BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
ADMINISTRATIVE
CITATION
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
Complainant,
)
AC
44
V.
)
(IEPA
NoQ9),
GORDON
IN
VESTMENT
GROUP,
LLC,
)
,
Respondents.
)
Pol1ut
STATE
OFILLINO
0
Controi
Bo%
NOTICE
OF
FILING
To:
Clerk
Illinois
Pollution
Control
Board
James
R. Thompson
Center
100 W.
Randolph
Street,
Suite 11-500
Chicago,
IL 60601
Illinois
Environmental
Protection
Agency
Attn:
Division
of Legal Counsel
1021
North
Grand
Avenue
East
P0
Box
19276
Springfield,
IL
62794-9276
PLEASE
TAKE
NOTICE
that on
this date
I mailed
for filing
with
the
Clerk of
the Pollution
Control Board
of the
State
of Illinois
the
following
instrument
entitled
PETITION
FOR REVIEW.
Respectfully
submitted,
Holland
and
Holland
ByyJ4f4’
Stephen
E.
Holland
Steph
n E.
Holland
Holland
and
Holland
Attorney
for
Respondent
Attorney
for
the
Respondents
397
West
Main
Street
Bushnell,
IL
61422
ANDHOLLAND
HOLLAND
30977221
‘
8
‘j’
ArTORNEYS
307 WEST MAINAT
LAW
Fax:
309-772-2085
P.O.
BOX
208
USHNELL,
ILLINOIS
61422
TELEPHONE,
300 772378
Dated:
June
10, 2009
HOLLAND
AND
HOLLAND
ATTORNEYS
AT
Law
397
WEST
MAIN
P.O.
BOX
296
USHNELL,
ILLINOIS
61422
TELEPHONE:
309
772-3178
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
ADMINISTRATIVE
CITATION
C
‘:
II
V
E
D
OFFICE
ILLINOIS
ENVIRONMENTAL
)
JUN
12
jj9
PROTECTION
AGENCY
)
STATE
OF
ILLINOIS
Complainant,
)
AC
cf(
t
Lf1
POllution
Control
Board
v.
)
(IEPA
No.
80-09-AC)
GORDON
INVESTMENT
GROUP,
LLC,
Respondents,
NOTICE
AND
ENTRY
OF
APPEARANCE
Now
comes
HOLLAND
AND
HOLLAND,
attorney
for
the Respondent,
Gordon
Investment
Group,
LLC in
the above
entitled
cause,
and
enters
their
appearance
as attorneys
of record
for the
Respondent
herein.
Dated:
June 10,
2009
HOLLAND
AND
HOLLAND
By:_______
‘tephen
E. Holland
Attorney
for
Respondent
Stephen
E.
Holland
Holland
and
Holland
Attorney
for the
Respondents
397
West
Main
Street
Bushnell,
IL 61422
309-772-3178
Fax: 309-772-2085
S
0iFic
AC
,j
11
20fl9
‘-,
I
OF
ILLINOIS
(IEPA
No.
80-09-Ab)
Controj
8
Oarc
GORDON
INVESTMENT
GROUP,
LLC,
Respondents,
PETITION
FOR
REVIEW
Now
comes
Gordon Investment
Group,
LLC,
by
its
attorney
Stephen
E.
Holland,
and
Petition
the
agency
to
review
the
Administrative
Citation
filed
herein
on
May
6,
2009,
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.
4.
They
neither
admit
nor deny
the allegation
of
paragraph
4.
5.
They
admit
the
allegation
of
paragraph
5.
In
addition
thereto,
they
specifically
deny
that
the Respondents
caused
or
allowed
the
open
dumping
of
waste
in
a
manner
resulting
in
litter
in violation
of
415
ILCS
5/21(p)
(1).
They
further
deny
the intentional burning
of
mobile
home
materials
at
the site
as
they
were
salvaging
the
mobile
homes
as
they
were
being
torn
down,
as
noted
to be
in
violation
of
415
ILCS
5/2l(p)(
3
).
They
further
deny
that the
Respondents
caused
or allowed
the
open
dumping
of
waste
in a
manner
resulting
in
deposition
of
general
construction
or
demolition
debris
in
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
ADMINISTRATIVE
CITATION
ILLINOIS
ENVIRONMENTAL
PROTECTION
AGENCY
Complainant,
V.
HOLLAND
AND
HOLLAND
ATTORNEYS
AT
LAW
397
WEST MAIN
P.O. BOX
298
USHNELL
ILLINOIS
61422
TELEPHONE:
309
772.3178
violation
of 415
ILCS
5/2l(p)(7).
The
grounds were
continually cleaned
as materials
were
disposed
of at
a
local legal
dump site.
Dated
this
10
th
day
of June,
2009.
Gordon
Investment Group,
LLC
By:
/
7
Stephd’n
E. Holland,
their aft
ney
Stephen
E. Holland
Holland
and Holland
Attorney
for the Respondents
397
West Main
Street
Bushnell, IL 61422
309-772-3178
Fax: 309-772-2085
HOLLAND
AND HOLLAND
ATTORNEYS
AT
Law
307 WEST
MAIN
P.O. BOX 208
USHNELL, ILLINOIS 61422
—2—
TELEPHONE:
300 772-3178
CERTIFICATE
AND
PROOF OF
SERVICE
/ (ii/\J/
L
I certify that
on
June 10, 2009, the foregoing
instrument
was served
upon the following
by
depositing a copy
thereof in
the
U.S.
Mail, postage
prepaid,
in envelopes
addressed
to
the
following:
Clerk
Illinois Pollution Control
Board
James R.
Thompson
Center
100 W. Randolph
Street, Suite 11-500
Chicago, IL
60601
Illinois Environmental
Protection Agency
Attn: Division of
Legal
Counsel
1021
North Grand Avenue
East
P0 Box
19276
Springfield, IL
62794-9276
EC -
CLEF
JUL
STATE
Pollutior
HOLLAND
AND
HOLLAND
ATTORNEYS AT
Lxw
397 WEST 9IAIN
P.O.
BOX
=98
USHNELL,
ILLINOIS
61422
TELEPHONE: 309 772-3178
JUN
j
22009
STATE
OF
ILLiNOIS
Pollution
Control
Board
!EcVED
CLERI<’S
OFFICE
-3-
Ho/lana
and Holland
Ylitorneys at
Law
397 WEST MAIN
STREET
PC. Box 298
CLER(’S
OFFICE
BUSHNELL, ILLINOIS
61422-0298
1
.
FAX
NUMBER:
309/772-2085
309)772-3178
\
I
(—i
/
/\//
EMAIL: hollholl@logonix.net
June 10,
2009
VIA:
CERTIFIED
MAILJRETURN
RECEIPT
Clerk
Illinois Pollution
Control
Board
James
R. Thompson Center
100
W. Randolph Street,
Suite
11-500
Chicago,
IL 60601
RE:
IEPA v. Gordon
Investment
Group, LLC
IEPA
No.
80-09-AC
Dear Sir:
Attn:
Illinois
Division
Environmental
of Legal
ProtectionCounsel
Agency
4
1021 North
Grand Avenue
East
P0 Box 19276
Springfield, IL
62794-9276
On behalf
of Gordon
Investment
Group,
LLC, I am forwarding
to the Illinois
Pollution Control
Board
a
Petition
for
Review of
the
above
captioned matter
along with the
Notice of Filing,
Certificate
of Service,
and Notice
of Appearance
and nine
duplicate copies.
I am also
forwarding
a copy of
the Petition
for Review with the
Notice
of Filing,
Certificate of
Service,
and Notice of Appearance
to the Illinois
Environmental
Protection
Agency.
Please
let
me know
if you have any questions.
Sincerely,
HOLLAND
AND HOLLAND
STEPHEN
E.
HOLLAND
BRIAN P. HOLLAND
JUN
2
2OO
STATE
OF
1LLi;
POllution
Contrj
:i:y
Holland
SEH:ksg
Enclosures
cc:
Rod Gordon
