1. NOTICE OF FILING
  2. CERTIFICATE OF SERVICE
    1. Certificate of Service
  3. PETITION FOR REVIEW TO CONTEST ADMINISTRATIVE CITATION
(printed on recycled paper)
BEFORE THE ILLINOS POLLUTION CONTROL BOARD
CITY OF CHICAGO DEPARTMENT
)
OF ENVIRONMENT
)
) Siting Code 0316615233
Complainant,
)
) AC 2008-017
v.
)
)
CRYSTAL IL 98, L.L.C.
)
)
Respondent.
)
NOTICE OF FILING
TO: Clerk of the Illinois Pollution Control
Board
James R. Thompson Center
100 W. Randolph Street
Suite 11-500
Chicago, Illinois 60601
City of Chicago Dept. of the Environment
Permitting and Enforcement Division
30 N. LaSalle Street
Suite 2500
Chicago, Illinois 60602
PLEASE TAKE NOTICE
that on March 27, 2008, the attached document,
Respondent’s Petition for Review To Contest Administrative Citation, was filed with the
Clerk of the Pollution Control Board.

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CERTIFICATE OF SERVICE
I,
GLENN C. SECHEN
, an attorney, certify that I have served a copy of the
attached documents by regular mail upon the person(s) referenced above at or before
4:00 p.m. on the 27th day of March, 2008.
Glenn C. Sechen
Glenn C. Sechen, Counsel for the Respondent
Glenn C. Sechen
Schain, Burney, Ross & Citron, Ltd.
222 North LaSalle Street
Suite 1910
Chicago, IL 60601-4514
312/ 332-0200
F:\GCS\Crystal\Filed Pleadings\Notice of Filing Applicant's Petition for Review 9-27-06.doc
Electronic Filing - Received, Clerk's Office, March 27, 2008
(Printed on Recycled Paper)
BEFORE THE ILLINOS POLLUTION CONTROL BOARD
CITY OF CHICAGO DEPARTMENT
)
OF ENVIRONMENT
)
) Siting Code 0316615233
Complainant,
)
) AC 2008-017
v.
)
)
CRYSTAL IL 98, L.L.C.
)
)
Respondent.
)
APPEARANCE
Glenn C. Sechen, James R. Griffin and M. Hope Whitfield hereby enter their
appearance on behalf of the Respondent, Crystal IL 98, L.L.C.
Glenn C. Sechen
Attorney for the Applicant
James Griffin
Attorney for the Applicant
M. Hope Whitfield
Certificate of Service
The undersigned hereby certifies that on the 27
th
day of March, 2008, a copy of the
above was served upon:
Clerk of the Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph Street
Suite 11-500
Chicago, Illinois 60601
City of Chicago Dept. of the Environment
Permitting and Enforcement Division
30 N. LaSalle Street
Suite 2500
Chicago, Illinois 60602
By: Glenn C. Sechen
Attorney for the Applicant
F:\GCS\Crystal\Filed Pleadings\Appearance.doc
Electronic Filing - Received, Clerk's Office, March 27, 2008
(printed on recycled paper)
BEFORE THE ILLINOS POLLUTION CONTROL BOARD
CITY OF CHICAGO DEPARTMENT
)
OF ENVIRONMENT
)
) Siting Code 0316615233
Complainant,
)
) AC 2008-017
v.
)
)
CRYSTAL IL 98, L.L.C.
)
)
Respondent.
)

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PETITION FOR REVIEW TO CONTEST ADMINISTRATIVE CITATION
Now comes the Respondent, Crystal IL 98 LLC and files this petition to
contest the administrative citation issued by the City of Chicago, and in support
thereof states as follows:
1.
Respondent is within the 35 day time period described in 35 IAC
108.204(b) and Section 31.1(d) of the Act.
2.
Respondent contests the issuance of the Administrative Citations
for one or more of the following reasons:
a)
The alleged violations are untimely and improperly alleged;
b)
The AC Recipient did not cause or allow the alleged violations;
c)
The AC was not timely filed or properly served;
d)
The alleged violation was the result of uncontrollable
circumstances;
e)
The City of Chicago exceeded its authority regarding the
allegations set forth;
f)
The penalty sought is excessive, duplicative and inappropriate, and
is otherwise improper and not in accordance with the law.
Electronic Filing - Received, Clerk's Office, March 27, 2008
(printed on recycled paper)
Wherefore, for the above and foregoing reasons, Respondent, CRYSTAL
IL 98, L.L.C., prays that the Illinois Pollution Control Board dismiss Complainant’s
Administrative Citation and for such further relieve as it deems just and equitable.
Respectfully Submitted,
Glenn C. Sechen
Glenn C. Sechen
Glenn C. Sechen
James R. Griffin
M. Hope Whitfield
Schain, Burney, Ross & Citron, Ltd.
Attorneys for Plaintiff
222 North LaSalle Street, 19
th
Floor
Chicago, IL 60601
312-332-0200
F:\GCS\Crystal\Filed Pleadings\PETITION FOR REVIEW TO CONTEST ADMINISTRATIVE CITATION.doc
Electronic Filing - Received, Clerk's Office, March 27, 2008

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