FBI/CoastGuard Complaint

> FBI/CoastGuard Complaint

UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

Steven B. Pollack and Blue Eco Legal Council

U.S. Department of Justice,

U.S. Coast Guard

U.S. Navy

U.S. Marines

U.S. Department of Justice

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Case Number: 08-cv-320
Assigned Judge: Guzman
Magistrate Judge: Brown

CWA, RCRA, CERCLA, AND
PUBLIC NUISANCE FTCA CASE

Hyperlinked Case Documents

Notice of Intent Coast Guard Notice of Intent FBI	.	.	.	.	.	.	.	.
Complaint	Exhibits-	A	B	C	D	E	F	G
	Table of Exhibits	H	I	J	K	L	M	N
Pl.Motion for preliminary injunction	Affidavit-	Barton	.	.	.	.	.	.
Def. Response*	*Attachments-**	1-4	5	6-10	11-15
	Table of Attachments
Pl. Reply	Exhibits-	1	2	3	4	5	6	7
	Table of Exhibits	8	9	10	11	12
	Affidavits-	Barton1	Barton2	BlueEco	Miller	Pollack

Def.Motion to dismiss*	Attachments*	1-4	5	6-10	11-15	.	.	.
Pl. Response	Exhibit	1
Def. Reply	Attachments	1-4
*Defendants filed combined motion to dismiss and response to motion for preliminary injunction.

COMPLAINT

1. Plaintiffs bring suit as private attorneys general under the citizen suit provisions of the CWA, RCRA, and CERCLA, and for tort damages under the Federal Tort Claims Act, against the President, for discarding lead bullets onto state owned lakebeds which are held in trust for the public, and thereby damaging natural resources and the public water supply. The accumulation of these discharges over 90 years has created an imminent and substantial endangerment for which Plaintiffs ask this Court to use its broad statutory powers to order Defendants to stop discharging lead bullets onto state owned lakebeds and into the Nation’s waters, order Defendants to pay $35.2 million to assess and remove the hazardous material in Lake Michigan at the FBI facility in North Chicago, and order Defendants to compensate the public for damage to natural resources with a Supplemental Environmental Project in the amount of $20 million.