ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS
)
)
Complainant,
1
VS.
1
)
FIRST COUNTRY HOMES, L.L.C., an Illinois
)
Limited liability company,
)
1
Respondents
1
PCB 06-173
(Enforcement
-
Water)
NOTICE OF FILING
TO: Thomas G. Gardiner
Gardiner Koch
&
Weisberg
53 West Jackson Blvd.
Suite 950
Chicago, Illinois 60604-3849
Mr. Bradley P. Halloran
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center, Suite 11-500
100 West Randolph
Chicago, Illinois 60601
PLEASE TAKE NOTICE that I have today electronically filed with the Office of the
Clerk of the Pollution Control Board a Proposed Discovery Schedule, a copy of which is
Dated:
- -
~atthew%arinelli
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN
Attorney General of the State of Illinois
By: Assistant Attorney General Matthew Marinelli
Environmental Bureau
188 West Randolph St., 2oth
Floor
d
Chicago, IL 60601
3
12-814-0608
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JULY 31, 2006
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS
1
1
Complainant,
)
1
VS.
1
1
PCB No. 06-173
)
(Enforcement
-
Water)
FIRST COUNTRY HOMES, L.L.C., an
1
Illinois corporation
1
1
Respondent.
1
PROPOSED DISCOVERY SCHEDULE
NOW COMES Complainant, People of the State of Illinois, through its attorney, LISA
MADIGAN, Attorney General of the State of Illinois, hereby proposing the following
simultaneous discovery schedule in the above-captioned matter:
1.
Written discovery, including but not limited to, interrogatories, document
requests, and requests for admission shall be propounded by 30 days after the entry of this order;
2.
Responses to written discovery shall be completed by 60 days after the entry of
this order;
3.
Fact depositions shall be completed by 90 days after the entry of this order;
4.
Notices of expert depositions, including but not limited to, depositions and
subpoenas, shall be served by 105 days after the entry of this order.
5.
Expert depositions shall be completed by 135 days after the entry of this order;
6.
Nothing in this Order shall preclude the filing of any motion or form of discovery
prior to the date set forth in this Order and any such earlier filing shall not preclude the filing of
additional discovery of that type so long as the additional discovery is timely as provided in this
Order;
7.
The parties reserve the right to seek leave to conduct additional discovery to the
extent that prior discovery responses warrant additional discovery.
WHEREFORE, Complainant requests that the above discovery schedule be granted.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JULY 31, 2006
Respectfully submitted,
For the Complainant:
PEOPLE OF THE STATE OF ILLINOIS,
LISA MADIGAN, Attorney General
State of Illinois
BY:
Matthew Marinelli
Assistant Attorney ~eneral
Environmental Bureau
188 W. Randolph St.
-
20th F1.
Chicago, Illinois 60601
(3
12) 8 14-0608
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JULY 31, 2006
CERTIFICATE OF SERVICE
I, MATTHEW MARINELLI, an Assistant Attorney General, do certify that I caused the
foregoing PROPOSED DISCOVERY SCHEDULE to be served upon the persons listed on the
said NOTICE on this
Zkd-
day of July, 2006, by facsimile and first-class mail in a postage
prepaid envelope and depositing same with the United States Postal Service located at 188 West
Randolph Street, Chicago, Illinois, 60601.
It is hereby certified that a true copy of the foregoing Notice was electronically filed with
the following on July
,2006:
Ms Dorothy Gunn
Illinois Pollution Control Board
James R. Thompson Center
100 West Randolph, Suite 1 1-500
Chicago, Illinois 60601
MATTHEW MARINELLI
Assistant Attorney General
Environmental Bureau
188 West Randolph St., 2oth
Floor
Chicago, Illinois 6060 1
3 12-8 14-0608
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ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JULY 31, 2006