R-01-99 Approving a Plat of Permanent Utility Easement (Amoco Property at McCarthy Road and Archer Avenue intersection)991 43
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9505/0032 21 001 Page 1 of
1999 -02 -04 11 :0 7 : 31
COOS'. County Recorder
1
ESOLUTION
DATE OF APPROVAL:
RESOLUTION APPROVING A PLAT OF
PERMANENT UTILITY EASEMENT
(Amoco Property at McCarthy Road and Archer Avenue intersection)
1
irti i 111
99118438
WHEREAS, the Village of Lemont has received a Plat of Permanent Utility
Easement , attached as Exhibit "A ", for property known as "Amoco Split Second" located
at the intersection of McCarthy Road and Archer Avenue in Lemont, Illinois which is
legally described on Exhibit A, and
WHEREAS, said Permanent 25' by 30' wide Permanent Easement will permit
the maintenance of a sanitary sewer line; and
WHEREAS, said Permanent 25' wide Permanent Easement will permit the
maintenance of a water main; and
WHEREAS, said Permanent Easement will be granted to the Village of Lemont
following the final inspection and approval of the utility lines.
WHEREAS, the Village of Lemont shall have the right of access across the
premises for the purpose of inspection and maintaining said easements.
NOW THEREFORE, BE IT RESOLVED by the President and Board of
Trustees of the Village of Lemont that the Easement be hereby approved.
PASSED AND APPROVED BY THE PRESIDENT AND BOARD OF
TRUSTEES OF THE VILLAGE OF LEMONT, COUNTIES OF COOK, WILL
AND DuPAGE, ILLINOIS, on this, s) day of w , 1999.
Barbara Buschman
Keith Latz
Connie Markiewicz
Rick Rimbo
Ralph Schobert
Mary Studebaker
AYES NAYS PASSED ABSENT
V
U
SLATDOCUMENT
APPROVED AS TO FORM
1
John P. Anto
0 os, Village Attorney
9911R4:7R ,
,eow 2'1'2
HARLENE M. SMOLLEN, Village Clerk
Approved by me this ,254'^ day of , 1999.
SA
'Ira A. KWASNESKI, Village President
Attest:
,Z.07-e-,ei4( 'bitee-4&--
CHARLENE M. SMOLLEN, Village Clerk
Approved to Form:
7Th
441%
John Antonopoulos, Vill
//MG- 779:
Attorney
V:LLAGE OF LEMONT
418 Main Street
Lemont, IL 60439
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4
IN THE CIRCUIT COURT OF COOK COUNTY, ILLIN(
COUNTY DEPARTMENT, CHANCERY DIVISION
PEOPLE OF THE STATE OF ILLINOIS, )
ex rel. JOHN R. LUMPKIN, )
Director of the Illinois Department )
of Public Health and MARY A. GADE, )
Director of the Illinois )
Environmental Protection Agency, )
Plaintiff, )
v. )
VILLAGE OF LEMONT, an Illinois )
municipal corporation, )
Defendant. )
CONSENT ORDER
No. 96 CH 8041
Plaintiff, the PEOPLE OF THE STATE OF ILLINOIS, by and through
JAMES E. RYAN, Attorney General of the State of Illinois, and ex
rel. JOHN R. LUMPKIN, Director of the Illinois Department of Public
Health and MARY A. GADE, Director of the Illinois Environmental
Protection Agency, and Defendant, VILLAGE OF LEMONT, having agreed
to the entry of this Consent Order, do hereby stipulate and agree as
follows:
I.
STIPULATION OF USE AND AUTHORIZATION
The parties stipulate that this Consent Order is entered into
for purposes of settlement only and that neither the fact that a
party has entered into this Consent Order, nor any of the facts
stipulated herein, shall be used for any purpose in this or any
other proceeding except to enforce the terms hereof by the parties
to this agreement. Notwithstanding the previous sentence, this
Consent Order may be used in any future enforcement action as
1
evidence of a past adjudication for purposes of Section 42(h) of the
Environmental Protection Act ( "Act "), 415 ILCS 5/42(h)(1996). The
undersigned representatives for each party certify that they are
fully authorized by the party whom they represent to enter into the
terms and conditions of this Consent Order and to legally bind them
to it.
II.
STATEMENT OF FACTS
The parties stipulate and agree that the following stipulations
form the factual basis for Section VIII., Final Judgment Order, of
this Consent Order:
A. PARTIES
1. The Attorney General of the State of Illinois brings this
action on his own motion as well as at the request of the Illinois
Department of Public Health ( "IDPH "), and the request of the
Illinois Environmental Protection Agency ( "Illinois EPA "), pursuant
to the statutory authority vested in him under Section 42 of the
Act, 415 ILCS 5/42 (1996).
2. The IDPH is an agency of the State of Illinois authorized
to administer the Illinois Plumbing License Law ( "PLL "), 225 ILCS
320/1 et seq. (1996), formerly known as I11. Rev. Stat., ch. 111,
par. 1101 et seq., and to promulgate a minimum Plumbing Code of
Standards ( "Plumbing Code "), 225 ILCS 320/35 (1996), formerly known
as I11. Rev. Stat., ch. 111, par. 1133.
3. The Illinois EPA is an agency of the State of Illinois
created pursuant to Section 4 of the Act, 415 ILCS 5/4 (1996), and
charged, inter alia, with the duty of enforcing the Act.
2
4. The Village of Lemont ( "Lemont ") is an Illinois municipal
corporation, located in southwest Cook County. Lemont owns and
operates a water supply system and sewage collection system within
its corporate limits. Lemont also provides drinking water to its
residents through its water supply system.
B. ALLEGED VIOLATIONS AND RESPONSE THERETO
Plaintiff has filed a two Count Complaint. Count I alleges
violations of Sections 18 and 40 of the PLL, 225 ILCS 320/18 and 40
(1996), and Sections 890.1150 and 890.1560 of the Plumbing Code, 77
I11. Adm. Code 890.1150 and 890.1560, in that Defendant did not have
a licensed plumber acting as its Plumbing Inspector during the years
1986 to 1988. As a result of this violation of the PLL, numerous
homes constructed during that time in Lemont are not in compliance
with the Plumbing Code. Count II alleges violations of Section 18
of the Act, 415 ILCS 5/18 (1996), and Section 601.101 of the
Illinois Pollution Control Board's ( "Board ") Public Water Supply
Regulations, 35 I11. Adm. Code 601.101. This latter allegation
deals with failure by Defendant to provide water which is assuredly
safe in quality for ordinary domestic consumption.
Lemont has filed a Motion to Dismiss the Complaint, which has
not been heard. Lemont has neither admitted nor denied the
allegations of Plaintiff's Complaint. In the interests of resolving
the dispute between the parties in a manner to foster the best
interests of the people of the State of Illinois and the citizens of
Lemont, the parties have agreed to enter into this settlement. The
parties have further agreed that entry of this Consent Order shall
not constitute a waiver of any defense which may be, or may have
3
been, available to the Defendant, including but not limited to all
matters raised in the Defendant's Motion to Dismiss the Complaint.
C. EXISTING NON - COMPLIANCE
As a result of the parties' cooperative efforts, the current
number of homes subject to the allegations of the Complaint has been
substantially reduced from the original total of 288 residences.
There remain approximately 135 affected homes which are out -of-
compliance or subject to inspection for violations alleged in the
Complaint.
D. AVAILABILITY OF GRANT FUNDS FROM THE STATE OF ILLINOIS
The State of Illinois, through the Illinois EPA, has made
available to Lemont, grant funds in the amount of TWO HUNDRED FIFTY
THOUSAND DOLLARS ($250,000.00), to be used for any of Lemont's costs
associated with the drinking water and wastewater system improve-
ments made necessary by reason of the allegations in the Complaint.
III.
APPLICABILITY
This Consent Order shall apply to and be binding upon the State
of Illinois, Defendant, Defendant's officers, agents and employees,
and the successors and assigns of each and every officer, agency and
employee of Defendant. Defendant shall not raise as a defense to
any action to enforce this Consent Order, the failure of any of its
officers, agents, servants or employees to take such action as shall
be required to comply with the provisions of this Consent Order.
IV.
COMPLIANCE WITH OTHER LAWS AND REGULATIONS
This Consent Order in no way affects the responsibilities of
4
Defendant to comply with any other federal, state or local laws and
regulations, including but not limited to the Plumbing License Law,
225 ILCS 320/1 et seq. (1996), the Illinois Plumbing Code, 77 I11.
Adm. Code 890.110 et seq., the Environmental Protection Act, 415
ILCS 5/1 et seq. (1996), and the Illinois Pollution Control Board's
Rules and Regulations, 35 I11. Adm. Code Subtitles A through H.
V.
NONADMISSION
Agreement to this Consent Order shall not constitute an
admission by Defendant of any violation of any federal, state or
local statute or regulation or rule of any kind.
VI.
VENUE
The parties agree that the venue of any action commenced in
Circuit Court for the purposes of interpretation, implementation and
enforcement of the terms and conditions of this Consent Order shall
be in Cook County, Illinois.
VII.
SEVERABILITY
It is the intent of the parties hereto that the provisions of
this Consent Order shall be severable, and if any provisions be
declared by a court of competent jurisdiction to be inconsistent
with state or federal law, and therefore unenforceable, the
remaining clauses shall remain in full force and effect. In the
event that any provision of this Consent Order shall be declared
inconsistent with the provisions of the PLL, 225 ILCS 320/1 et seq.
(1996), or the Act, 415 ILCS 5/1 et seq. (1996), the provisions of
5
the PLL or the Act shall be controlling.
VIII.
FINAL JUDGMENT ORDER
NOW THEREFORE, pursuant to the foregoing stipulations by the
parties, this Court having jurisdiction over the parties and subject
matter, the Court having considered the stipulations and being
advised in the premises, the Court finds the following relief
appropriate:
IT IS HEREBY ORDERED, ADJUDGED AND DECREED:
A. JURISDICTION
This court has jurisdiction of the subject matter herein and of
the parties consenting hereto.
B. OBJECTIVE
The objective of this Consent Order is to have an enforceable
order which will assure the protection of public health, safety,
welfare and the environment, and assure compliance with the
applicable provisions of the PLL, the Plumbing Code, the Act and the
Board Regulations promulgated thereunder. The parties agree that
time is of the essence for compliance hereunder.
C. COMPLIANCE PLAN
1. INDEPENDENT LICENSED PLUMBING INSPECTOR:
Within ninety (90) days after the entry of this Consent Order,
Defendant shall provide a licensed plumbing inspector or inspectors,
approved by the Illinois Department of Public Health, to conduct the
various inspections provided for herein, to oversee the corrective
action plan as outlined herein and to certify compliance hereunder.
Defendant's costs associated with providing such licensed plumbing
6
inspector or inspectors for purposes of this Consent Order shall be
reimbursable from the State grant funds noted above in Section II.
D. of this Consent Order. Notwithstanding this paragraph, the
Plaintiff reserves its inspection rights as authorized by law and as
provided in Section VIII., K., of this Consent Order.
2. NOTIFICATION:
Within forty -five (45) days of the entry of this Consent Order,
Defendant shall notify each Lemont homeowner whose property is
subject to the terms of this Consent Order eg. those which have
violations of the water /sewer separation requirements of the
Plumbing Code and the Illinois EPA Technical Policy Statements, or
those which have not been inspected for compliance with same, of the
general contents of the Consent Order. Defendant shall advise each
homeowner that all water /sewer separation violations shall be
corrected at no expense to the homeowner.
3. CORRECTIVE ACTION:
a. KNOWN VIOLATIONS:
i. Defendant shall engage the services of a
licensed plumbing contractor or contractors ( "contractor "), approved
by the Illinois Department of Public Health, to perform the
following scope of work and require said contractor or contractors
to make the following scope of work commitments to the appropriate
property owners where previous inspections have determined a
violation:
1. Contractor shall cause all water, sewer
and /or building drain service lines between the
buffalo box and the home to be separated
horizontally by a minimum of ten (10) feet, or
the water service line to be separated
vertically a minimum of eighteen (18) inches
7
above the building drain and sewer service
line; that any building drain or sewer service
line shall be constructed in accordance with
the Plumbing Code and the Illinois EPA
Technical Policy Statements;
2. Contractor shall cause sleeves to be
installed where necessary to protect the water
service line in accordance with the Plumbing
Code and the Illinois EPA Technical Policy
Statements;
3. Contractor shall cause any landscaping
which is damaged as a result of above - ground
work to be replaced as close to its original
state as possible;
4. Contractor shall take photographs, both
before commencement and after completing the
work, of the landscape, grounds, interior
sections where work was done and any other
additional work required for compliance;
5. The completed work shall be inspected for
a Certification of Compliance by the licensed
plumbing inspector provided for above.
ii. Once a homeowner agrees to permit the work to
proceed, all work shall be completed and a final inspection shall be
made, within one (1) year of the homeowner's authorization to
proceed. Upon a satisfactory final inspection, a Certificate of
Compliance shall issue pursuant to Section VIII. C. 4. of this
Consent Order.
iii. In the event a property owner, after not less
than two contacts by Defendant and /or Contractor and two refusals by
the property owner, refuses to allow Defendant and /or Contractor to
perform work which will result in compliance under this Consent
Order, then Defendant, within 90 days from the last refusal, shall
take all lawful actions, and institute any necessary proceedings
under this Consent Order to cause the water service to said property
to be disconnected.
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b. INSPECTIONS REOUIRED:
i. For property which is subject to this Consent
Order, but which has not been previously inspected, Defendant shall
schedule an inspection for each property within one hundred twenty
(120) days of the entry of this Consent Order. In the event a
property owner, after not less than two contacts by Defendant and
two refusals by the property owner, refuses to allow Defendant to
perform an inspection, then Defendant, within 90 days from the last
refusal, shall take all lawful actions, and institute any necessary
proceedings under this Consent Order to cause the water service to
said property to be disconnected.
ii. In the event that the inspection reveals
violations, then Defendant shall proceed in accordance with Section
VIII. C. 3. a. ( "Known Violations ") of this Consent Order.
iii. In the event that no violation is found, then a
Certificate of Compliance shall be issued pursuant to Section VIII.
C. 4. of this Consent Order.
4. CERTIFICATION OF COMPLIANCE:
Within ten (10) business days of the final inspection of each
property, Defendant shall provide the Illinois EPA and IDPH with a
copy of the Certification of Compliance for each property corrected
and copies of the photographs taken pursuant to Section VIII. C. 3.
of this Consent Order. Defendant shall record the Certification of
Compliance with the water /sewer regulations with the Cook County
Recorder of Deeds and send copies of the recorded certification to
the property owner, the Illinois Attorney General, the Illinois EPA
and the IDPH. Plaintiff reserves the right to rebut Defendant's
9
issuance of any Certification of Compliance consistent with the
provisions of this Consent Order.
5. FINAL REPORT:
Within two (2) years after the entry of this Consent Order,
Defendant shall certify to Plaintiff that all compliance work
required under this Consent Order has been completed.
D. STIPULATED PENALTIES
1. In the event Defendant fails to meet the deadlines for
the Final Compliance Report set forth in Section VIII., C., 5. of
this Consent Order, Defendant shall pay a stipulated penalty of ONE
THOUSAND ($1,000.00) DOLLARS per week, or any portion thereof, until
the required Final Compliance Report is submitted to Plaintiff.
Interest shall accrue on any unpaid portions as provided below.
2. In the event Defendant fails to meet any other deadline
set forth in Section VIII., C. of this Consent Order, Defendant
shall pay a stipulated penalty of FIVE THOUSAND ($5,000.00) DOLLARS
per month, or any portion thereof, until such deadline is met.
Interest shall accrue on any unpaid portions as provided below.
3. Payment of any stipulated penalties under this Section is
due within THIRTY (30) days of the missed deadline. One -half (1/2)
of the payment shall be made to the Treasurer of the State of
Illinois for deposit in the Plumbing Licensure and Program Fund and
delivered to:
Illinois Department of Public Health
P.O. Box 4263
Springfield, IL. 62708
The remaining one -half (1/2) of the payment shall be made to the
Treasurer of the State of Illinois for deposit in the Environmental
10
Protection Trust Fund and delivered to:
Illinois Environmental Protection Agency
Fiscal Services Division
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794 -9276
The name and number of the case and Defendant's Federal Employer
Identification Number ( "FEIN ") 36- 6005968 shall appear on the
face of each check.
4. For purposes of payment of stipulated penalties, any
interest due and collection thereof, Defendant may be reached at the
following address:
Village Administrator
Village of Lemont
418 Main Street
Lemont, IL. 60439 -3788
E. INTEREST
Pursuant to Section 42(g) of the Act, 415 ILCS 5/42(g) (1996),
interest shall accrue on any payment amount not paid within the time
prescribed herein, at the maximum rate allowable under Section
1003(a) of the Illinois Income Tax Act, 35 ILCS 5/1003(a) (1996):
1. Interest on unpaid payments shall begin to accrue from
the date the payment is due and continue to accrue to the date
payment is received;
2. Where partial payment is made on any payment amount that
is due, such partial payment shall be first applied to any interest
on unpaid amounts then owing;
3. All interest on payments owed Plaintiff, shall be paid by
check. One -half (1/2) of the interest payment shall be made to the
Treasurer of the State of Illinois for deposit in the Plumbing
Licensure and Program Fund and delivered to:
11
Illinois Department of Public Health
P.O. Box 4263
Springfield, IL. 62708
The remaining one -half (1/2) of the interest payment shall be made
to the Treasurer of the State of Illinois for deposit in the
Environmental Protection Trust Fund and delivered to:
Illinois Environmental Protection Agency
Fiscal Services Division
2200 Churchill Road
P.O. Box 19276
Springfield, IL 62794 -9276
The name and number of the case and Defendant's Federal Employer
Identification Number ( "FEIN ") 36- 5005968
shall appear on the
face of each check.
F. FUTURE COMPLIANCE
1. Defendant shall comply with Sections 18 and 40 of the
PLL, 225 ILCS 320/18 and 40 (1996), and Sections 890.1150 and
890.1560 of the Plumbing Code, 77 I11. Adm. Code 890.1150 and
890.1560.
2. Defendant shall comply with Section 18 of the Act, 415
ILCS 5/18 (1996), and Section 601.101 of the Board Public Water
Supply Regulations, 35 I11. Adm. Code 601.101.
3. Defendant shall comply with the PLL, 225 ILCS 320/1 et
seq. (1996), the Illinois Plumbing Code, 77 I11. Adm. Code 890.110
et seq., the Act, 415 ILCS 5/1 et seq. (1996), and the Board's Rules
and Regulations, 35 I11. Adm. Code Subtitles A through H.
G. FORCE MAJEURE
1. Should Defendant be unable to complete any part of the
work in accordance with this Consent Order as a result of
circumstances not within the reasonable control of Defendant,
12
Defendant shall notify the Plaintiff as soon as practicable, but no
later than fifteen (15) calendar days of becoming aware of the
apparent non - compliance. Such notification shall be in writing and
shall include a precise description of the circumstances, the
measures to be taken to prevent or minimize the delay and the
revised timetable to reflect the anticipated delay.
2. If the parties agree that an extension is warranted,
because the delay was caused through circumstances beyond the
control of Defendant, the parties, by written agreement, may extend
the time for performance hereunder for a period equal to the delay
resulting from such circumstances, and the affected deadlines herein
will be adjusted accordingly.
3. If the parties cannot agree whether the reasons for the
delay were beyond the reasonable control of Defendant, the matter
shall be resolved by this Court, pursuant to the Dispute Resolution
provisions which follow under Section VIII. H. of this Consent
Order. Defendant shall have the burden of going forward and proving
by a preponderance of the evidence that the circumstances alleged to
be causing the delay were beyond its reasonable control.
H. DISPUTE RESOLUTION
1. Any dispute which arises with respect to the meaning,
application, or interpretation of this Consent Order, including any
dispute whatsoever related to any Certificate of Compliance, report,
submission, notice or agreement required hereunder, or with respect
to any party's compliance herewith, shall in the first instance be
the subject of informal negotiations. If the parties cannot resolve
the dispute within thirty (30) calendar days, it shall be presented
13
to the Court for appropriate resolution upon written notice by any
party. The period for negotiations may be extended by mutual
agreement among the Parties. Unless the Plaintiff is seeking
interpretation or enforcement of this Order, Defendant shall file
the documents necessary to notify the Court of the dispute, and
thereafter the Court shall order the parties to file such pleadings
as the Court deems necessary and proper. If interpretation or
enforcement of the Order is sought by the Plaintiff, the Illinois
Attorney General's Office shall have the responsibility of filing
the necessary papers.
2. Defendant shall file any petition with the Court within
thirty (30) calendar days after the informal negotiation period (or
any extension) has expired, and, where the Plaintiff has the
responsibility of filing, the Plaintiff shall petition the Court
within thirty (30) calendar days after the expiration of the
informal negotiation period (or any extension). When it is movant,
Defendant shall have the burden of establishing by a preponderance
of the evidence that its position is in compliance with the terms
and objectives of this Consent Order. When it is movant, the
Plaintiff shall have the burden of establishing by a preponderance
of the evidence that its position is in compliance with the terms
and objectives of this Consent Order.
3. The invocation of dispute resolution, in and of itself,
shall not excuse compliance with any deadline contained herein.
I. NOTICE
Any notices required under this Consent Order shall be
submitted as follows:
14
For Plaintiff:
Christine S. Bucko, AAG
Environmental Bureau
Illinois Attorney General
100 W. Randolph, llth Flr.
Chicago, IL 60601
John G. Abrell, Legal Services
Illinois DPH
535 W. Jefferson, 5th Flr.
Springfield, IL 62761
For Defendant:
Village Administrator
Village of Lemont
418 Main Street
Lemont, IL. 60439 -3788
Stephen C. Ewart
Deputy Counsel
IEPA
1021 N. Grand Ave. East
P.O. Box 19276
Springfield, IL 62794 -9276
Nicholas E. Sakellariou
Robbins, Schwartz, Nicholas,
Lifton & Taylor, Ltd.
116 N. Chicago Street
Joliet, IL. 60432
J. DISCHARGE OF LIABILITY
In consideration of Defendant's commitment to undertake the
corrective action work described herein and commitment to comply
with the PLL, 225 ILCS 320/1 et seq. (1996), the Plumbing Code, 77
I11. Adm. Code 890.110 et seq., the Act, 415 ILCS 5/1 et seq.
(1996), and the Board's Rules and Regulations, 35 I11. Adm. Code
Subtitles A through H, the Plaintiff shall release, waive and
discharge Defendant from any further liability or penalties from
violations which were the subject matter of the Complaint, upon
compliance by Defendant of all requirements set forth in Section
VIII. of this Order. However, nothing in this Consent Order shall
be construed as a waiver by the Plaintiff of the right to collect
stipulated penalties and interest provided in Section VIII. D. and
E. of this Consent Order or to redress any future violations of the
PLL, 225 ILCS 320/1 et seq. (1996), the Plumbing Code, 77 I11. Adm.
Code 890.110 et seq., the Act, 415 ILCS 5/1 et seq. (1996), and the
Board's Rules and Regulations, 35 I11. Adm. Code Subtitles A through
15
H, or this Consent Order, or to obtain penalties with respect
thereto.
K. RIGHT OF ENTRY
In addition to any other authority at law, IDPH, its employees
and representatives, the Illinois EPA, its employees and
representatives, and the Illinois Attorney General, his agents and
representatives, by presentation of appropriate credentials, shall
have the right of entry to any property areas where Defendant has
been authorized to perform compliance work hereunder at all
reasonable times, for the purposes of conducting inspections. In
conducting any such inspection, IDPH, its employees and
representatives, the Illinois EPA, its employees and
representatives, and the Attorney General, his agents and
representatives, may take any photographs or samples as they deem
necessary in order to conduct their inspection.
L. RETENTION OF JURISDICTION
This Court shall retain jurisdiction over this matter for
purposes of amending, interpreting, implementing and enforcing the
terms and conditions of this Consent Order.
M. ENFORCEMENT OF CONSENT ORDER
Following the entry of this Consent Order, any party hereto may
move this Court to enforce the terms and conditions of this Consent
Order. This Consent Order is a binding and enforceable Order of the
Court and may be enforced as such through any and all available
means.
16
WHEREFORE, the parties, by their representatives, enter into
this Consent Order and submit it to the Court that it may be
approved and entered.
AGREED TO:
PEOPLE OF THE STATE OF ILLINOIS,
ex rel. JAMES E. RYAN
Attorney General of the
State of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/
Asbestos Litigation Division
BY :. ) I I IAA,
AGREED TO:
VILLAGE OF LEMONT
WILLIAM D. SEITH, Chie
Environmental Bureau
Assistant Attorney General
DATED: All, 1 41
ILLINOIS DEPARTMENT OF PUBLIC HEALTH
BY:
n R. Lumpkin, VM,D.
btrector of Public Health
DATED: - G y Ct
d A. Kwasneski, M
DATED:
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
SEPH . SVOBODA
neral Counsel
'vision of Legal Counsel
BY:
DATED:
E N T E R E D
BY:
N R'
FEB 1 (3 1999
JUDG$.ESTE
17
DATED:
\lemont \cd6
i
ROBBINS, SCHWARTZ, NICHOLAS, LIPTON & TAYLOR, LTD.
A T T O R N E Y S
20 NORTH CLARK
SUITE 900
CHICAGO, ILLINOIS 60602
312- 332 -7760
FAx 312 - 332 -7768
rsnit @interaccess.com
420 Mn.LUCIN COURT
DECATUR, Tumors 62523
217 -428 -2100
FAx 217 -428 -2186
NICHOLAS E. SAKELLARIOU
Joliet Office
March 11, 1999
Mr. Steve Jones
Village Administrator
Village of Lemont
418 Main Street
Lemont, Illinois 60439
116 NORTH CHICAGO STREET
JOLIET, ILLINOIS 60432
815 - 722 -6560
FAx 815 - 726 -2605
105 EMERALD
P.O. Box 758
CARBONDALE, ILLINOIS 62901
618 - 549 -5582
FAx 618- 549 -5584
205 SOUTH RANDOLPH STREET
MACOMB, ILLINOIS 61455
309 - 837 -5055
FAX 309 -833 -5575
Re: People v. Village of Lemont
Dear Steve:
Enclosed for your files is a copy of the Consent Order as filed in court. With a sigh, I believe that
the legal work in this matter is concluded.
If you have any questions, please call.
Very truly yours,
ROBBINS, SCHWARTZ, NICHOLAS,
LIFTON & TAYLOR, LTD.
_7
By: <Chola E. Sakellariou
NES /coj
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