BEFORE THE
    ILLINOIS
    POLLUTION CONTROL
    BOAI
    ADMINISTPTIVE
    CITATION
    ILLINOIS ENVIRONMENTAL
    )
    FEB
    102009
    PROTECTION AGENCY,
    )
    STATE
    OF
    ILLINOI
    Complainant,
    )
    AC
    0
    °
    U
    on
    Control
    Board
    )
    v.
    )
    (IEPANo. 317-08-AC)
    fl
    QUINN
    &
    GLENNA
    HUNLEY,
    )
    ‘‘ ‘
    IV/\
    I
    Respondents.
    )
    AMENDED
    PETITION
    FOR REVIEW
    Now come
    Quinn Hunley and
    Glenna Hunley,
    by
    their attorney, Tom
    L. Weber, and
    petition
    the agency to
    review the
    Administrative Citation
    filed herein on November
    20, 2008,
    and in
    support thereof,
    state:
    1. They admit
    the
    allegations
    of paragraph 1;
    2.
    They deny
    the allegations of
    paragraph 2
    and specifically state
    that they were not
    operating an open
    dump
    at
    said
    premises;
    3.
    They
    admit
    the
    allegations of
    paragraph 3
    in that they own the
    said premises,
    but
    deny that
    they operated
    a
    facility
    at
    2136
    N IL Route
    130,
    West
    Salem, Edwards
    County, Illinois;
    4.
    They neither
    admit
    nor deny the allegations
    of
    paragraph 4;
    5.
    They admit
    the allegations
    of paragraph
    5;
    In
    addition
    thereto, they
    specifically deny that
    the Respondents caused
    or allowed the
    open
    dumping of
    waste
    in an manner
    resulting
    in litter in violation
    of415 ILCS 5/21(p)(l).
    They
    deny
    the
    accumulation of
    material with little
    or no value on the premises
    and assert that
    the items
    assembled at said premises
    were items of considerable value which the Petitioners were in the
    process of
    selling.
    Dated this
    6th
    day
    of February, 2009.
    Quinn
    Hunley
    &
    Glenna Hunley
    By:
    Tom L. Weber, their attorney
    TOM L
    WEBER
    Attorney for
    Respondents
    101 S Elliott Street
    Olney,
    IL
    62450
    618/395-4911
    Fax 618/395-4449
    CEVED
    CLEKS
    OFFICE
    FEB
    1
    02009
    Pa ra I ega I
    (:(>flflIC
    L.
    lcVicker
    TOM
    L. WEBER
    ATTORNEY
    AT
    LAW
    101
    S. ELLIOTT
    ST.
    OLNEY,
    ILLINOLS 62450
    TEL. 618-395-4911
    FAX 618-395-4449
    STATE
    OF
    ILLINOIS
    Pollution
    Control
    Board
    Administr’stive
    Assistant
    Christina R
    Son eli
    February
    6,
    2009
    Illinois
    Pollution
    Control
    Board
    .James
    R. Thompson
    Center
    100
    West Randolph
    Street,
    Suite
    11-500
    Chicago,
    IL 60601
    Illinois
    Environmental
    Protection
    Agency
    Attention:
    Division
    of Legal
    Counsel
    POBox
    19276
    Springfield.
    IL
    6
    1794-9276
    Re:
    IEPANo.
    317-08-AC
    IL
    EPA v.
    Quinn Hunley
    Dear Sirs:
    A
    0
    qLf
    Please
    find enclosed
    herewith
    an Amended
    Petition
    For
    Review on
    behalf of
    Quinn
    Hunley
    and
    Glenna
    Hunley.
    TLW:crs
    Enclosure
    Cc:
    Michelle
    Ryan
    Division of
    Legal
    Counsel
    Illinois
    Environmental
    Protection
    Agency
    P0
    Box
    19276
    Springfield,
    IL
    62794-9276
    Very
    truly yours,

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