly Booker
Jeb
McGhee
Roger Callaway
Tim Kluge
Des Plaines Region, WPC
Agency reply due 08/10/2005
In answer tQ your letter of June 30, 2005 alleging a violation in regards to the possibility
offill infiltrating an unnamed tributary on the adjoining owner'sproperty south of my
property, I
wish to advise as follows:
I have owned the subject property since 1958, and have, from time to time, added fill in
such a
manner and location that would not encroach upon the neighbor's ditch, which is
sometimes dry
in
the summer and frozen
in
the winter.
In leveling any fill,
the equipment will push the fill in a northeasterly direction, which is
away from the neighbor'
sproperty on the south. I have been careful to maintain an area
of foliage consisting of small trees, brush, weeds, and grass between my property and the
tributary.
It
is my belief that this foliage is a sufficient buffer to where a silt fence is not
needed.
The fill area slopes down to the north and away from the south property line. Rain and
surface water is directed away from the tributary.
The property has
been re-graded in the last several weeks, and is scheduled to be finished
in the
next several days, as the contractor'sequipment broke down and needed to be
repaired.
Electronic Filing - Received, Clerk's Office, January 15, 2008
Ms. Beverly Booker
Illinois EPA
July 8, 2005
Page 2
I will continue to see that a buffer
of foliage is maintained between my property and the
property to the south on which the tributary is located.
I might
add that I have been the victim of several incidents of this type of harassment
during the past two years by some
of the local neighbors who oppose my support for
annexation
of this property into the Village of Wonder Lake. My property allowed the
village to go forward in annexing several hundred acres
to the east. The subject property
is part
of the corridor that I made available to the village to proceed with their
annexation.
Please advise
if you wish to have a formal meeting.
Sincerely,
~
.
..':'
.
.
....../ ..
-
,."
"
Thomas P.
--
a ews
TPM/psp
cc:
Michael S. Garretson, Manager
Jeb McGhee
Electronic Filing - Received, Clerk's Office, January 15, 2008
EXHIBITB
Electronic Filing - Received, Clerk's Office, January 15, 2008
DEC-21-2005 14:25
12/21/0~
15:18
DLC LEGAL
COLDWELL/PRIMUS MCHENRY
~
12177829807
T.
P.
Mathews
7314 Hancock Drive
P.O. Box 189
Wonder Lake, IL 60097
Tel: 815653.2062
Fax: 815653.2081
FAX TRANSMISSION COVER SHEET
P.01/07
NO. 942
GJ0:
lJate: DeceJnber21,2005
To: Jim Day, IEPA
Fax: 217..782.9807
Subject:
Notice
ofIntent to Pursue LegalAction
Violation Notice: W.200S.00313
Facility J.D.: ILU000714.T.P. Mathews Property.McHenry County
From: T.P. Mathews
YOU SHOULD RECEIVE
(7)
PAGE(S). IF YOU DO NOT RECEIVE ALL OF THE
PAGES CLEARLY, PLEASE CAll Bi5 653-2062.
Dear Mr. Day:
I am sending you this fax as I tried to reach you several days ago, and again last week,
and was advised that you were out ofthe office at the time. Since I don'tknow ifyou
have the entire file on this matter, I am also attaching the letter I received on August 3,
2005, which rejected my letter of July 8, 2005.
There was no explanation in the August 3
rd
letter concerning what was required to
eliminate the alleged threat ofcontamination, as there never was a threat of
contamination in the first place. Accordingly, I was most interested to know what
someone thought was a threat ofcontamination that would result in a violation.
You will note in my letter of July 8, 2005, that I have owned the property since 1958. and
from time to time have added till
to
the north ofthe neighbor'sproperty at a distance and
in such a manner that none of the fill would reach the neighbor'sproperty, even in the
event ofa lOa year or 500 year rain.
Electronic Filing - Received, Clerk's Office, January 15, 2008
DEC-21-2005 14:25
12/21/05
15:18
DLC LEGAL
COLDWELL/PRIMUS MCHENRY
~
12177829807
P.02/07
NO. 942
Q0:
Mr. Jim Day
IEPA
December 21, 2005
Page
2
To be certain that none ofthe
till,
which is not contaminated, would wash onto the
neighbor'sproperty in any manner whatsoever,
I
regraded my property and planted grass
for a distance of250 feet along the south boundary at a width of 50 feet.
This property is one mile distance from my office, and J drive by it at least twice a day
when going to ond from my home, which is also one mile from the subject site. In the
last
4S
years, I have never observed any soil from my property reaching the sometimes
dry
ditch on "the neighbor's 120 acres.
As I mentioned in my letter of July 8, 2005, I have been subject to a certain amount of
harassment'bythree or four neighbors in the area, who were unhappy with my annexation
ofpart of my property into the Village of Wonder Lake. These people have made
complaints to local authorities about grass being too tall or weeds growing on my
properties. They have even dumped bags of garbage on some of my vacant property, and
then called the McHenry County Health Department that
I
am maintaining a nuisance.
I would like to conclude this matter, and would appreciate knowing ofany evidence that
would support a violation.
Sincerely,
T. P. Mathews
~
Electronic Filing - Received, Clerk's Office, January 15, 2008
DEC-21-2005 14:25
12/21/05
15:18
•
DLC LEGAL
COLDWELL/PRIMUS MCHENRY
~
12177829807
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021
NORTH GRAND AVENUE EAST,
P.O. Box 19276,
SPRINGFIELD, ILLINOIS
62794-9276 _ ( 217) 782-3397
lAMES R. THOMPSON CENTER,
100
WEST RANDOLPH, SUITE
11-300,
CHICAGO,
IL 60601 - (312) 814-6026
ROD R. BLAGOJEVICH, GOVERNOR
DOUGLAS P. SCOTT, DIRECTOR
P.03/07
NO. 942
[;Ie
(217) 782-5544
November 15, 2005
Mr. T. P. Mathews
7314 Hancock Drive
Wonder Lake. Dlinois 60097
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
"'000 1670 0004 1555 8522
Attachment
Re:
Notice ofIntent to Pursue Legal Action
Violation Notice: W-2005-00313
Faoility
.-_.~
J.D.:
-
lLU0007l4-
.._._--_.
T.P. Mathews
'.,
Property
~.~
"'.-
-McHenry
~-""-'
County
.~_
.. _-----..__ ...
_---=~
...
_~_
.. --..
Dear
Mr.
Mathews:
This Notice of Intent to Pursue Legal Action is provided pursuant to Section 31(b) of the IIJinois
Environmental Protection Act ("Act"). 415 ILCS 5/31(b)(2002). The Illinois Environmental Protection
Agency (uJ1linois EPA") is providing this notice because you have failed to adequately respond to a
Violation Notice dated June 30. 2005 and issued by the J1linois EPA within the time frame required by
Section 31 ofthe Act.
.
The Dlinois EPA is providing this notice because it may pursue legal action for the violations of
environmental statutes, regulations and permits specified in Attachment A. The Notice of Intent to
Pursue Legal Action provides the opportunity to schedule a meeting with representatives of the Illinois
EPA
to
attempt to resolve the violations of the Act. regulations and permits specified in Attachment A. If
a meeting is requested. it must be held within thirty (30) days ofreceipt ofthis notice unless an extension
oftime is agreed to by the Illinois EPA.
If you wish to schedule a meeting with representatives of the Dlinois EPA or have any questions, please
contact Jim Day. Assistant Counsel, at (217) 782-5544 within twenty (20) days of your receipt of this
notice.
Sincerely.
(f;;::?~
Associate Counsel
Division ofLegal Counsel
,
~)<
I\lj,'l!
f\1
ROCKFORD - 4302 North Main Street, Rockford, IL 61103 -(815) 9117.7760 .•
DES
PLAINES - 9511 W. Harrison
~
St., Des Plaines. IL 60016 _ (647)294.4000
ELGIN - 595 South
Stlle,
Elgin, IL 60123 - (847) 60B-3131
•
PEORIA - 5415 N. Unlvershy
St.,
Peoria, IL 61614 - (309) 693-5463
BUREAU OF lAND. PeORIA - 7620 N. University St., Peoria, IL 61614 - (309) 693-5462 •
CHAMPAIGN - 2125 South First Street, Champaign, IL 61820 _ (217) 278.5800
SPRINGfIELD - 4500 S.
Sixth
Street
Rd.,
Springfield,
IL 62706 - (217)786.6892 •
COLLINSVILLE - 2009
Mall
Street,
Collinsville,lL 62234 _
(618)
346.5120
Electronic Filing - Received, Clerk's Office, January 15, 2008
DEC-21-2005 14:25
12/21/05
15:18
DLC LEGAL
COLDWELL/PRIMUS MCHENRY
~
12177829807
ATTACHMENT A
P.04/07
NO.942
GJ0,
Deposition of Contaminants
Violation
Date
4/22/2005
RulelReg.:
Violation
Description
Unlawful deposit ofcontaminants upon land thatcaused or threatened to cause
water pollution in Wonder Lake and an unnamed tributary of Wonder Lake in
McHenry County.
Section 12(a), (d) and
(f)
ofthe Act, 415 ILCS 5/12(a), Cd) and (t) (2004).
____:_ •. __ .•
••. _0' •
_•. _."
.~
l..
._"..... -
•
---... - .-.----- ...----
••
_.~
,,' -
-.
~
..-
Electronic Filing - Received, Clerk's Office, January 15, 2008
DEC-21-2005 14:25
12/21/05
15:18
.....
-;;;;;--=-~
......-
--
DLC LEGAL
COLDWELL/PRIMUS MCHENRY
~
12177829807
P.05/07
NO. 942
Li0~
CERTIFIED MAIL # 7004 2510 0001 86470384
RETURN RECEIPT REQUESTED
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
1021 NORTH GRAND AVENUe EAST, P.O. Box
19276,
SPRINGFIELD, ILLINOIS 62794-9276 - ( 217)
782.3397
JAMES R. THOMPSON
CENTER,
100 WEST RANDOLPH,
SUITE
11.300,
CHICAGO,
IL 60601 -
(312)
814-6026
•
2171782.9720
ROD R. BLAGOJEVICH, GOVERNOR
DOUGLAS
P.
SCOTT, DIRECTOR
August 3, 2005
Mr. Thomas P. Mathews
7314 Hancock Drive
P.O. Box 189
Wonder Lake, IL 60097
•••
.0 ••
._.
.--
••• __
_._.- --.-- ••
Re:
Compliance Commitment Rc,jection, Violation Notice W-200S-00313
Facility ID: ILU000714 - T.P. Mathews Property
Dear
Mr.
Mathews:
The Illinois Environmental Protection Agency ("Illinois EPA") rejects the Compliance
Commitment Agreement C'CCA") dated July 8, 2005 proposed by T. P. Mathews. Property
regarding the Violation Notice dated June 30, 2005.
The proposed CCA is rejected because the proposed CCA does not eliminate the threat of
contamination to Waters ofthe State from T. P. Mathews Property.
Because the violations remain the subject of disagreement between the Illinois EPA and T. P.
Mathews Property, this matter will be considered for referral to the Office of the Attorney
General, the State's Attorney, or the United States Environmental Protection Agency for formal
enforcement action and the imposition ofpenalties.
Questions regarding this matter should be directed to Jeb McGhee at 217/782-9720. Written
communications should be directed to Beverly Booker at Illinois Environmental Protection
Agency, Bureau of Water, CAS #19, P.O. Box 19276, Springfield, IL 62794-9276, and all
communications shall include reference to your Violation Notice Number W.2005-00313.
Sincerely,
1t1rc,U
s:
~~iA.
Michael S. Garretson, Manager
Compliance Assurance Section
Bureau of Water
ROCKFORD _ 4302 North Main
Sireel,
Rockford, IL 61103 - (815) 987-7760
0
DEs
PlIo.IN1S -
9511 W.
Harrison
St.,
Des Plaines,
IL 60016 - (647)294-4000
ELGIN _
595 South
State. Elgin,
IL60123 - (847)608.3131 •
PEORIA - 5415 N.
University
St..
Peoria.
IL61614 - (309)693.541>3
----. -.- _._-
~
__ ..._. __ ..
~
•
.,~c_
...
t.c;.<t~."""
rh~mn~ion.1I
(,IA20-12171276.5800
Electronic Filing - Received, Clerk's Office, January 15, 2008
DEC-21-2005 14:25
12/21/05
15:18
July 8, 2005
DLC LEGAL
COLDWELL/PRIMUS MCHENRY
~
12177829807
T.
Po
MATHEWS
7314 Hancock Drive
P. O. Box 189
Wonder Lake, IL 60097
Tel: 815..653.2062
Fax: 815-653-2081
P.06/07
NO. 942
Gl0
Ms. Beverly Booker
Illinois
EPA
Bureau ofWater
CAS #19
P. O. Box 19276
Springfield, IL 62794-9276
Re:
Violation Notice W-200S-00313
Facility 10 ILU000714- T. P. Mathews Property
Dear
Ms. Booker:
In
answer to your letter of June 30, 2005 alleging a violation in regards to the possibility
offill infiltrating
an unnamed tributary on the adjoining owner'sproperty south ofmy
property, I wish to advise as follows:
I have owned the subject property since 1958, and have, from time to time, added fill in
such a mariner and location that would not encroach upon the neighbor'sditch, which is
sometimes dry in the summer and frozen
in
the winter.
In leveling
any
fill, the equipment will push the fill
in
a northeasterly direction, which is
away from the neighbor'sproperty on the south. I have been careful to maintain an area
offoliage consisting ofsmall trees, brush, weeds, and grass between my property and the
tributary.
It
is my belief that this foliage is a sufficient buffer to where a silt fence is not
needed.
The fill area slopes down to the north and away from the south property line. Rain and
surface water is directed away from the tributary.
The property has been re-graded in the last several weeks, and is scheduled to be finished
in the next several days, as the contractor'sequipment broke down and needed to be
repaired.
Electronic Filing - Received, Clerk's Office, January 15, 2008
DEC-21-2005 14:25
12/21/05
15:18
DLC LEGAL
COLDWELL/PRIMUS MCHENRY
~
12177829807
P.07/07
NO. 942
[;)0'
Ms. Beverly Booker
Illinois EPA
July
8, 2005
Page 2
I
will continue to see that
a
buffer offoliage is maintained between
my
property and the
property to the south on which the tributary is located.
I might add that I have been the victim ofseveral incidents ofthis type of harassment
during the past two years by some ofthe local neighbors
who
oppose
my
support for
annexation ofthis property into the Village of Wonder Lake. My property allowed the
village to go.forward in annexing several hundred acres to the east. The subject property
is part ofthe corridor that
I
made available to the village to proceed with their
annexation.
Please advise ifyou wish to have a formal meeting.
Sincerely,
~
_
Thomas
JJ~=
P. Mathews
TPMlpsp
cc:
Michael S. Garretson, Manager
JebMcGhee
Electronic Filing - Received, Clerk's Office, January 15, 2008
CERTIFICATE OF SERVICE
I, ANDREW ARMSTRONG, an Assistant Attorney General, do certify that I caused to
be served this 15th day
of January, 2008, the foregoing Notice of Filing and First Request for
Admission
of Facts and Genuineness of Documents upon the persons listed on said Notice of
Filing by placing true and correct copies of each in an envelope, first class postage prepaid, and
depositing same with the United States Postal Service at 69 West Washington Street, Chicago,
Illinois, at or before the hour
of 5:00 p.m.
ANDREW
~~
ARMSTRONG
Electronic Filing - Received, Clerk's Office, January 15, 2008
