BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
LISA MADIGAN, Attorney General
)
of the State of Illinois,
)
)
Complainant,
)
)
vs.
)
PCB No. 09-69
)
(Enforcement - Water)
PAR DEVELOPMENT, INC.,
)
an Illinois corporation,
)
)
Respondent.
)
NOTICE OF FILING
TO:
Warren R. Fuller
Fuller and Berres
Attorneys at Law
69
South Barrington Road
South Barrington, Illinois 60010
Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph Street, Ste. 11-500
Chicago, Illinois 60601
PLEASE
TAKE NOTICE that I have today filed with the Office of the Clerk of the
Illinois Pollution Control Board an original and nine copies
of the Stipulation and Proposal for
Settlement, an Agreed Motion for Relief from the Hearing Requirement, Notice
of Filing and a
Certificate
of Service; a copy of which is attached herewith and served upon you.
BY:
DATE: September 14, 2009
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA
MADIGAN
Attorney General
State of Illinois
ZEMEHERET
*,~Mb
BEREKET-AB
Environmental Bureau
Assistant Attorneys General
69 W. Washington
St., Suite 1800.
Chicago, Illinois 60602
(312) 814-3816
THIS FILING IS SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
LISA MADIGAN, Attorney General
)
of the State of Illinois,
)
)
Complainant,
)
)
vs.
)
)
PAR DEVELOPMENT, INC.,
)
an Illinois corporation,
)
)
Respondent.
)
PCB No. 09-69
(Enforcement - Water)
AGREED MOTION TO REQUEST RELIEF
FROM THE HEARING REQUIREMENT
In
support of this Motion, the parties state as follows:
1.
Today, the People of the State of Illinois, filed a Stipulation and Proposal for
Settlement, with the Illinois Pollution Control Board.
2.
Section
31 (c )(2) of the Illinois Environmental Protection Act, ("Act"), 415 ILCS
5/31 (c )(2)(2008) provides:
Notwithstanding the provisions of subdivision (1) ofthis subsection (c), whenever
a complaint has been filed
on behalf of the Agency or by the People of the State of
Illinois, the parties may file with the Board a stipulation and proposal for
settlement accompanied
by a request for relief from the requirement of a hearing
pursuant to subdivision (1)
....
3.
Complainant and Respondent agree that a formal hearing
is not nece"ssary to conclude this matter and wish to avail themselves
of Section 31 (c )(2) of the
Act, 415 ILCS 5/31 (c )(2)(2008).
Electronic Filing - Received, Clerk's Office, September 14, 2009
WHEREFORE, Complainant and Respondent request relief from the hearing requirement
pursuant to Section
31 (c )(2) of the Act.
BY:
DATE: September 14,
2009
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA
MADIGAN
Attorney General
State
of Illinois
MATTHEW
J. DUNN, Chief
Environmental Enforcement/
Asbestos Litigation Division
ZEMEHERET
~~~iM
BEREKET-AB
Environmental Bureau
Assistant Attorneys General
69 W. Washington St., Suite
1800
Chicago, Illinois 60602
(312) 814-3094
G:\Environmental Enforcement\Z BEREKET-AB\PAR DEVELOPMENT\Agreed Mot to Req Relief9-14-09.doc
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
v.
PAR DEVELOPMENT, INC.,
an Illinois corporation,
Respondent.
)
)
)
)
)
)
)
)
)
)
PCB NO. 09-69
(Enforcement - Water)
STIPULATION AND PROPOSAL FOR SETTLEMENT
Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA MADIGAN, Attorney
General
of the State of Illinois, the Illinois Environmental Protection Agency ("Illinois EPA"),
PAR DEVELOPMENT, INC. ("PAR") ("Parties to the Stipulation"), have agreed to the making
of this Stipulation and Proposal for Settlement ("Stipulation") and submit it to the Illinois
Pollution Control Board ("Board") for approval. This stipulation of facts is made and agreed
upon for purposes
of settlement only and as a factual basis for the Board's approval of this
Stipulation and issuance
of relief. None of the facts stipulated herein shall be introduced into
evidence in any other proceeding regarding the violations
of the Illinois E;nvironmental
Protection
Act ("Act"), 415 ILCS 511
et seq.
(2008), and the Board's Regulations, alleged in the
Complaint except as otherwise provided herein.
It
is the intent of the Parties to the Stipulation
that it
be a final adjudication of this matter.
I.
STATEMENT OF FACTS
A.
Parties
1.
On March 30, 2009, a Complaint was filed on behalf of the People of the State of
Illinois by Lisa Madigan, Attorney General of the State of Illinois, on her own motion and upon
Electronic Filing - Received, Clerk's Office, September 14, 2009
the request of the Illinois EPA, pursuant to Section 31 of the Act, 415 ILCS 5/31 (2008), against
the Respondent
PAR DEVELOPMENT, INC.
2.
The Illinois EPA is an administrative agency of the State of Illinois, created
pursuant to Section 4 of the Act, 415 ILCS 5/4 (2008).
3.
At all times relevant to the Complaint, Respondent PAR was and is an Illinois
corporation that is authorized to transact business in the
State of Illinois. At all times relevant to
the Complaint,
PAR was and is the developer at the parcel of real property intended to be a retail
business development project called Lake
Pointe located at the northeast comer of the
intersection at Algonquin Road and Lakewood Road in Lake in the Hills, McHenry County,
Illinois
("Site").
4.
On September 24, 2004, the Illinois EPA received from PAR a Notice of Intent
("NOI") application for coverage under the NPDES general permit to discharge storm water
from construction site activities. On October 26, 2004, the Illinois EPA issued to PAR Notice of
Coverage Under Construction Site Activity Storm Water General Permit NPDES Permit No.
ILRI0B681.
5.
The total size of the construction Site is approximately 26.3 acres and the closest
receiving water is Exner Marsh, an Illinois protected area. The
NOI indicated that storm water
from the Site discharges directly to waters of the State, Exner Marsh.
6.
On June 20, 2007, the Illinois EPA conducted an inspection of the construction
Site.
7.
During the June 20, 2007 inspection, the Illinois EPA observed that a pump was
pumping sediment laden water adjacent to the silt fence, and the sediments were breaching the
silt fence and entering into a pond named
Rose's Pond, a "water" of the State of Illinois as
2
defined in Section 3.550 of the Act, 415 ILCS 5/3.550 (200S), which is located within the Site.
Rose's Pond is a tributary to Exner Marsh, also a "water" of the State of Illinois as defined in
Section
3.550 of the Act, 415 ILCS 5/3.550 (200S).
S.
The Illinois EPA also observed some piles of dirt laden with debris as well as a
pile
of broken concrete with rebar adjacent to Rose's Pond and the silt fence. The exposed piles
of soil laden with debris and pile of broken concrete with rebar (which Respondents advised was
left in part
by an unrelated prior owner) were placed in a manner which posed a potential hazard
to water quality.
9.
During the June 20, 2007, inspection, the Illinois EPA also observed that the NOI
was not posted and there was no copy of the stormwater pollution prevention plan ("SWPPP")
available for review at the Site.
10.
On August 10,2007, the McHenry County Soil and Water Conservation District
("MCSWCD") conducted an inspection of the Site under a delegation agreement with the Illinois
EP
A.
Respondent alleges there is no evidence that it received any report of this inspection. The
Complainant states there was no statutory
or regulatory provision requiring the MCSWCD to
provide the Respondent a copy
of the report. Despite this, Complainant alleges that on August
15,2007, the MCSWCD did send to Ryan Trottier of PAR Development a copy of its August 10,
2007
inspection report and photos.
11.
During the August
10, 2007 inspection, the MCSWCD inspector observed
sediment-laden water being pumped from an area adjacent to the Site where
PAR's contractor
was working to widen Algonquin Road for the McHenry County Highway Department. The
Illinois
EPA asserts that water was pumped from the area adjacent to the Site and discharged to
the ground
on the Site and traveled 300 to 400 feet over bare ground to the detention basin,
3
documented in photographs and from the basin, the water was pumped into a filter bag, which
. failed to remove suspended solids from the water. The water then flowed into Exner Marsh. The
Respondent disputes the assertions made in the preceding sentence.
12.
On July 9,2007, the Illinois EPA sent a violation notice to PAR.
13.
On July 16, 2007, PAR sent its compliance commitment agreement ("CCA") to
the Illinois EPA.
14.
On August 15, 2007, the Illinois EPA rejected PAR's CCA. PAR responded to the
Illinois
EPA's letter of August 15, 2007 and requested a conference for clarification with respect
to the Illinois EPA's letter of August 15,2007. No conference was held pursuant to that request,
as Illinois law does not require the Illinois
EPA to hold a conference with an alleged violator in
this instance.
15.
On March 20,2008, the Illinois EPA issued a Notice ofIntent to Pursue Legal
Action
("NIP LA") letter. PAR requested a meeting with the Illinois EPA pursuant to the NIPLA
letter,
as a result of which a telephone conference was held on April 11,2008.
B.
Allegations of Non-Compliance
Complainant contends that the Respondent has violated the following provisions of the
Act and Board regulations:
Count
I:
Count II:
Count III:
Water Pollution, in violation
of Section 12(a) of the Act, 415 ILCS
5112(a) (2008).
Water Pollution Hazard, in violation of Section 12( d) of the Act,
415
ILCS 5/12(d) (2008).
NPDES Permit
Violation-Discharge of Contaminants, in violation
of Section 12(f) of the Act, 415 ILCS 5/12(f) (2008), and 35 Ill.
Adm. Code
309.102(a).
4
..
Count IV:
Count V:
NPDES Permit Violation-Failure to Post Notification of Coverage,
in violation
of Section 12(f) of the Act, 415 ILCS
5/12(f) (2008),
and 35 Ill. Adm. Code 309.102(a).
NPDES
Permit Violation-Failure to Have Stormwater Pollution
Prevention Plan Available at the
Site, in violation of Section 12(f)
of the Act, 415 ILCS
5/12(f)
(2008), and 35 Ill. Adm. Code
309.102(a).
C.
Non-Admission of Violations
The Respondent neither admits nor denies the violation(s) alleged in the Complaint filed
in this matter and referenced herein.
D.
Compliance Activities to Date
PAR has completed the following compliance activities to date:
1.
Silt fence repair completed for west side of pond, north, east and south side of
stockpile, and the east side of the area south of the stockpile.
2.
Jute netting completed over rock checks and 50 feet of ditch prior to Rose Pond.
3.
North Pond - Small area of existing silt fence replaced with monofilament silt
fence and the area stabilized with seed and blanket.
4.
Temporary seeding of the stockpile completed.
5.
Repair utility areas completed: Backfill, seed and stabilization.
6.
Restoration of machine tracking from utility, fence and tree installations around
south pond completed.
7.
Observed clean water leaving the Property.
8.
Protecting all surface water inlets with monofilament drop-in basket.
9. '
Site stabilization with maturing vegetation.
5
II. APPLICABILITY
This Stipulation shall apply to and be binding upon the Parties to the Stipulation, and any
officer, director, agent,
or employee of the Respondent, as well as any successors or assigns of
the Respondent. The Respondent shall not raise as a defense to any enforcement action taken
pursuant to this Stipulation the failure
of any of its officers, directors, agents, employees or
successors or assigns to take such action as shall be required to comply with the provisions of
this Stipulation. This Stipulation may be used against the Respondent in any subsequent
enforcement action
or permit proceeding as proof of a past adjudication of violation of the Act
and the Board Regulations for all violations alleged in the Complaint
in this matter, for purposes
of Sections 39 and 42 of the Act, 415 ILCS 5/39 and 42 (2008).
The Respondent shall notify each contractor to be retained to perform work required in
this Stipulation
of each of the requirements of this Stipulation relevant to the activities to be
performed by that contractor, including all relevant work schedules and reporting deadlines, and
shall provide a
copy of this Stipulation to each contractor already retained no later than thirty
(30) calendar days after the date of entry of this Stipulation. In addition, the Respondent shall
provide copies
of all schedules for implementation of the provisions of this Stipulation to the
prime vendor(s) supplying the control technology systems and other equipment required
by this
Stipulation.
III. IMPACT ON THE PUBLIC RESULTING FROM ALLEGED NON-COMPLIANCE
Section 33(c) of the Act, 415 ILCS 5/33(c)(2008), provides as follows:
. In making its orders and determinations, the Board shall take into consideration
all the facts and circumstances bearing upon the reasonableness
of the emissions,
discharges,
or deposits involved including, but not limited to:
1.
the character and degree of injury to, or interference with the protection of
the health, general welfare and physical property of the people;
6
2.
the social and economic value of the pollution source;
3.
the suitability
or unsuitability of the pollution source to the area in which
it is located, including the question
of priority of location in the area
involved;
4.
the technical practicability and economic reasonableness
of reducing or
eliminating the emissions, discharges or deposits resulting from such
pollution source; and
5.
any subsequent compliance.
In response to these factors, the Parties to the Stipulation state the following:
1.
The adjacent property to the Site is a marsh designated an Illinois protected area
by the Illinois Department of Natural Resources. The discharge of contaminants into a protected
natural resource poses serious injury to the
State's natural resources.
2.
There is social and economic benefit to Respondent's construction activities at the
Site.
3.
Operation of the facility was suitable for the area in which it occurred.
4.
Implementing adequate erosion control measures and complying with
NPDES
permit operating conditions is both technically practicable and economically reasonable.
5.
Respondent is in the process of implementing compliance measures to comply
with the Act and the Board Regulations.
IV. CONSIDERATION OF SECTION 42(b) FACTORS
Section 42(h) of the Act, 415 ILCS 5/42(h)(2008), provides as follows:
In determining the appropriate civil penalty to be imposed under
... this Section,
the Board is authorized to consider any matters of record in mitigation or
aggravation
of penalty, including but not limited to the following factors:
1.
the duration and gravity of the violation;
7
Electronic Filing - Received, Clerk's Office, September 14, 2009
2.
the presence or absence of due diligence on the part of the respondent in
attempting to comply with requirements
of this Act and regulations
thereunder or
to secure relief therefrom as provided by this Act;
3.
any economic benefits accrued by the respondent because of delay in
compliance with requirements, in which case the economic benefits shall
be determined by the lowest cost alternative for achieving compliance;
4.
the amount of monetary penalty which will serve to deter further
violations by the respondent and to otherwise aid in enhancing voluntary
compliance with this Act by the respondent and other persons similarly
subject to the Act;
5.
the number, proximity in time, and gravity of previously adjudicated
violations
of this Act by the respondent;
6.
whether the respondent voluntarily self-disclosed, in accordance with
subsection i
of this Section, the non-compliance to the Agency; and
7.
whether the respondent has agreed to undertake a "supplemental
environmental project," which means an environmentally beneficial
project that a respondent agrees to undertake in settlement
of an
enforcement action brought under this Act, but which the respondent is not
otherwise legally required
to perform.
In response to these factors, the Parties to the
StipUlation state as follows:
1.
Stormwater permit violations were noted during the Illinois EPA's inspection on
June
20, 2007, and the Illinois EPA asserts that continuing permit violations were observed
during a follow-up inspection by the MC
SWCD on August 10, 2007. The adjacent property
known
as the Exner Marsh is designated an Illinois protected area by the Illinois Department of
Natural Resources.
2.
Respondent took some steps to address erosion controls at the Site after the
Illinois EPA's July
20,2007 inspection, but the Illinois EPA asserts a second inspection of the
Site approximately three weeks later indicated continuing problems at the Site. Respondent
asserts that it was not notified
of the follow-up inspection referred to in paragraph 1 preceding or
8
the second inspection or its results in endeavoring to resolve any issues related to its remedial
efforts or follow-up inspection noted.
3.
Economic benefits accrued by Respondent are believed to be minimal and are
accounted for in the
$20,000.00 penalty agreed herein.
4.
Complainant has determined, based upon the specific facts of this case, that a
penalty
of Twenty Thousand Dollars ($20,000.00) will serve to deter further violations and aid in
future voluntary compliance with the Act and Board regulations.
5.
To Complainant's knowledge, Respondent has no previously adjudicated
violations
of the Act.
6.
Respondent did not voluntarily disclose the violations that are the subject of this
case but did execute an Incident of Non-Compliance Report ("ION") which acknowledged the
pumping activities
of the road building contractor referred to in Section LA. II preceding after
MCSWCD learned of the pumping activities and directed Respondent to submit the ION. The
Respondent submitted a completed
ION at the recommendation of its consultant, Haeger
Engineering, LLC.
7.
The settlement of this matter does not include a supplemental environmental
project.
V. TERMS OF SETTLEMENT
A.
Penalty Payment
1.
The Respondent shall pay a civil penalty in the sum of Twenty Thousand Dollars
($20,000.00) within thirty (30) days from the date the Board adopts and accepts this Stipulation.
9
Electronic Filing - Received, Clerk's Office, September 14, 2009
B.
Stipulated Penalties, Interest and Default
1.
If the Respondent fails to complete any activity or fails to comply with any
response
or reporting requirement by the date specified in this Stipulation, the Respondent shall
provide notice to the Complainant
of each failure to comply with this Stipulation and shall pay
stipulated penalties in the amount
of $1 00.00 per day until such time that compliance is
achieved. The Complainant
may make a demand for stipulated penalties upon the Respondent
for its noncompliance with this Stipulation. However, failure
by the Complainant to make this
demand shall not relieve the Respondent
of the obligation to pay stipulated penalties. All
stipulated penalties shall be payable within thirty
(30) calendar days of the date the Respondent
knows or should have known
of its noncompliance with any provision of this Stipulation.
2.
If the Respondent fails to make any payment required by this Stipulation on or
before the date upon which the payment is due, the Respondent shall be in default and the
remaining unpaid balance
of the penalty, plus any accrued interest, shall be due and owing
immediately. In the event
of default, the Complainant shall be entitled to reasonable costs of
collection, including reasonable attorney's fees.
3.
Pursuant to Section 42(g)
of the Act, interest shall accrue on any penalty amount
owed
by the Respondent not paid within the time prescribed herein. Interest on unpaid penalties
shall begin to accrue from the date such are due and continue to accrue to the date full payment
is received. Where partial payment is made on any penalty amount that is due, such partial
payment shall be first applied to any interest
on unpaid penalties then owing.
C.
Payment Procedures
All payments required by this StipUlation shall be made by certified check or money
order payable to the Illinois
EPA for deposit into the Environmental Protection Trust Fund
10
("EPTF"). Payments shall be sent by first class mail and delivered to:
Illinois Environmental Protection Agency
Fiscal Services
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
The name, case number and the Respondent's federal tax identification number shall appear
on
the face of the certified check or money order. A copy of the certified check or money order and
any transmittal letter shall be sent to:
Environmental Bureau North
Illinois Attorney General's
Office
69 West Washington Street, Suite 1800
Chicago, Illinois 60602
D.
Future Compliance
1.
By November 30, 2009, PAR shall complete adequate reseeding of the Site to
establish final stabilization.
2.
In addition to any other authorities, the Illinois EPA, its employees and
representatives, and the Attorney General, her employees and representatives, shall have the
right
of entry into and upon the Respondent's facility which is the subject of this Stipulation, at
all reasonable times for the purposes
of conducting inspections and evaluating compliance status.
In conducting such inspections, the Illinois EPA, its employees and representatives, and the
Attorney General, her employees and representatives, may take photographs, samples, and
collect information, as they deem necessary.
3.
This Stipulation in no way affects the responsibilities of the Respondent to
comply with any other federal, state or local laws or regulations, including but not limited to the
Act and the Board Regulations.
11
Electronic Filing - Received, Clerk's Office, September 14, 2009
4.
The Respondent shall cease and desist from future violations of the Act and
Board Regulations that were the subject matter
of the Complaint.
E.
Release from Liability
In
consideration of the Respondent's payment ofthe $20,000.00 penalty, its commitment
to cease and desist as contained in
Section V.D. above, completion of all activities required
hereunder, and upon the Board's approval
of this Stipulation, the Complainant releases, waives
and discharges the Respondent from any further liability or penalties for the violations
of the Act
and Board Regulations that were the subject matter
of the Complaint herein. The release set forth
above does not extend to any matters other than those expressly specified in Complainant's
Complaint filed on March
30, 2009. The Complainant reserves, and this StipUlation is without
prejUdice to, all rights
of the State of Illinois against the Respondent with respect to all other
matters, including but not limited to, the following:
a.
criminal liability;
b.
liability for future violation of state, federal, local, and common laws and/or
regulations;
c.
liability for natural resources damage arising out of the alleged violations; and
d.
liability or claims based on the Respondent's failure to satisfy the requirements of
this Stipulation.
Nothing in this Stipulation is intended as a waiver, discharge, release, or covenant not to
sue for any claim or cause
of action, administrative or judicial, civil or criminal, past or future, in
law or in equity, which the
State of Illinois may have against any person, as defined by Section
3.315 of the Act, 415 ILCS 5/3.315 (2008), or entity other than the Respondent.
12
Electronic Filing - Received, Clerk's Office, September 14, 2009
F.
Correspondence, Reports and Other Documents
Any and all correspondence, reports and any other documents required under this
Stipulation, except for penalty payments, shall
be submitted as follows:
As to the Complainant
Zemeheret Bereket-Ab
Assistant Attorney General
Environmental Bureau
69 W. Washington Street,
Suite 1800
Chicago, Illinois 60602
Chuck Gunnarson
Assistant Counsel
Illinois EP A
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
Karen Katamay
Division
of Water Pollution Control
Field Operations Section
9511 West Harrison
Street
Des Plaines, Illinois 60016
As to the Respondent
PAR Development, Inc.
1141 East
Main Street, Suite 100
East Dundee, Illinois 60118
Warren R. Fuller
Fuller and Berres
69
S. Barrington Road
South Barrington, Illinois 60010
G.
Enforcement and Modification of Stipulation
1.
Upon the entry of the Board's Order approving and accepting this Stipulation, that
Order is a binding and enforceable order ofthe Board and may be enforced as such through any
and all available means.
13
Electronic Filing - Received, Clerk's Office, September 14, 2009
2.
The Parties to the Stipulation may, by mutual written consent, agree to extend any
compliance dates or modify the terms
of this Stipulation. A request for any modification shall be
made in writing and submitted to the contact persons identified in
Section V.G. Any such
request shall be made
by separate document, and shall not be submitted within any other report
or submittal required
by this Stipulation. Any such agreed modification shall be in writing,
signed
by authorized representatives of the Parties to the Stipulation.
H.
Execution of Stipulation
The undersigned representatives for the Parties to the Stipulation certify that they are
fully authorized
by the party whom they represent to enter into the terms and conditions of this
Stipulation and to legally bind them to it. .
WHEREFORE, the
Parties to the Stipulation request that the Board adopt and accept the
foregoing Stipulation and Proposal for Settlement as written.
[THE REMAINDER OF THIS PAGE IS INTENTIONALLY LEFT BLANK]
14
A
'
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN
Attorney General
State
of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/
Asbestos Li .
PAR DEVELOPMENT, INC.
THE ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY
DOUGLAS P. SCOTT, Director
Illinois Environmental Protection Agency
.
ef Legal Counsel
DATE: ----"<..$->-..(
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G:\Environmental Enforcement\Z BEREKET-AB\PAR DEVELOPMENnStipulation 7-24-09.doc
15
CERTIFICATE OF SERVICE
I, ZEMEHERET BEREKET-AB, an Assistant Attorney General, do certify that I caused
to be served on this
14th
day of September, 2009, the foregoing Notice of Filing, a Stipulation
and Proposal for Settlement, and an Agreed Motion for Relief from the Hearing Requirement,
upon the persons listed on said Notice by placing same in an envelope bearing sufficient postage
with the
United States Postal Service located at 100 West Randolph Street, Chicago, Illinois.
~~fA!,
ZEMEHERET BEREKET-AB
G:\Environmental Enforcement\Z BEREKET-AB\PAR DEVELOPMENT\NOF&Cert 9-14-09.doc
Electronic Filing - Received, Clerk's Office, September 14, 2009
