'This referral is requested against Fredric Bernstein and Dominic Bouchard for the unlawful discharge of dredged and fill material into Indian Creek, its adjacent wetlands. Two administrative orders for compliance have been issued to Defendants requiring them to remove the fill material and restore the area. The Defendants continue to violate EPA''s orders by failing to implement their approved restoration and stabilization plan by continuing to discharge fill material for road crossings throughout the property.'