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MY GOAL
CLEAN UP THIS HAZARDOUS LANDFILL SITE
AND THE FEDERAL MISSOURI RIVER!

THE HAZARDOUS MATERIALS OF ALL
KINDS WERE IN THE DEMOLITION DEBRIS

MORT SULLIVAN
IS TRYING TO PROTECT THE CITIZENS

THESE INDIA PEOPLE HAVE TO OBEY THE FEDERAL EPA
ASBESTOS/NESHAP
REGULATED ASBESTOS CONTAINING MATERIALS
GUIDANCE - AND THEIR ARE CERTAIN ITEMS THAT
THEY HAVE TO DO AND THEY ARE GOING TO HAVE
TO USE A SHOVEL TO DIG INTO THE ASBESTOS SITE
AND HAVE TO WEAR PROTECTIVE CLOTHING AND
NOT USE HEAVY EQUIPMENT THAT WOULD MAKE 
THE ASBESTOS FRIABLE FROM DRIVING ON IT AND
 THEN PUT THE ASBESTOS INTO BAGS AND AND THEN 
INTO APPROVED TRUCKS AND THEN HAULED TO AN
ASBESTOS APPROVED LANDFILL - FAR AWAY!

SOMEBODY BETTER BUY THESE PEOPLE FROM
INDIA A SHOVEL TO USE - 13 ACRE LANDFILL
THAT IS 150 FEET DEEP FILLED UP WITH 
HAZARDOUS MATERIALS
MAY BECOME HARD WORK WITH A SHOVEL!

"THE CLEANUP OF THE LANDFILL AREA"
THERE WAS ANOTHER CLEANUP FROM A 
"FEDERAL CLEAN WATER ACT LAWSUIT"
THIS WAS A SEPARATE LAWSUIT AND IN NO 
WAY IS IT CONNECTED TO THIS COMING LAWSUIT 
AND THE NAME OF THE COMPANY WAS ASARCO

In a document dated April 20, 1990 and titled
Articles of Merger of OKAHOMA, INC., INTO TCLA, INC
In what is listed as THIRD that states:  "The sole shareholder of 
TCLA, In., PDM, Inc. having reviewed the Plan Of Merger, Exhibit "A", has waived the mailing of the plan requirement of Neb. Stat. §21-2074.  Dated this 19th day of April, 1990.  Signed by TCLA, Inc., President, Thomas C. Lauritsen.  This means that PDM, Inc., owned all the land at the time of Zoning, Grading and Development of Site and all the Improvements and Installation of Utilities.  In the Domestic Corporation Occupation Tax Report, dated and signed on February 19, 1990, for PDM, Inc., it lists Jack Baker as the President.

There was also a man named Joe Matusek that lived on solid ground at 2923 South 15th Street at the edge of the landfill site that claimed that Big Trucks were dumping large drums of something into this "Open Landfill during the middle of the night.

Judge Rudy Tesar bought this land at a tax sale and let 
anyone dump anything into this 13 acre site, and now
it is going to be time for this problem and landfill to
be cleaned out and right - the wrong - to the Missouri River.

THIS WAS AN "OPEN LANDFILL" WITH NO SUPERVISION
AND ANY ONE COULD DUMP INTO IT AND WITH THE 
"NATURAL SPRING" RUNNING THROUGH IT COULD BE
THEN FLOWING INTO THE MISSOURI RIVER!

We are also in possession of a Document that is written and titled August, 1968:  "Status Of Dumps And Dumping In Omaha And Douglas County"
It States The Following In Item #3.  Anderson Dump - 13th & Frederick
To 15th And Elm Street.  This Dump Is Confined to Demolition Debris.  Some Residential Dumping Is Done Here.  There Is A WATER RESTRICTION PROBLEM Caused By The Dumping.  This Dump Caught On Fire a Month Ago.  Separate Cases Against this Dump By the Health Department And The Fire Department Are Now In The Court.

It Is Our Personal Opinion That Since This Was A Open Landfill That
Hazardous Materials Of Many Kinds Could Have Been Dumped Into It
And That There Is A Natural Spring That Flows To The Missouri River.

Jack W. Baker, President of PDM, Inc., TCLA, Inc., GRANTOR, quitclaims to Ficus, LLC, a Nebraska Limited Liability Company, GRANTEE, an unrestricted charitable contribution of $2.7 Million Dollars to the Omaha Zoo Foundation, a Nonprofit Corporation, is the Sole Member, John K. Boyer, President, Lee G. Simmons, Secretary and Treasures, 3710 South 10th Street, Omaha, Nebraska, 68108 and they are the new owners of the Hazardous Waste Landfill, legally described as Lot 3, 4, 5, 6, 8, 9, 10 and 11 in the 13th Street Commercial Development, a cluster subdivision in Omaha, Douglas County, Nebraska, and the East 33.33 feet of Lot 11 in Connell Addition, in Omaha, Douglas County, Nebraska, on December 26, 2006.

Any grading that was to maybe occur in the future could endanger the heath of all
McDonald's employees and residents in the area since the families across 13th Street
on the East side have suffered lead poisoning to their family and their children.

The DeerPark Neighborhood Association And All Officers
Of The Association Personally

LAWSUIT ROUGH DRAFT
BEING WRITTEN AND WILL BE PLACED BELOW

DEER PARK NEIGHBORHOOD ASSOCIATION, INC.
Jason Smith, President - Personally - Board Member
John Synowiecki, Vice President - Personally - Board Member
Gus Palmer, Secretary - Personally - Board Member
Garry Gernandt - Treasurer - Personally - Board Member
Howard Hanson - Director - Personally - Board Member
Kay Novacek - Director - Personally - Board Member
Gerri Duda - Director - Personally - Board Member
To Get their Personal Property

John S Slavik - His Company Assets = Sheppard Hay And Feed
And Home And Business Offices and Garages

Overland Constructors, Inc.
Timothy J. Huber
5036 South 135th Street
Omaha, Nebraska  68135

Advanced Building & Components, Inc.
Randall Johansen
1541 County Road 11
Mead, Nebraska  68041

DNB Electrical Contractors, Inc.
David Nienaber
4427 South 139th Street
Omaha, Nebraska  68137

PDM, Inc. a Nebraska Corporation
TCLA, Inc. a Nebraska Corporation
Jack W. Baker, President
8805 Indian Hills Drive, Suite 210
Omaha, Nebraska  68114
13th Street Outlot Association
Jeffrey M. Keating, Incorporator
John R. Karnish, Incorporator
8805 Indian Hills Drive, Suite 210
Omaha, Nebraska  68114

Omaha Zoo Foundation
President, Dennis Pate
Lee G. Simmons
3710 South 10th Street
Omaha, Nebraska  68108
Ficus, LLC
Calvin R. Sisson, Organizer
14721 Sprague Street
Omaha, Nebraska  68116

McDonald's Corporation
Ralph Alvarez
2111 McDonald's Drive
Oakbrook, Ill 60523

Charles R. Clatterbuck, Trustee
13th Street Lodging, LLC
Charles R. Clatterbuck and Gary Friedenbach,
General Partners of Crown Management, LLC
Managing Partner of 13th Street Lodging, LLC, 
a Nebraska Limited
Liability Company
1409 Buck Drive
Bellevue, Nebraska  68005

Pair-A-Dice Properties IV, LLC
Clark W. Anderson, Member
Terry R. Johnson, Member
Gary L. Schreiner, Member
Daniel R. Gilg, Member
117 East 4th Street
Ogallala, Nebraska  69153

Buck's Inc., a Nebraska Corporation
Steve Buchanan, President
5001 Dodge Street
Omaha, Nebraska  68132

DHARMISTHA DESAI
4433 North 26th Street
Lincoln, Nebraska  68521

Okahoma, Inc.
Jay R. Lerner - President
L C Development Co.
Jay R. Lerner
Salvadore Carta
10855 West Dodge Road, Suite 270
Omaha, NE 68154 

RE:  Citizen Suit Notice.

Dear Gentleman:

     Please take notice that the following persons, Corporations and Limited Liability Companies hereby give notice

pursuant to Section 505 (b) of the Federal Water Pollution Control Act, as amended, 33 U.S.C. § 7002 (a)  (1) of the

Solid Waste Disposal Act. 42 U.S.C  § 6972 (RCRA), and 40 C.F.R. Parts 135 and 254 of their intent to file suit.

     A.     Parties.  The parties giving notice and their addresses are:

                             1.       Morton D. Sullivan
                                       5224 North 52nd Street
                                       Omaha, Nebraska  68104

                              2.       Eastroads, LLC
                                        Box 4578
                                        Omaha, Nebraska  68104

                              3.       Environmental Associates, LLC
                                        Box 2
                                        Ames, Nebraska  68621

                                4.     Thirteenth Streets Associates, Inc.
                                         Box 3
                                         Ames, Nebraska  68621

     B.       Violations.      The facts giving rise to this notice are as follows:

                For many years, PDM, Inc., A Nebraska Corporation, the Majority Stockholder in TCLA, Inc., 
                A Nebraska Corporation, has owned property of approximately 13 acres located in the Northwest 
                corner of Interstate 80 and 13th Street, Omaha, Nebraska.  This 13 acre site has been a Unsupervised
                Landfill since 1948, and there is Groundwater (drainageway) that flows beneath the Landfill, extending
                between the Northwest and Southeast portions of the site and then to the Missouri River that is a 
                Federal Waterway.    The Landfill site is located on alluvial clay, silt, gravel deposits, which are underlain
                by older Pennsylvania age sedimentary bedrock strata and gravel deposits.

                 The Groundwater can be divided into two categories:  bedrock and alluvial.  The Groundwater in the 
                 bedrock system flows toward the Missouri River and is discharge into alluvial systems which is 
                 interconnected with and is apart of the Missouri River.  The Groundwater is 150 feet below the top of 
                 the Landfill site.

                 The Landfill was established in 1948, and anyone was allowed to dump anything into this 13 acre,
                 150 foot deep ravine hole.  Because the dumping was unsupervised and according to a letter dated
                  March 29, 1988, that was written by Donald E. Olson, P.E., Chief, Division of Environmental Health
                  Department stated:  "A large portion of this site was the repository for demolition debris arising from
                  the clearing of corridors for the Interstate system in Omaha".  The demolition debris referred to in the
                  letter were the Old Omaha City Hall and the Old Federal Post Office, and all the houses and buildings
                  that were removed from the clearing the way of the Interstate Highway.  These houses and buildings
                  were built from the era of 1930 to 1950, and primarily made out of wood with Asbestos, Transite Siding,
                  Roof, Flooring, Asbestos Wrapped Furnace Pipes, and Lead Pipes, and other Lead and Asbestos  
                  containing items and materials.

                  Each and every day since 1948, the Landfill Dump Area was filled with Asbestos, Lead, Transite, and 
                  possible other types of buried hazardous wastes that contain numerous heavy metals, including lead,
                  arsenic, magnesium, manganese, potassuim, mercury, nickel, chromium, zinc, and copper.

                  The Landfill Dump Area that was started in 1948, was never capped off for the protection of the
                   surrounding residents in the area.  The company TCLA, Inc., purchased the Landfill Dump
                   Area in separate pieces by various corporations so the sellers would not be aware of the buyers names
                   The TCLA, Inc., A Nebraska Corporation was established April 10, 1989, and through a Articles of 
                   Merger of Okahoma, Inc., into TCLA, Inc., where the sole shareholder of TCLA, Inc., was PDM, Inc.,
                   and was dated April 19, 1990.  The TCLA, Inc., then immediately took control of the Landfill Dump
                   Area, and made plans to sub-divide and develop the approximately 13 acres.  In a letter dated May 15,
                   1996, their engineering firm Kirkham & Michael wrote to Mr. Joe Francis, Assistant Director, Air 
                   and Waste Management Division, Nebraska Department of Environmental Quality.  The routine that
                   both TCLA, Inc., and Kirkham & Michael had adopted was the fact that they referred to all the debris
                   in the Landfill Dump Area, as "Rubble" and not Asbestos, Lead, and other possible Toxic Materials.
                   They also realized that the Landfill Dump Site was approximately 200 feet above the Interstate 80 
                   Interchange and that there would be future runoff from the site.  It apparently was going to become
                   a major problem because of all the Asbestos, Lead, and Transite that had over the years been flowing
                   from the site into the State of Nebraska, Department Storm Sewer System and directly into the Missouri
                   River.  The State of Nebraska Department of Roads knew about this violation and apparently chose
                   to ignore it.  This was the first sign of a violation of the Federal Water Pollution Control Law, as
                   embodied in the Clean Water Act (CWA), 33 U.S.C. § 1251 et seq, contains a comprehensive program
                   for protecting our nation's waters.

                   Since the TCLA, Inc., company knew that they had a problem they apparently decided to hire a grader
                   to come in and grade the entire 13 acre site and did not at that time, nor have they ever applied for the
                   NPDES PERMIT PROGRAM.  Under the 6.0 THE NPDES PERMIT PROGRAM.  6.2 What
                   Discharges Require a NPDES Permit?  A NPDES Permit is required for any discharge of a pollutant
                   from a point of source to waters of the United States.  This includes such waste streams as industrial
                   process water, non-contact cooling water, raw water overflow, and Storm Water Runoff.  In other words,
                   a NPDES Permit is requirerd for all discharges except street runoff (which is not a point of source 
                    discharge), discharges into wholly intrastate waters, and certain exempted activities.  The TCLA, Inc.,
                   has never obtained a NPDES Permit and there has been Storm Water Runoff containing Asbestos,
                   Lead and Transite containing materials running into the State of Nebraska Department of Roads
                    Storm Sewer System, and then flowing into the Federal Missouri River.

                    Each and every day since 1948, the Asbestos, Lead, Transite and other metals which were buried have
                    been, are, and for indefinate future will continue to be, discharged into both the groundwater stream, 
                    and storm water runoff will flow into the State of Nebraska Storm Sewer System, and then into the
                    Federal Missouri River.  Of particular environmental concern is the Asbestos, Lead, and Transite
                    that was found at ground level flowing into the Storm Sewer Systems.

                    On December 9, 1996, Environment Management Resources conducted a evaluation and determination
                    of the site with regards to N.E.S.H.A.P. violations.  In a letter, Richard L. Cook, stated "Based on my
                    observations from earlier this week, prior to snow cover, that numerous pieces of suspect floor tile
                    and mastic, and various pieces of suspect Transite were present in the existing excavated debris.  I do
                    believe that the N.E.S.H.A.P. regulations apply in this situation.  Since EPA has taken a cradle to grave 
                    approach regarding the disposition of ACM, responsibility for the for the ultimate fate of Category I                   
                    ACM rests with all the individuals involved in handling the material".  I do think that it is appropriate
                     to consider the potential health risks associated with uncovering Asbestos containing materials anytime
                     one excavates in a previous landfill/or construction debris fill site that operated without regulatory 
                     controls.  Furthermore, as N.E.S.H.A.P. points out, it is important to understand the various outside
                     forces that may have been applied to the Category I & II non-friable materials after they are actually
                    removed from a facility, that may cause the materials to become regulated at anytime during the 
                    handling and/or land filling process".  Attached hereto is an Affidavit from Richard L. Cook, signed and 
                    dated the 4th day of March, 1997.  While it has been known for some time that TCLA, Inc., has been
                    disturbing and digging into the landfill area, that the pollutants have been flowing into the underground
                    creek and the State of Nebraska Department of Roads Storm Sewer System and discharging the 
                    pollutants directly into the Federal Missouri River.

                     All the buried Asbestos, Lead, and Transite and various other metals are "pollutants" for the purposes 
                     of the Clean Water Act.  At lease some, if not all, of the buried Asbestos, Lead, and Transite and other
                      metals are "Hazardous Waste" for the purposes of RCRA.

                      PDM, Inc., TCLA, Inc., has never obtained an NPDES permit, ("the permit") with respect to some
                       of its discharges into the Federal Missouri River.  The permit authorizes discharge of effluent
                       containing Asbestos, Lead, Transite, and certin metals through designed outfalls in the Omaha Sewer
                       System and surface waters of the Federal Missouri River.  The permit that was never applied for does 
                       not authorize the discharge of pollutants into the State of Nebraska Storm Sewer System or
                       underground creek and groundwater.

                       Section 301 of the Clean Water Act, 33 U.S.C.  § 1311, prohibits the discharge of a pollutant from a
                        point source into a river of the United States except in compliance with an NPDES permit issued by
                       the EPA pursuant to  § 402 of the Clean Water Act, 33 U.S.C.  §  1342.  Since PDM, Inc., TCLA, Inc.,
                       has no permit for these discharges, it is violating, and in the indefinate future will continue to violate,
                       33 U.S.C.  §§  1311, 1317 and 1342.  PDM, Inc., TCLA, Inc., has been violating and continues to
                       violate the Clean Water Act each and every day since they acquired different ownerships on April 3,
                        1991.  PDM, Inc., TCLA, Inc., actions as owners and operator of the site also constitute, and for the
                        the foreseeable future will continue to constitute, violations of RCRA  §§  1008  (42 U.S.C.  §  6907 
                        (;  3004  (42  U.S.C.  §  6924),  including 3004  (d)  (42  U.S.C.  §  6924  (d),  3005  (42)  U.S.C.  § 6925);
                        4005  (42  U.S.C.  §  6945) ; 7002  (42 U.S.C.  §  6972) ;  and 7003  (42 U.S.C. §  6973)  and their
                        implementing regulations, including 40 C.F.R.  Parts 260 through 264, by this unpermitted storage
                        and disposal of hazardous waste and creating an imminent and substantial endangerment to the
                        Federal Missouri River and its ecosystem.  PDM, Inc., TCLA, Inc., has committed and continues to
                        commit these violations each and every day, at least since April 3, 1991 and not the Henry Doorly
                        and Ficus, LLC., is now owners.  (More will be added by the attorneys in the future in this space).
     
                        Unless appropriate enforcement action is taken by NDEQ or EPA under the RCRA and the Clean
                         Water Act within 60 days, the above listed parties will file a suit under the Citizen Suit provisions
                        of those statutes.  Such Citizen Suit may include a request for damages, penalties, attorney's fees
                        and costs as well as injunctive or other equitable relief.

                       c:  Indentification of Counsel.  The counsel giving this notice is______To Be Filled In __________.

                         The following will be involved in the following Citizens Suit:   Omaha Zoo Foundation, Ficus, LLC.,
                          McDonald's Corporation, Charles R. Clatterbuck, Trustee. 13th Street Lodging, LLC.,                        
                          Charles R. Clatterbuck and Gary Friedenbach, General Partners of Crown Management, LLC .,
                          Pair-A-Dice Properties IV, LLC., Buck's Inc., a Nebraska Corporation.

                      
 IF I WAS THE ZOO
I  WOULD GIVE THE LAND & ALL THE COMING 
ENVIRONMENTAL PROBLEMS & LAWSUITS 
BACK TO JACK BAKER SINCE IT DID
NOT COST THEM ANYTHING "YET" TO GET THE LAND!

WHEN THE ZOO HAS TO CLEAN UP THE 
ASBESTOS, LEAD, TRANSITE AND OTHER METALS 
THEY ARE GOING TO HAVE TO DO IT 
ONE (1) SHOVEL FULL AT A TIME  
AND THEN PUT THE HAZARDOUS ITEMS
INTO BAGS AND PUT IT INTO A TRUCK
AND DELIVER IT TO A EPA APPROVED LANDFILL!
  

THE REST OF THE EMR REPORT COMING SOON
AND ALSO A REPORT ON THE LEAD PROBLEM
IN THE AREA SINCE JACK BAKER DID THE GRADING
AND WE HAVE ALL THE VIDEOS AND PICTURES

HERE IS ANOTHER ORGANIZATION THAT
REFUSED TO BUY THESE EXACT SAME 
 LOTS IN THIS HAZARDOUS SITE

JACK BAKER AND NOW THE FICUS, LLC AND THE
OMAHA ZOO FOUNDATION
APPARENTLY DOES NOT SHARE THIS PHASE I & II
ENVIRONMENTAL ASSESSMENT
TO FUTURE LAND BUYERS AND THAT IN MY 
PERSONAL OPINION IS WRONG TO CHEAT PEOPLE!

IT IS MY PERSONAL OPINION THAT IF THESE INDIA
PEOPLE HIRE A GOOD ATTORNEY - HE SHOULD BE ABLE
TO GET BACK THEIR MONEY THAT THEY PAID FOR THIS LAND!

THE STREET THAT WAS PUT INSTALLED SOME DAY
WILL CAVE IN SINCE IT IS OVER THE DEEPEST PART
OF THE LANDFILL THAT HAS LARGE VOIDS FROM
THE BURNED OUT HOUSES THAT WE BURIED AT
THIS SAME SITE.  THEY ONLY DUG A HOLE ABOUT
8 FEET DEEP AND THEY LAID WHITE ROCK IN THE 
HOLE AND THEN LAID THE STORM SEWER PIPE ON
TOP THE THE WHITE GRAVEL.  THEY NEVER OBTAINED
A CITY PERMIT TO INSTALL THIS STORM SEWER AND
DID IT ANY WAY.  THE LETTER BELOW TELLS THAT
THERE WAS NEVER A PERMIT APPROVED TO INSTALL
THE STORM SEWER AND WE HAVE VIDEOS AND PICTURES
OF THE STORM SEWER BOTH BEFORE AND AFTER IT
WAS INSTALLED.  THE LAND PURCHASERS WE HAVE
BE TOLD HAVE TO PAID FOR ANY TYPE OF DAMAGE
THAT MAY HAPPEN TO THIS STORM SEWER SINCE
THE LANDFILL WILL SETTLE SOMEDAY AND IT MAY
FALL INTO ALL THE VOIDS IN THIS LAND FILL AREA!

HEN THEY DID GRADING IN THIS
SITE WE HAVE VIDEOS OF ALL THE DUCT THAT WAS BLOWING
INTO THE HOMES OF THE SURROUNDING RESIDENTS

HERE IS ONE OF THE PAGES FROM THE ENTIRE
REPORT AND IT TELLS THAT LEAD WAS FOUND
IN THESE AREA AND IN THE 2ND PICTURE
IT WAS IN THE KIDS BEDROOM AND THAT IS
WRONG TO HURT CHILDREN FOR MONEY

THE QUESTION IS " WHERE DID THEY GET THIS MONEY"???

WE WILL BE FINDING OUT!

THIS INDICATES AS I HAVE TOLD EVERYONE THAT YOU DO NOT
STOP NATURE AND IT'S WATER FLOW!  THIS DOCUMENT PROVES THAT
 THERE IS A CREEK THAT IS FLOWING UNDERNEATH THIS LANDFILL 
AND TAKING HAZARDOUS MATERIALS AND LEAD, ASBESTOS, 
TRANSITE AND OTHER MATERIALS INTO THE FEDERAL PROTECTED 
MISSOURI RIVER
AND THAT IS WHY ALL SPORTSMEN ARE INTERESTED IN 
HAVING THE CLEAN WATER ACT FILED SO THIS ENTIRE
LAND FILL AREA WILL BE CLEANED OUT AT THE EXPENSE
OF ALL THE PAST AND PRESENT OWNERS$$$$$ 

THIS AREA OF THE WEB SITE IS DEDICATED
TO THE ATTORNEYS THAT ARE ON OUR SIDE IN THIS FIGHT

THE NEWSPAPER ARTICLE BELOW
TELLS ABOUT THE MONEY THAT WAS MADE
WHEN A "CLEAN WATER ACT LAWSUIT"
WAS WON IN THE DISTRICT COURT AND
ALL THESE PEOPLE THAT WE ARE FIGHTING
HAVE LOTS OF MONEY AND CAN PAY US!

THIS CITIZENS LAWSUIT IS WORTH MORE MONEY
AND MORE COMPANIES WITH GREAT ASSETS
ARE INVOLVED AND DON'T CARE ABOUT THE 
FEDERAL MISSOURI RIVER & THE PUBLIC

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