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0:21-cv-02053-SAL Date Filed 12/29/21 Entry Number 27 Page 1 of 2
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF SOUTH CAROLINA
`ROCK HILL DIVISION
`
` ___________________________________
`
`
`
`
` )
` UNITED STATES OF AMERICA, )
`
`
`
`
`
`
` ) C/A No.: 0:21-cv-02053-SAL
`
`
`
` Plaintiff,
` )
`
`
`
`
`
`
` ) NOTICE OF LODGING OF CONSENT
`
`
`
`v.
`
`
` ) DECREE
`
`
`
`
`
`
` ) AND
` NEW INDY CATAWBA, LLC,
` ) REQUEST THAT THE COURT TAKE
`
`
`
`
`
`
` ) NO ACTION UNTIL A MOTION FOR
`
`
`
` Defendant.
` ) ENTRY IS FILED
` ___________________________________)
`
`
`
`
`The United States of America respectfully lodges with the Court a proposed Consent
`
`Decree. Exhibit 1.
`
`
`
`The proposed Consent Decree is contingent upon a public comment period, so the United
`
`States requests that the Court not sign the Consent Decree until the United States files a Motion
`
`for Entry. Pursuant to Paragraph 81 of the proposed Consent Decree, and in accordance with the
`
`procedures of 28 C.F.R. § 50.7, the public will have 30 days in which to submit comments to the
`
`United States Department of Justice on the proposed Consent Decree. The 30-day period will begin
`
`on the date notice of the lodging of the proposed Consent Decree is published in the Federal
`
`Register. If, after reviewing the public comments, the Department of Justice concludes that the
`
`proposed Consent Decree should be entered, the United States will inform the Court of any public
`
`comments received and any responses thereto and will move for entry of the Consent Decree as a
`
`final order of the Court.
`
`
`
`Plaintiff therefore respectfully requests that this Court receive the proposed Decree for
`
`lodging only and that it abstain from acting upon the Consent Decree until the period for public
`
`
`
`
`1
`
`

`

`0:21-cv-02053-SAL Date Filed 12/29/21 Entry Number 27 Page 2 of 2
`
`comment has expired and the Plaintiff has moved for entry of the proposed Consent Decree.
`
`
`
`
`
`
`
`
`
` Respectfully submitted,
`
`
` COREY F. ELLIS
` UNITED STATES ATTORNEY
`
` By: /s/ Johanna Valenzuela
` Johanna C. Valenzuela
` Assistant United States Attorney
` Federal Bar No. 11130
` United States Attorney’s Office
` District of South Carolina
` Telephone: (803) 929-3122
` E-mail: johanna.valenzuela@usdoj.gov
`
` TODD KIM
` Assistant Attorney General
`
` STEVEN O’ROURKE
` Environmental Enforcement Section
` Environment and Natural Resources Division
` U.S. Department of Justice
` P.O. Box 7611 Washington, D.C. 20044-7611
` (202) 514 2779
` Mass. Bar # 565493
` steve.orourke@usdoj.gov
`
` OF COUNSEL:
`
` Marirose J. Pratt
` Associate Regional Counsel
` U.S. Environmental Protection Agency, Region 4
`December 29, 2021
`
`
`
`
`
`
`2
`
`
`
`
`
`
`

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