BEFORE THE ILLINOIS POLLUTION CONTROL BO
ECEIVED
PEOPLE OF THE STATE OF ILLINOIS,,
)
CLERK'S OFFICE
Complainant,
j
OCT
0 2 2006
j
STATE OF ILLINOIS
V .
PCB No . 03-191Pollution
Control Board
COMMUNITY LANDFILL COMPANY, INC .,
)
an Illinois Corporation, and CITY OF MORRIS,
)
an Illinois Municipal Corporation,,
)
Respondents .
)
NOTICE OF FILING
TO
:
All counsel of Record (see attached Service List)
Please take notice that on September 28, 2006, the undersigned filed with the Illinois
Pollution Control Board, 100 West Randolph Street, Chicago, Illinois 60601, Witness List and
Expert List
.
Dated :
September 28, 2006
Charles F. Helsten
Hinshaw & Culbertson LLP
100 Park Avenue
P.O. Box 1389
Rockford, IL 61105-1389
815-490-4900
This document utilized 100% recycled paper products .
Respectfully submit
ted,
Cktrl6s F. Helsten
One of Its Attorneys
70492057v1 806289
RECEIVED
CLERK'S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
OCT 0 2 2006
STATE OF ILLINOIS
Pollution Control Board
PEOPLE OF THE STATE OF ILLINOIS,,
Complainant,
v
.
COMMUNITY LANDFILL COMPANY, INC .,
an Illinois Corporation, and CITY OF MORRIS,
an Illinois Municipal Corporation,,
Respondents .
WITNESS LIST AND EXHIBIT LIST
NOW COMES the Respondent, City of Morris, by and through its attorneys, Hinshaw &
Culbertson, LLP, and files its Witness List and Exhibit List, as follows
:
WITNESS LIST
1
.
Devin Moose
2 .
William Crawford
3 .
John Enger
4 .
J.P. Pelnarsh Sr.
5 .
Robert Pruim
6
.
Edward Pruim
7 .
R. Michael McDermont
8
.
Joyce Munie
9 .
Blake Harris
10 .
Cristina Roque
11
.
Ellen Robinson
70502427v 1 806289
)
)
)
PCB No. 03-191
)
)
)
)
12
.
Mark Retzlaff
13 .
Brian White
14
.
The City also reserves the right to call any other witness in rebuttal of any
position taken by the State or Community Landfill Company in presentation of their respective
cases .
EXHIBIT LIST
1
.
Any and all exhibits and/or information attached to any pleadings, motions or
other documents filed for the record in this case
;
2 .
Any and all documents, records, reports, information, and/or other tangible things
referred to in all depositions taken and all discovery requests (and responses thereto) made in this
matter ;
3 .
Any and all documents on file concerning the Morris Community Landfill with
the Illinois Environmental Protection Agency
.
4 .
Any and all documents produced by any party in response to information riders
attached to depositions notices or discovery requests (including, but not limited to all documents
produced by the City of Morris in connection with the depositions of John Enger, William
Crawford and Devin Moose) .
5 .
The City also reserves the right to call any other exhibits in rebuttal of any
position taken by the State or Community Landfill Company in presentation of their respective
cases .
2
70502427v1806289
Dated
: ,
/t11/o6
Charles F. Helsten
Hinshaw & Culbertson LLP
100 Park Avenue
P.O. Box 1389
Rockford, IL 61105-1389
815-490-4900
Respectfully submitted,
On behalf of the CITY OF MORRIS
Charles F . Helsten
One of Its Attorneys
This document utilized 100% recycled paper products .
3
70502427v 1 806289
AFFIDAVIT OF SERVICE
The undersigned, pursuant to the provisions of Section 1-109 of the Illinois Code of Civil
Procedure, hereby and
pena
of perjury under the laws of the United States of America,
certifies that on , 2006, she caused to be served a copy of the
foregoing upon
:
Mr. Christopher Grant
Assistant Attorney General
Environmental Bureau
188 W. Randolph St., 20th Fl
.
Chicago, IL 60601
Mark LaRose
Clarissa Grayson
LaRose & Bosco, Ltd .
200 N. LaSalle, Suite 2810
Chicago, IL 60601
Ms. Dorothy Gunn, Clerk
Pollution Control Board
100 W. Randolph, Suite 11-500
Chicago, IL 60601
Bradley Halloran
Hearing Officer
Pollution Control Board
100 W. Randolph, Suite 11
Chicago, IL 60601
A copy of the same was enclosed in an envelope in the United States mail at Rockford, Illinois,
proper postage prepaid, before the hour of 5 :00 p.m ., addressed as above .
HINSHAW & CULBERTSON
100 Park Avenue
P.O. Box 1389
Rockford, IL 61105-1389
(815) 490-4900
Wdi
.KW'
AWL--(
70415200v1 806289
