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COMMONWEALTH OF MASSACHUSETTS,
Plaintiff,
v. COMPLAINT
INTRODUCTION
1. From 2001 to the present, Russell and Karen Mehl ("the Mehls") altered or
destroyed more than 3,400 linear feet of stream bank and approximately five acres of bordering
2. The Mehls clear-cut approximately 27 acres of forest and filled and graded the
property—including stream bank and wetlands—using 14,423 cubic yards of aluminum oxide
fill disposed of at the site by the Mehls, Truck Crane Service, Inc. ("TCS"), and Micro Abrasives
Corp. ("Micro Abrasives"), and other solid waste disposed of at the site by the Mehls and
Legend Lawn Care, Inc. ("Legend"), in violation of the Solid Waste Act, G.L. c. Ill, § 150A
3. The Commonwealth seeks an order (1) enjoining the Mehls from further
alterations or filling of the wetlands and stream bank; (2) enjoining the Mehls, TCS, Micro
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Abrasives, and Legend from further disposal of solid waste at the property; (3) requiring the
Mehls, TCS, Micro Abrasives, and Legend to pay civil penalties for the violations; and (4)
requiring the Mehls, TCS, Micro Abrasives, and Legend to remove the aluminum oxide fill and
other solid waste and restore the altered wetlands and streams to their former condition.
4. This court has jurisdiction over the subject matter of this action and the authority
to grant the relief requested pursuant to G.L. c. 131, § 40 and G.L. c. 111, § 150A. Venue lies in
PARTIES
6. The Attorney General, with her principal office at One Ashburton Place, Boston,
Massachusetts, is the Chief Legal Officer of the Commonwealth and is authorized to bring this
enforcing the Commonwealth's environmental laws. MassDEP maintains its principal offices at
9. Russell A. Mehl, Jr., is the owner and registered agent of Legend and the co-
owner of 514 Blandford Road in Russell, Massachusetts. He resides at 514 Blandford Road in
Russell, Massachusetts.
10. Karen L. Mehl is the co-owner of 514 Blandford Road in Russell, Massachusetts.
13. The WPA and its implementing regulations, 310 C.M.R. 10.00 et seq., safeguard
the Commonwealth's wetland resources. Wetlands provide valuable habitats for wildlife, natural
management and filtration of groundwater and drinking water supplies, and protection against
flooding and storm damage, among other benefits. The WPA and its implementing regulations
protect these benefits by requiring public review of any proposed activity that will remove, fill,
dredge, or alter the Commonwealth's wetlands or any area within a 100-foot "buffer zone" of a
wetland.
14. The SWA and its implementing regulations, 310 C.M.R. 16.00 et seq. and 19.00
et seq., regulate the siting and operation of solid waste disposal sites in the Commonwealth. The
SWA prohibits the establishment, expansion, and operation of a solid waste disposal facility
without a site-assignment from the local Board of Health and a valid permit from MassDEP. The
SWA also generally prohibits the disposal of solid waste outside of permitted solid waste
disposal facilities. The SWA's regulations do provide for the use or disposition of solid waste
outside of solid waste disposal facilities in certain circumstances, if done in accordance with the
FACTS
15. On September 25, 2001, the Mehls purchased 514 Blandford Road in Russell,
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16. The Mehl Property is a large, roughly square parcel of more than 100 acres.
Blandford Road, the Massachusetts Turnpike, and Potash Brook bound the Mehl Property to the
south. Other wooded parcels of private land bound the Mehl Property to the west, north, and east.
The Mehl Property generally slopes downward from north to south. A home, garage, and several
outbuildings are located in the property's southeastern comer. The Mehl Property is and has been
17. The Mehl Property was mostly wooded when the Mehls purchased it in 2001.
Two unnamed intermittent streams ("Western Stream" and "Eastern Stream") ran north to south
in roughly parallel channels in the central portion of the Mehl Property. The Eastern and Western
Streams discharged into Potash Brook immediately to the south of the Mehl Property. Potash
Brook discharges into the Westfield River about a mile to the east of the Mehl Property.
designated Potash Brook a Coldwater Fish Resource (stream identification number 3209725).
Coldwater Fish Resources are habitats for trout and other coldwater fish and are particularly
sensitive to changes in land and water use. MassWildlife stocks Potash Brook with trout for the
public to catch. MassWildlife also stocks the Westfield River, which is also a Coldwater Fish
19. The Mehl Property also included land bordering on the banks of the Eastern and
Western Streams that exhibited saturated and/or inundated soils and a predominance of wetland
20. The Mehls have never applied for and the Russell Board of Health has never
issued a site assignment allowing the Mehls to maintain or operate a solid waste disposal facility
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21. The Mehls have never applied for and MassDEP has never issued a permit
allowing the Mehls to operate or maintain a solid waste disposal facility at the Mehl Property.
Micro Abrasives's and TCS's Beneficial Use Determinations for Micro Abrasives's Flocced
Aluminum Oxide
22. Micro Abrasives designs, manufactures, and sells abrasive powders for
oxide, consisting of aluminum oxide powder that is too fine for use in Micro Abrasives's
24. In October 1998, Micro Abrasives applied for a Beneficial Use Determination
from MassDEP for the flocced aluminum oxide, requesting permission to stockpile the flocced
aluminum oxide on Micro Abrasives's property until it could be sold to other manufacturers.
Abrasives ("Micro Abrasives BUD"), allowing Micro Abrasives to store the flocced aluminum
26. Consistent with regulations, the Micro Abrasives BUD allows Micro Abrasives to
store the flocced aluminum oxide only "in such a manner that it does not become a solid waste."
27. In or about early 2001, Micro Abrasives and TCS—a demolition, excavation, and
trucking company-—agreed that TCS would produce sub-grade fill material using Micro
28. On July 17, 2001, TCS applied for a Beneficial Use Determination, proposing to
use Micro Abrasives's flocced aluminum oxide to produce aluminum oxide fill.
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29. On October 12, 2001, MassDEP issued a Beneficial Use Determination to TCS
("TCS BUD"), allowing TCS to mix the flocced aluminum oxide from Micro Abrasives with
bank run sand at a gravel pit at Boisseau Farm in Westfield, to produce the aluminum oxide fill.
30. Consistent with regulations, the TCS BUD states that the flocced aluminum oxide
"is NOT classified as solid waste ONLY when it is used in accordance with the requirements set
forth in this determination. The material shall not be handled or utilized in a manner that will
result in the material becoming a solid waste." (Emphasis original.) The TCS BUD also states,
consistent with regulations, that the beneficial use of the flocced aluminum oxide must be in
compliance with other applicable state and federal laws and regulations.
31. TCS began producing aluminum oxide fill using flocced aluminum oxide from
Micro Abrasives pursuant to the TCS BUD in 2001 and continued through 2016.
32. In or about the spring of 2003, the Mehls approached TCS, looking for
33. TCS and the Mehls agreed that TCS would provide aluminum oxide fill to the
34. From 2003 through at least 2014, TCS delivered at least 14,423 cubic yards of the
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Year Aluminum Oxide Fill
Delivered by TCS to the Mehl Property
(cubic yards)
2010 1,677
2011 1,341
2012 2,246
2013 3,555
2014 465
Total 14,423
35. At all relevant times, Micro Abrasives knew that TCS was delivering the
36. The aluminum oxide fill remains in place on the Mehl Property.
37. From 2003 through at least 2014, TCS delivered and the Mehls used the
aluminum oxide fill at the residentially-zoned Mehl Property, without first notifying the Russell
38. From 2002 through 2017, TCS and Micro Abrasives produced the aluminum
oxide fill at Micro Abrasives's facility in Westfield, Massachusetts, rather than at the Boisseau
Farm gravel pit, in violation of the terms of the TCS BUD and the Micro Abrasives BUD.
39. From 2008 through at least 2014, TCS added wood chips and sawdust obtained
from lumber yards to the aluminum oxide fill mix, rather than only clean, bank run sand, in
40. For the years 2002 through 2007, TCS failed to submit annual summary reports to
41. When TCS submitted annual summary reports to MassDEP for the years 2008
through 2014, TCS failed to submit the reports by February 15 of the following year and instead
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submitted them between roughly three weeks and three months late each year, in violation of the
42. In the report submitted to MassDEP for 2008, TCS failed to state the amount of
aluminum oxide fill it distributed that year, in violation of the terms of the TCS BUD and
regulations.
Illegal Dumping of Additional Solid Waste at the Mehl Property by Legend and the Mehls
43. The Mehls dumped or allowed the dumping of construction and demolition debris
at the Mehl Property between 2001 and 2017, including oversized and reinforced concrete
rubble, painted concrete, concrete patio and wall blocks, ceramic tile, painted window frames,
44. The Mehls and Legend also dumped leaf and yard waste and other debris at the
Mehl Property between 2001 and 2017 that Legend removed from the properties of its
customers. The Mehl Property was not registered with the Department of Agricultural Resources
45. The Mehls also dumped or allowed the dumping of scrap metals, plastic, tires, a
mattress, and other waste ("other waste materials") at the Mehl Property between 2001 and 2017.
The Mehls' Illegal Filling and Alteration of Bordering Vegetated Wetlands, Stream Banks, and
Associated Buffer Zones
46. Between 2001 and 2017, the Mehls clear-cut trees and other vegetation from
approximately 27 acres of the Mehl Property, in the central portion of the property.
47. Between 2003 and 2017, the Mehls and Legend filled and graded those 27 acres
using the aluminum oxide fill provided by TCS and Micro Abrasives and the materials described
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48. The Mehls and Legend built up a large area in the center of the Mehl Property,
using the aluminum oxide fill and materials described in paragraphs 43 through 45, piled up to
thirty feet deep in the south-central portion of the property, to lessen the natural slope of the land.
49. The clear-cut, filled, and graded 27 acres included portions of the Bordering
Vegetated Wetlands along the banks of the Eastern and Western Streams, described in paragraph
19.
50. The clear-cut, filled, and graded 27 acres also included areas within 100 feet of
51. The Mehls' and Legend's clear-cutting, filling, and grading of portions of the
Bordering Vegetated Wetlands and Wetlands Buffer Zone destroyed wildlife habitat and
vegetation and changed water levels, drainage characteristics, and sedimentation and flow
52. The clear-cut, filled, and graded 27 acres also included portions of the banks of
the Eastern and Western Streams and areas within 100 feet of the banks of the Eastern and
53. In addition to clearing, filling, and grading portions of the Stream Bank Buffer
Zone, the Mehls and Legend removed trees and other vegetation from, dumped the aluminum
oxide fill and materials described in paragraphs 43 through 45 onto, and installed road crossings
54. These activities destroyed wildlife habitat and vegetation and changed drainage
approximately 3,466 linear feet of the banks of the Eastern and Western Streams, thereby
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changing the physical, biological and chemical characteristics of the receiving water (i.e.. Potash
Brook).
55. The Mehls and Legend failed to submit a Notice of Intent or a Request for a
undertaking these activities in the Bordering Vegetated Wetlands, the Wetlands Buffer Zone, the
banks of the Eastern and Western Streams, and the Stream Bank Buffer Zone.
56. The Mehls and Legend have not restored the Bordering Vegetated Wetlands, the
Wetlands Buffer Zone, the banks of the Eastern and Western Streams, or the Stream Bank Buffer
57. The aluminum oxide fill and the materials described in paragraphs 43 through 45
placed in the Bordering Vegetated Wetlands, the Wetlands Buffer Zone, on and over the banks
of the Eastern and Western Streams, and in Stream Bank Buffer Zone remains in place.
CAUSES OF ACTION
58. The Commonwealth realleges the allegations set forth in paragraphs 1 through 57.
59. The WPA and its implementing regulations, 310 C.M.R. 10.00 et seq., provide
that no person shall remove, fill, dredge, or alter areas subject to protection under the WPA (with
certain exemptions, not relevant here) without first filing a Notice of Intent with and receiving
60. Areas subject to the protection of the WPA and its regulations include banks and
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61. The WPA's implementing regulations also require that all activities conducted
within a "buffer zone" that will alter areas subject to protection under the WPA (with certain
exemptions, not relevant here) require the filing of a Notice of Intent. 310 C.M.R. 10.02(2)(b).
The "buffer zone" is an area within 100 feet of an area subject to protection by the WPA. Id.
62. The WPA also provides that no person will cause, suffer, or allow the removal,
filling, dredging, or alteration of areas subject to protection under the WPA without required
63. Likewise, the WPA provides that no person will leave unauthorized fill in place or
64. The WPA specifically provides that this Court may restrain violations of the WPA
and may enter such orders as it deems necessary to remedy the violations, including orders to
65. The WPA also states that any person who violates any provision of the WPA shall
be subject to a maximum civil penalty of twenty-five thousand dollars ($25,000) per violation
66. The Commonwealth realleges the allegations set forth in paragraphs 1 through 65.
67. The Mehls, Legend, TCS, and Micro Abrasives are "person[s]," as the WPA
68. The Eastern and Western Streams are "stream[s]," as 310 C.M.R. 10.04 defines
that term.
69. The banks of the Eastern and Western Streams are "bank[s]," as 310 C.M.R.
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70. The banks of the Eastern and Western Streams "border[]" on the Eastern and
71. The banks of the Eastern and Western Streams are "areas subject to protection
72. The Stream Bank Buffer Zone is a "buffer zone," as defined by 310 C.M.R.
10.02(2)(b).
73. By removing trees and other vegetation from the banks of the Eastern and
Western Streams and the Stream Bank Buffer Zone, the Mehls "alter[ed]" the banks of the
Eastern and Western Streams, as 310 C.M.R. 10.04 defines that term.
74. By dumping aluminum oxide fill and the materials described in paragraphs 43
through 45 onto the banks of the Eastern and Western Streams and the Stream Bank Buffer
Zone, thereby changing their drainage characteristics, sedimentation and flow patterns, and
surface water characteristics, the Mehls and Legend "filljed]" and "alter[ed]" the banks of the
Eastern and Western Streams, as 310 C.M.R. 10.04 define those terms.
75. By installing road crossings across the banks of the Eastern and Western Streams,
thereby changing their drainage characteristics, sedimentation and flow patterns, and surface
water characteristics, the Mehls "alter[ed]" the banks of the Eastern and Western Streams, as 310
76. By delivering aluminum oxide fill at the Mehl Property for the Mehls to use in
filling and altering the banks of the Eastern and Western Streams, TCS and Micro Abrasives
"cause[d], suffered], or allow[ed]" the filling and alteration of the banks of the Eastern and
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77. By filling and altering the banks of the Eastern and Western Streams or causing,
suffering, or allowing such activity, without first filing a Notice of Intent, the Mehls and Legend
violated 310 C.M.R. 10.02(2)(a), 310 C.M.R. 10.05(4)(a), and the WPA,
78. By undertaking activities within the Stream Bank Buffer Zone that altered the
banks of the Eastern and Western Streams or by causing, suffering, or allowing such activity,
without first filing aNotice of Intent, the Mehls and Legend violated 310 C.M.R. 10.02(2)(b),
79. By "caus[ing], suffer[ing], or allowing]" the filling and altering of the banks of
the Eastern and Western Streams without the filing of a Notice of Intent, LCS and Micro
80. By failing to remove the unauthorized fill from the banks of the Eastern and
Western Streams and the Stream Bank Buffer Zone or otherwise restore the banks of the Eastern
and Western Streams and the Stream Bank Buffer Zone to their original condition, the Mehls,
81. The Commonwealth realleges the allegations set forth in paragraphs 1 through 80.
82. The Bordering Vegetated Wetlands are "freshwater wetlands," as the WPA
83. The Bordering Vegetated Wetlands "border[]" on the Eastern and Western
84. The Bordering Vegetated Wetlands are "bordering vegetated wetland[s]," as 310
85. The Bordering Vegetated Wetlands are "areas subject to protection under M.G.L.
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86. The Wetlands Buffer Zone is a "buffer zone," as defined by 310 C.M.R.
87. By removing trees and other vegetation from the Bordering Vegetated Wetlands
and the Wetlands Buffer Zone, the Mehls "alter[ed]" the Bordering Vegetated Wetlands, as 310
88. By filling and grading the Bordering Vegetated Wetlands and the Wetlands
Buffer Zone using solid waste and other fill material, thereby changing their drainage
characteristics and sedimentation and flow patterns, the Mehls and Legend "fill[ed]" and
"alter[ed]" the Bordering Vegetated Wetlands, as 310 C.M.R. 10.04 define those terms.
89. By delivering aluminum oxide fill at the Mehl Property for the Mehls to use in
filling and altering the Bordering Vegetated Wetlands, TCS and Micro Abrasives "cause[d],
suffered], or allow[ed]" the filling and alteration of the Bordering Vegetated Wetlands, as
90. By filling and altering the Bordering Vegetated Wetlands or causing, suffering, or
allowing such activity, without first filing a Notice of Intent, the Mehls and Legend violated 310
91. By undertaking activities within the Wetlands Buffer Zone that altered the
Bordering Vegetated Wetlands or by causing, suffering, or allowing such activity, without first
filing a Notice of Intent, the Mehls and Legend violated 310 C.M.R. 10.02(2)(b), 310 C.M.R.
Bordering Vegetated Wetlands without the filing of a Notice of Intent, TCS and Micro Abrasives
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93. By failing to remove the unauthorized fill from the Bordering Vegetated Wetlands
and the Wetlands Buffer Zone or otherwise restore the Bordering Vegetated Wetlands and the
Wetlands Buffer Zone to their original condition, the Mehls, TCS, Micro Abrasives, and Legend
COUNT II: VIOLATIONS OF THE SOLID WASTE DISPOSAL ACT, G.L, c. Ill,
§ 150A, AND ITS IMPLEMENTING REGULATIONS
94. The Commonwealth realleges the allegations set forth in paragraphs 1 through 93.
95. The SWA and its implementing regulations, 310 C.M.R. 16.00 e/and 19.00
et seq., prohibit any person from maintaining or operating a solid waste disposal facility at any
96. The SWA and its implementing regulations further prohibit any person from
establishing, expanding, maintaining, or operating a solid waste disposal facility without first
97. The SWA and its implementing regulations also prohibit any person from
disposing or contracting for the disposal of solid waste or refuse at any place which MassDEP
98. The SWA and its implementing regulations allow solid waste to be used as a
secondary material in the production of a new product or commodity, if done in accordance with
99. The SWA provides that any person who violates the SWA or its implementing
regulations shall be subject to a civil penalty of up to twenty-five thousand dollars ($25,000) per
violation and that each day a violation occurs or continues is a separate offense.
100. The Commonwealth realleges the allegations set forth in paragraphs 1 through 99.
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101. The Mehls, TCS, and Micro Abrasives are "person[s]," as 310 C.M.R. 16.02 and
102. Because the Mehls, TCS, and Micro Abrasives handled the flocced aluminum
oxide in violation of the terms of the TCS BUD and the Micro Abrasives BUD, the flocced
aluminum oxide at the Mehl Property is "solid waste or waste" and "refuse" as 310 C.M.R.
16.02, 310 C.M.R. 19.006, and 310 C.M.R. 19.060(10) define those terms.
103. By placing the flocced aluminum oxide at the Mehl Property, the Mehls, TCS,
and Micro Abrasives "dispos[ed]" of the flocced aluminum oxide at the Mehl Property, as 310
104. By disposing of solid waste at the Mehl Property, which does not have a site
assignment from the Russell Board of Health and a permit from MassDEP, the Mehls, TCS, and
Micro Abrasives violated 310 C.M.R. 16.01(8)(a)(6), 310 C.M.R. 19.014(2), and the SWA.
105. By contracting for the disposal of solid waste at the Mehl Property, which
MassDEP has not approved as a solid waste disposal site, the Mehls, TCS, and Micro Abrasives
106. The Commonwealth realleges the allegations set forth in paragraphs 1 through
107. The construction and demolition debris described in paragraph 43 is "solid waste
or waste" and "refuse" as 310 C.M.R. 16.02, 310 C.M.R. 19.006, and 310 C.M.R. 19.060(10)
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108. By dumping the construction and demolition debris described in paragraph 43 at
the Mehl Property, the Mehls "dispos[ed]" of the construction and demolition debris at the Mehl
Property, as 310 C.M.R. 16.02 and 310 C.M.R. 19.006 define that term.
109. By disposing of solid waste at the Mehl Property, which does not have a site
assignment from the Russell Board of Health and a permit from MassDEP, the Mehls are
violating 310 C.M.R. 16.01(8)(a)(6), 310 C.M.R. 19.014(2), and the SWA,
110. By contracting for the disposal of solid waste at the Mehl Property, which
MassDEP has not approved as a solid waste disposal site, the Mehls violated 310 C.M.R.
111. Legend is a "person," as 310 C.M,R, 16,02 and 310 C.M.R. 19.006 define that
term.
112. The leaf and yard waste described in paragraph 44 is "solid waste or waste," as
310 C.M.R, 16,02, 310 C.M.R, 19,006, and 310 C,M.R. 19,060(10) define those terms,
113. The leaf and yard waste described in paragraph 44 is "refuse," as 310 C,M,R,
114. By dumping the leaf and yard waste described in paragraph 44 at the Mehl
Property, Legend and the Mehls "dispos[ed]" of the leaf and yard waste at the Mehl Property, as
115. By disposing of solid waste at the Mehl Property, which does not have a site
assignment from the Russell Board of Health and a permit from MassDEP, Legend and the
Mehls are violating 310 C,M,R, 16,01(8)(a)(6), 310 C,M.R. 19.014(2), and the SWA.
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Other Waste Materials
116. The other waste materials described in paragraph 45 are "solid waste or waste," as
310 C.M.R. 16.02, 310 C.M.R. 19.006, and 310 C.M.R. 19.060(10) define those terms.
117. The other waste materials described in paragraph 45 are "refuse," as 310 C.M.R.
118. By dumping the other waste materials described in paragraph 45 at the Mehl
Property, the Mehls "disposjed]" of the other waste materials at the Mehl Property, as 310
119. By disposing of solid waste at the Mehl Property, which does not have a site
assignment from the Russell Board of Health and a permit from MassDEP, the Mehls are
violating 310 C.M.R. 16.01(8)(a)(6), 310 C.M.R. 19.014(2), and the SWA.
120. The Commonwealth realleges the allegations set forth in paragraphs 1 through
119.
121. As a site used for the disposal of solid waste—the flocced aluminum oxide,
construction and demolition debris, the leaf and yard waste, and the other waste materials—the
Mehl Property is a "facility," as 310 C.M.R. 16.02, 310 C.M.R. 19.006, and the SWA define that
term.
122. As a facility or place used for the disposal of solid waste which is not established
or maintained pursuant to a valid site assignment or permit, the Mehl Property is a "dumping
123. Through their ownership of the Mehl Property and their control over the dumping
and use of the solid waste on the Mehl Property, Russell and Karen Mehl are "operator[s]" of a
facility at the Mehl Property, as 310 C.M.R. 16.02 and 310 C.M.R. 19.006 define that term.
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124, Through their control over the dumping and use of the solid waste on the Mehl
Property and their failure to remove those materials, Russell and Karen Mehl "maintain" a
facility on the Mehl Property, as 310 C.M.R. 19.006 and the SWA define that term.
125. By operating and maintaining the Mehl Property as a facility without having
obtained a site assignment from the Russell Board of Health and a permit from MassDEP,
Russell Mehl and Karen Mehl are violating 310 C.M.R. 16.01(8)(a)(5), 310 C.M.R. 19.014(1),
RELIEF REQUESTED
A. Enjoin the Mehls from further alterations to or filling of any wetlands and stream
B. Enjoin the Mehls, Legend, TCS, and Micro Abrasives from any further disposal
C. Order the Mehls, Legend, TCS, and Micro Abrasives to properly remove the
aluminum oxide fill and other solid waste and restore, to MassDEP's satisfaction,
the Wetlands, Wetlands Buffer Zone, the banks of the Eastern and Western
Streams, and the Stream Bank Buffer Zone to their original condition;
D. Order the Mehls, Legend, TCS, and Micro Abrasives to pay the Commonwealth a
civil penalty of twenty-five thousand dollars ($25,000) per day for each violation
of the WPA, the SWA, and the regulations promulgated under each, or such
E. Award any other or further relief which the Court deems proper.
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Respectfully Submitted,
COMMONWEALTH OF MASSACHUSETTS
MAURA HEALEY
ATTORNEY GENERAL
20
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COMMONWEALTH OF MASSACHUSETTS
COMMONWEALTH OF MASSACHUSETTS, )
Plaintiff, )
v. )
Russell A. Mehl, Jr., Karen L. Mehl, Legend Lawn Care, Inc., and Micro Abrasives Corp.,
jointly move this Court for entry of Final Judgment, pursuant to Massachusetts Rule of Civil
The Commonwealth also moves the Court to enter Final Judgment, pursuant to
Massachusetts Rule of Civil Procedure 58(a), as to Defendant Truck Crane Service, Inc., in the
form submitted with this Motion, and submits the Affidavit of Peter C. Mulcahy, attached as
1
Respectfully submitted,
THE COMMONWEALTH OF
MASSACHUSETTS
By its Attorney:
MAURA HEALEY
ATTORNEY GENERAL
2
RUSSELL A. MEHL, JR., KAREN L. MEHL,
AND LEGEND LAWN CARE, INC.
By their Attorney;
3
MICRO ABRASIVES CORPORATION
By its Attorney:
Date