FBI/CG Case File

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 Defense

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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

For a narrative on this private attorney general case brought by Blue Eco Legal Council pursuant to citizen suit provisions of the CWA RCRA, CERCLA, and Public Nuisance against the United States FBI and Coast Guard for its discharge of lead bullets into the Great Lakes, visit our other pages devoted to Coast Guard Live Fire exercises and FBI Firearms Training.

Notice of Intent Coast Guard Notice of Intent FBI	.	.	.	.	.	.	.	.
Blue Eco Complaint	Exhibits-	A	B	C	D	E	F	G
	Table of Exhibits	H	I	J	K	L	M	N
Blue Eco Motion for Preliminary Injunction	Affidavit-	Barton	.	.	.	.	.	.
FBI/CG Combined Response to Prel. Inj. and Motion to Dismiss*	*Attachments-**	1-4	5	6-10	11-15
	Table of Attachments
Blue Eco MTD Response	Exhibit-	1
Blue Eco Prel. Inj. Reply	Exhibits-	1	2	3	4	5	6	7
	Table of Exhibits	8	9	10	11	12
	Affidavits-	Barton1	Barton2	BlueEco	Miller	Pollack
FBI/CG MTD Reply	Attachments-	1-4
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District Court Judge Guzman's Memorandum Dismissing Case
APPEAL - 7th Circuit
Blue Eco Appellate Brief	Appendix
FBI/CG Response Blue Eco Reply Oral Argument (opens 7th Cir. website, you must enter case 08-3857)
7th Circuit Opinion, Manion, Tinder, Cudahy(concurring?)
Blue Eco Petition for Rehearing and Sanctions (denied)
Appeal U.S. Supreme Court Blue Eco Petition for Writ of Certiorari (denied)	Appendix

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.

FBI/CG Case File

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