IN THE MATTER BEFORE
THE
ILLINOIS POLLUTION CONTROL BOARD
KYLE NASH,
Complainant,
V.
LOUIS
JIMENEZ,
Respondent.
)
)
)
)
)
PCB 07-97
)
(Citizens Enforcement — Noise)
)
)
)
)
)
ECEVED
CLERK’S
OFFICE
DEC
115
2008
STATE
OF
ILUNOIS
POjItj
Control
Board
To:
Clerk
illinois Poflutton Control Board
100
West
Randolph Street
Suite
11-500
Chicago, illinois 60601
Attorney for
Respondent
James
M. Knox
121
W.
Chestnut, #3104
Chicago,
Illinois
60610
Bradley P.
Halloran
Hearing
Officer
James R.
Thompson Center,
Suite 11-500
100
West
Randolph
Street
Chicago, illinois 60601
PLEASE TAKE
NOTICE
that I
have
today
filed with
the Office of
the
Clerk
of the
Illinois
Pollution
Control
Board
a
Reply to Respondents’ Motion to Consolidate and
Reply to Respondents’ Reply to Complainant’s Response to Respondent’s
Motion to
Dismiss
and
AFFIDAVIT
OF
SERVICE,
a
copy
of
which
is herewith
served
üpóñ
the asgné4Hearing Officer,
the Resnondent
and
the
Re rnndent ‘
4ttoizne.
Dated:
December 5, 2008
1630 W 33rd
Place
Chicago,
Illinois
60608-6202
773,744.1954
Respectfully
sub
itted
by,
KyI.e Nash.
Pro Sc
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Now
comes Complainant, KYLE
NASH, pro
se,
replying
to
the
Respondents’
Motion to Consolidate.
C,
I respectfully
request
that the
Board
deny this Motion.
The reasons for my
request
Include, but are not limited
to reasons outlined below:
1. Each of the
original
and amended Complaints were Intentionally filed
by me
as
separate and distinct
cases
at the Initial
date
of filing. Each
Respondent has
been served
IndMdually
for that and all further matters, even after jointly
retaining
an
attorney.
2. New
developments in each Complaint have arisen even since I filed my Reply
to
Respondents Motion
to
Dismiss. These developments
are specific
to
each
Respondent
and are related
to
each
case,
separate and distinct
from one
another. (These
developments are fully outlined In my Reply to the Respondents’
Reply
to
the
Complainants Reply
to
the Respondent’s
Motion
to
Dismiss, which
is
being simultaneously filed with this
Reply
to
the Respondents’
Motion
to
ConsolIdate.)
S.
j.
3.
Paragraph
2 of
the Respondents’ Motion
to Consolidate
claims
that the
Complaints
are identical with
respect to
the Issues Involved.
In tact,
two (2) completely separate and distinct
sets of details relating
to wind chIme
pollution were stated In the original
and the amended
Complaints
that were filed
against
each Respondent
4. Paragraph 1 of the Respondents
Motion
to Consolidate claims
that all the
homes
and
properties more
than similar, It not
identical.. My house Is
a single-
family home, the Respondents’ are two-fiats.
There
also
exist
differences In the
front
yards, backyards,
and
gangways
on the properties regarding
access,
enclosures,
vegetation, and
the existence or not of air-conditioning
units,
garages, and
assorted
paraphernalia, both small and large, on
the properties.
5.
Two (2) separate and distinct time lengths exist during whIch
each
Respondent
has lived In this
neighborhood. (I have lived here the longest and
have
a
consistent hIstory of investment In this neighborhood, espedally in
keeping the
neighborhood
as
quiet
and
safe
as
possible. I have addressed
these
Issues and
more, both lndMdually
and
in cooperation with the local CAPS
community
police program.
a
6.
Two (2) separate
and distinct
time lengths exist
during
which
each
Respondent has lived
In their
respective homes next
to mine.
7.
Two
(2)
separate
and
distinct
personalities
define each
Respondent These
major
differences have
come
to
bear on each
situation in different
ways.
8.
Two
(2)
separate
and
distinct relationships
and
interactions
existed in the
past
between each Respondent
and
me, prior
to
my
filing an original
Complaint
against each.
9.
Two
(2)
separate
and
distinct
relationships
and
interactions
currentiy
exist
between
each
Respondent
and
me.
10.
Two (2) separate
and
distinct relationships
and
interactions
will exist in
the
future
between
each
Respondent
and me
following
an
IPCB ruling.
11. Two (2) separate
and
distinct family
constellations
occupy
each
Respondent’s
home.
These
have directly
and
indirectly impacted
each situation
before,
during, and
also
will
following
the
Board’s
ruling.
12. Two (2) separate
and distinct
past histories exist regarding
the
presence or
absence of
noise pollution emanating
from each
Respondent’s property
prior to
my
filing the
original Complaint
against each.
13. Two (2) separate and distinct past
histories exist regarding
types and levels
of
noise
pollution emanating from
each Respondent’s property
prior to my filing
the original Complaint against each.
14. Two (2)
separate and distinct
past histories exist regarding
attempts to
resolve the
noise pollution
emanating from each Respondent’s
property prior
to
my
filing the original Complaint against each.
15. Paragraph 2
of
the Respondents’ Motion to Consolidate claims that the
time
frame in each
case,
which necessitated my filing each Complaint are identical.
In
fact,
these two (2)
cases
are not identical with respect to time frame
as
clearly
stated
in the documents related to each case.
16. Two
(2) separate and distinct lengths of time existed following the filing of
each Complaint
after
which each Respondent finally removed her and his wind
chimes
from sight, not sound.
17. Two (2)
separate and distinct
personal reactions
have existed toward
me
by
each
Respondent since the initial
Complaint was filed.
18. Only one
(1)
Respondent, JIMENEZ, has
been trained in the law
through Law
Enforcement.
To the
best of my knowledge,
SOKOLWSKI has not.
19. Only one
(1)
Respondent, JIMENEZ, has
been employed (for
many years)
by
the City of
Chicago
as a professional Law Enforcement
Officer. To the
best
of
my
knowledge,
SOKOLWSKI
has not.
20.
Only
one (1) Respondent, JIMENEZ, has engaged in
formally documented
retaliatory
behavior toward me following
the initial filing of the Complaint against
him. (See
City of Chicago attachments to Complainant’s Reply to the
Respondents’ Motion to Dismiss). SOKOLWSKI has not.
21. Paragraph
2 of the Respondents’ Motion to Consolidate requests that “.. . in
the interest
of judicial economy...” the two cases be
consolidated. As stated
before
in previous
documents, I tried in every way possible over
a
very
extensive
period of time to
resolve these separate matters with each
Respondent
individually
prior to
filing
a
Complaint.
If each Respondent were concerned
about judicial
economy, during
that time,
each would
have
chosen to resolve
their matter
individually with
me personally
or
through
mediation
(each individually
declined
to participate). Even
after
each
Complaint was filed, each
Respondent
on their own
could have chosen
to
initiate
attempts to
resolve the
matter with
me privately or
through mediation.
Each did
not.
Furthermore, if SOKOLOWSKI
was seriously
interested in
judicial economy
and
seriously interested in resolving
the matter
at
all, she would have
responded in
some manner to my recent letter
of November 12,
2008, suggesting that
a
meeting take
place
to discuss these
matters.
(See
Paragraph
3 and Attachment
1 to Complainant’s Reply to the
Respondents’ Reply
to
the
Complainant’s Reply
to the
Respondent’s Motion
to Dismiss: SOKOLOWSKI.)
Furthermore,
JIMENEZ,
as a Chicago Law Enforcement officer,
has
“... sworn
to
follow and uphold the law and of whom it
is expected that” of whom it is
expected
that his “...on and
off-duty conduct reflects both the highest standards
of police service and personal responsibility” (12/5/08 City of Chicago Police website)
If he was
seriously interested in judicial economy
and seriously
interested in
resolving the
matter
at
all, he would
not simply
offer assurance that he is
a “...
law
abiding citizen” who could
be
fully trusted not to pollute any longer, his
actions
would support that.
In fact, as
recently
as
November
14 and 15, 2008,
he again blatantly
disregarded
the law.
(See
Paragraph
6
and
Attachments 1-4 to
Complainant’s Reply
to the
Respondents’ Reply to
the
Complainant’s
Reply to the
Respondent’s Motion
to
Dismiss: JIMENEZ.)
I am the only person in this matter who
has had any interest
in judicial
economy.
I have tried in every conceivable
way to resolve
each matter before having
to file
and for the entire time after filing.
Representing my
case
pro
Se, I have
nevertheless tried to engage in
these proceedings correctly
and
as
best I can.
I
have completed all documents, submitted
evidence verifying allegations,
met
every, participated in all Status Hearings except
one, and have addressed
every
matter in each Complaint in
a
thorough and
serious manner.
22.
Paragraph 2 of the Respondents’ Motion
to Consolidate states that the
Complaints
“... should
be consolidated to
ensure
fairness to all.”
There
is
nothing about
any thing
that
has happened over the
past
four (4) years (both
informally
and then formally after each Complaint was filed) related to this issue
that
has been fair to me. The amount
of stress, time, energy, effort, monetary
outlay, and
lost wages that I have had to
endure in this matter have been
extensive and
serious.
Throughout
almost all of the past four
(4) years, each Respondent
individually
has
failed to take
the matter seriously, either
informally or formally.
Each
Respondent,
although
having
unlimited
time
and opportunity
to
resolve
their matter
with
me
prior
to the
Complaint
being filed
against
them, chose
not
to.
Each
Respondent,
although
having
unlimited
time
and opportunity
to resolve
their matter
with
me
since
the Complaint
being
filed
against them,
chose
not
to.
Each
Respondent
individually
chose
not to submit
Responses/Replies
required
of them
by
the
IPCB nor
followed
all
IPCB
deadlines.
Each Respondent
individually
did
not
participate
in
all
IPCB phone
hearings.
The
only choice
showing
some
seriousness
was
their decision
to jointly
retain
an
attorney
and
was
exercised
only near
the end of
the proceedings.
It was
not
an
option
either
chose
individually
or together
during the
extensive
period
of time
that
passed
before.
At no point
during
he
extensive
time period
that has
passed
since
the
Complaints
were
filed did either
Respondent
file any
Motion to
Consolidate.
Had
that actually
been
important
to
them
in any
way,
they
would
have
taken
it
seriously
and
chosen to
do so
before
now
Based
upon
the aforementioned,
I
request
that the
Board deny
the
Respondents’
Motion
to
Consolidate.
Respectfully,
Kyle
Nash
Pro
Se
Now
comes
Complainant,
KYLE NASH,
pro
Se,
filing
a
Reply
to
Respondents’
Reply to Complainant’s
Response
to
Respondent’s Motion
to
Dismiss.
I respectfully request
that the Board
rule in my favor.
Because
I am engaged in
these legal
proceedings,
pro
se, I may
be completely
wrong
about
this,
but
I
question the validity
of the
Respondents’
Reply
to
Complainant’s
Response
to Respondent’s
Motion
to Dismiss
because it was
filed
as
consolidated reply.
At the time
it was filed,
there had not yet
been
any
ruling
by
the Board on the
Respondents’
Motion to Consolidate.
Therefore,
I would
expect that
until the
Board
has
made
a
decision, that
nothing
would change.
This is especially true
given that
my Reply to Respondents’
Motion
to
Consolidate
requests that
the
Board deny
the Motion.
As
a
result,
I am
filing
Complainant’s
Reply to
Respondents’ Reply
to
Complainant’s
Response
to
Respondent’s Motion
to
Dismiss in the
previous way.
Please note that
many, if not most,
of the points raised
in the Respondents’
Reply
to
Complainant’s
Response
to
Respondent’s
Motion
to
Dismiss have
already
been fully addressed
in my Complainant’s
Response
to Respondent’s
Motion
to
Dismiss
and other documents
I have previously
filed.
Paragraph 1 of the Respondents’
Reply
to Complainant’s
Response
to
Respondent’s Motion
to
Dismiss states:
1.
Both
above captioned
proceedings were filed
by
complainant, Kyle Nash, seeking
relief
from environmental
noise pollution said
to emanate from adjacent two
flat
residential
apartment buildings, or
from the respective
yards or
porch
areas thereto, which are owned by the
respective respondents herein,
and are
located
on
either side of complainant’s own nearly identical
two flat apartment
building,
each of the
three located mid-block, in
a
City
of Chicago near
Southside residential neighborhood; the
three architecturally nearly identical buildings were
constructed
so as to
stand
some six feet apart, allowing only narrow passageways between
buildings
on either side of complainant’s
own building, with small open yards at
the rear of
each.
The homes and properties are not similar or
not identical, relative
to
the
Complaint. My house is
a
single-family
home; the Respondent’s
is a
two-flat.
There also exist differences in the front
yards, backyards, and gangways
on the
properties
regarding
access, enclosures, vegetation,
and the existence or not
of
air-conditioning units, garages, and assorted paraphernalia, both small
and large,
on the
properties.
These facts
are
relevant
to issues cited in my response to
Paragraph 2 below.
Paragraph
2 of the
Respondents’ Reply
to
Complainant’s Response
to
Respondent’s
Motion
to Dismiss
states:
2.
In response to
complainant’s initial pleadings herein, Respondents
filed
separate
Motions to Dismiss which were filed on or
about August, 2008, asserting that the noise making
devices identified by complainant, viz wind
chimes, have been removed from both of their
respective properties more than
one year
ago,
facts
which are
readily
admitted by complainant;
further,
both respondents have
advised their
attorney
that they do not intend nor will either
of
them ever install similar devices on
their respective
properties,
front or
back, in
the future,
and
this
fact has been made known to
the complainant at Status conferences held
herein
by
Bradley
P. Halloran, Hearing Officer, with an offer
by respondents through their attorney to enter into an
agreed
order to memorialize this
agreement to preserve the
status
quo between the
parties hereto
and
purchase
peace.
Again,
as
stated during several
Status hearings and other
documents that
have
been filed, the wind chimes were removed
from sight, however I have
continued
to
hear chimes on and off
ever since. In addition, the Respondent
has
continued
to demonstrate
the very
reasons why I have no confidence that any such
agreement
would
be
followed.
(See
response
to
Paragraph
6 and Attachments
1-
4)
Paragraph
3
of the
Respondents’ Reply
to
Complainant’s Response
to
Respondent’s
Motion to
Dismiss
states:
3.
In
spite of
these voluntary
efforts on the part of respondents
to
ameliorate this
situation, complainant has now filed
a RESPONSE
to the
Motion
to
Dismiss, introducing
for the
first time new extraneous
matters, which are not
referable
to
noise pollution, basing these matters
on unsubstantiated hearsay
statements
which
are unsupported,
irrelevant and
immaterial, with still
no
mention of noise standards
purportedly
violated.
The Respondent “voluntarily’
removed
the wind chimes
only after several
years
during which it was fully
known that
a
problem
existed and was
in violation of
Illinois
law. The wind
chimes were removed
from sight only
after the Respondent
was served with the Complaint and,
even then, not immediately
Matters included in my Reply to Respondent’s
Motion to Dismiss were
addressed
in direct
response
to the suggestion that I acquiesce
to an “...agreed order
to
memorialize this agreement to preserve the
status
quo
between the parties
hereto and purchase
peace.”
My agreeing
to anything like that would
be
solely
founded
upon my confidence
in the honestly, character, and integrity
of the
Respondent in following through. I have not have
any confidence and,
as a
result of recent further developments related to the
case
and cited in my
response to
Paragraph
6
and Attachments 1
-4, I now
have
even less.
If the Respondent
was
seriously
interested resolving
the matter in
any
by
agreement I
would have
expected,
because he is
a citizen or more
importantly
because
he is
a
Law
Enforcement Officer,
that no
additional examples
of his
disregarding the laws would
ever have
occurred again. In
fact, the
Respondent
very recently disregarded
the law again.
Details are outlined
in my
response to
Paragraph 6
and
Attachments 1-4
I have fully met the burden of
proof required
by the applicable law in
this case.
All
necessary evidence was
submitted in the Original
Motion for Summary
Judgment
and
other documents I have
filed in this
case.
Paragraph
4 of the
Respondents’
Reply to Complainant’s Response
to
Respondent’s Motion to Dismiss states:
4.
Title
VI, Noise 415 ILCS Section 24, provides that “..no person shall emit noise
that
unreasonably interferes
so as to violate regulations or standards adopted by the Board;” while
Section
24 also
provides
that “[T]he Board may adopt regulations,
limitations,
prescribe
requirements, prescribe
maximum permissible limits...” and,
Sections 30-31 prescribe
“...detailed explanation of violations
alleged...” 3
1(a)(1)B,
and C “actions
that
may resolve..
and
furthermore, Section
42 provides mitigation, duration and gravity
considerations combined
with
“due diligence,”
considerations in such enforcement
proceedings which
we
submit have
been
met
in this case
by
the
respondents who have - and this is not in issue, complainant
freely
admits
this - by
voluntarily
removing the noise making devices, viz wind chimes, they
have
both
mitigated
the noise
pollution
by
voluntary removal of the offending devices, and
have
been
therefore duly diligent.
See
previous response to Paragraph 2.
Paragraph
5
of the
Respondents’
Reply
to
Complainant’s
Response
to
Respondent’s
Motion
to Dismiss
states:
5.
Please
keep in
mind that the
subject
neighborhood
in
question
where the
three
individual
property owners
reside, is
a reasonably
quiet, residential
area,
about a
block
from
a
busy
thoroughfare,
with
Chicago Fire
Department
nearby
and the usual
ambulances,
police and
other emergency
equipment
moving
up
and down the
nearby streets
at
all hours
of
the day and
night,
and
with
a
playlot
public
park directly
across the
narrow Street fronting the
three properties
where
children
of different ages
are
in evidence
a
good
part
of
the
day,
with
apartment
buildings
lining
either side of the
street on narrow
lots
with
automobiles
parked
on
either side, and with
residents coming and
going at all
hours
of the
day
and night,
this
is anything
but a
completely
quiet, sleepy area by
any stretch of the
imagination.
The only noise that is
relevant
in
this case is
the
Respondent’s noise
pollution about
which
the Complaint
was
filed.
The issue
of parking is relevant
to the lack
of available
spaces
on the block.
Paragraph
6
of the Respondents’
Reply
to
Complainant’s Response
to
Respondent’s
Motion
to
Dismiss states:
6.
Complainant
would now, in her
Response introduce for
the first
time
extraneous
and
irrelevant
matters,
having no connection
with the respondents,
and is
asking the Board to now
consider “dog
feces and assorted garbage”
being tossed
into
her yard, tree branches
and the like,
unexpected
telephone calls
and graffiti mysteriously
appearing, all of which
the respondents, and
each
of
them,
denies
having
any involvement with,
and categorically deny
that
they
would
ever
institute,
initiate or in
anyway contribute
to
such
goings on or
occurrences
which they abhor
personally,
and which
as
law
abiding citizens would
never condone and would
jointly seek to
prevent
if it were within
their power.
See
previous
response
to Paragraph
2.
Also, the
suggestion
that
the
Respondent
is
a law-abiding
citizen
is
false.
In fact,
it has now
been
formally
documented
with photos
that
he in continues
to
demonstrate
blatant disregard
for the
law. As
recently
as
November
14
and 15,
2008
the Respondent
illegally
parked
his
car in
the
critical
Firehouse
Swing
out
No
Parking
zone directly
across
from
his
house.
(See
ATTACHMENTS
1-4)
As
a
citizen,
the
law
binds
us
all.
As a Chicago
Law
Enforcement
officer,
the
Respondent
has
further
“...sworn
to follow
and
uphold the
law...” and
of whom
it
is
expected
that “ . . . on
and
off-duty
conduct
reflects
both
the
highest
standards
of
police service
and
personal responsibility.”
(City
of Chicago
Police
website
12/5/08).
In
these documented
cases, neither
has
occurred.
Paragraph
7
of
the Respondents’
Reply
to Complainant’s
Response
to
Respondent’s
Motion
to Dismiss
states:
7.
We
take
notice
of
the
fact that
the Board
has numerous
meetings
on momentous
matters
involving
commerce
and industry
operating
on
a
large scale,
and this
matter
while minor
in
the
grand
scheme
of things, is
very important
to
the
respondents,
as
well as the
complainant,
and
should
be resolved
expeditiously
on the
pleadings.
This
paragraph
reads
as
deliberate
and not-so-veiled
attempt
to minimize
the
importance
of
my
Complaint
relative
to
other
matters
before
the Board.
As
a
citizen
and
taxpayer
of the
State
of Illinois,
of which
the IPCB
is part,
my
complaint
is
no
more or less
important
than
any other
complaint
filed
with the
Board.
Simply
because I
have
been
patient
in
this
matter
and understanding
of
the numerous
pressures
faced
by the
Board
in
general,
neither
is indication
by
me or
by
the
Board
that my
Complaint
lacks
importance.
Paragraph
8
of the
Respondents’
Reply
to
Complainant’s
Response
to
Respondent’s
Motion
to Dismiss
states:
8.
Frankly,
neither
respondent
can afford
to conduct
this
new
“fishing
expedition”
proffered
by
the complainant,
although
as
neighbors,
they
too
are
concerned
about
the
conduct
of
the neighborhood,
do not wish
to have refuse
deposited
in their own
yards, excessive
noise
or
the like
interfering
with
neighborhood
peace and quiet,
and both
would
simply
like to
go
on
existing
as
law abiding
members
of
the
community,
without undue
interference
from neighboring
properties or
their
immediate
neighbors,
including
the
complainant,
or anybody
else.
I consider
the
statement
“fishing
expedition”
a far
too casual
phrase
given
the
seriousness
of
this
Complaint.
All of
the
choices the
Respondent
has freely
made
to-date,
have
brought
things
to
this point.
Whatever
choices
are
made
by
the
Respondent
prior
to
the
Board’s
final
ruling
will decide
next steps
and
whether
discovery
will
be
necessary.
That
the
Respondent
cannot
“afford”
this,
has been
the
result
of the
Respondent’s
choice
not
to
resolve
this
matter
privately
or
through
medication
before
the
Complaint was
filed
or
since.
Only
very
recently has
the
Respondent
decided to hire
an
attorney,
which
charge
for
their
services.
This
is
a
choice,
not
a
requirement.
There
has
never
been
anything
stopping
the
Respondent
from
engaging in this
process
pro
se,
as
I
have
had
to
do
all
along
because I
cannot
“afford”
the
extensive
stress,
time,
energy,
effort,
monetary
outlay,
and
lost
wages
that
I
have
had
to
face
in this
matter,
let alone
hiring
an attorney.
Again,
the
Respondent
is
clearly
not
law
abiding.
If
that
were
true,
no complaint
would
ever
have
had
to
be
filed,
especially
after
I provided
the
Respondent
with
a
written
copy
of the
relevant
Illinois
Law
Paragraph
9
of
the
Respondents’
Reply
to
Complainant’s Response
to
Respondent’s Motion
to
Dismiss
states:
9.
The
chimes
are down
now
and will
stay
down;
both
homeowner
respondents
go to
work
each
day,
Karen
Sokolowski
leaves
between
6:30
and 6:45
a.m.
each
day
and
returns
at
7:30
- 8:00
p.
in.,
seven
days a
week,
Mr.
Jimenez
similarly
works
long
hours,
and
everyone
wants
this
matter
over with,
concluded
and resolved,
so that
they can
go on
with
their
lives.
In
fact, I have
previously
cited
this
very information
in
support
of
my
Complaint.
The
Respondent
does
work
outside
the
home,
while I work
from
inside
my
home
and
am
therefore
subjected
both
personally
and
in
terms
of
my
livelihood
24/7
to
unwanted
noise
pollution
emanating
from
the Respondent’s
property.
I completely
agree
that
this
matter
should
be
“.
. .over
with,
concluded,
and
resolved,
so
that
[all parties}
can
go on
with
their
lives.”
However,
I feel
that
it
actually
should
have
been
“. . . over
with, concluded,
and resolved,
so
that [all
parties
could]
go on with
their
lives.
. .“long
before
my tiling
a
Complaint
was
necessitated
and resulted
in my
having
to engage
in such
a
generally
“costly”
and
protracted
process
that it
has been
for
me.
Only
the Respondents
choices
have
brought
things
to
this point.
In
support
of
my agreement
that
this matter
be “.
.
. over
with, concluded,
and
resolved,
so
that
[all
parties}
can
go
on
with
their lives,”
I request
again
that
the
Board
rule
in
my
favor. That’s
the
only
way to best
assure
an end to
the noise
pollution
and
will
act
as
proof
required
by
the police
so that
they
can and
will
act
upon
the problem
in the
future.
Respectfully,
Kyle Nash
Pro Se
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ATTACHMENTS 1-4
1.
Critical
firehouse
swing-out
No
Parking
zone
that’s
located directly
across
the street
from
the Respondent’s
house.
F
2. Respondent’s green van clearly
parked in violation
of the law.
/
4,
/
I
1
— —
2.C1ose-up of Respondent’s Illinois license
plate (obscured # 129241)
with his
Fraternal Order
of
Police sticker
prominently
located just to the left of
it.
•1
4.
Respondent’s green van illegally parked with silver
car that later parked in front of it.
