CEVE
CLERK’S
OFFICE
01T
I
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
STATE
OF
ILLINOIS
Pollution
Control
Board
IN THE MATTER
OF:
)
)
JOSEPH
&
VICTORIA
MORRISSEY,
)
)
Complainants,
)
)
v.
)
PCB
09-10
)
GEOFF
PAHIOS
and
ALPINE
)
AUTOMOTIVE,
)
)
Respondents.
)
NOTICE
OF
FILING
To:
Joseph
&
Victoria
Morrissey
Illinois Pollution
Control
Board
32
S. Chestnut
Court
James
R.
Thompson
Center,
#11-500
Hawthorn
Woods, Illinois
60047
100 W. Randolph
St.
Chicago,
Illinois
60601
PLEASE
TAKE NOTICE
that
on October
10, 2008,
the undersigned
filed with the
Clerk
of the State
of Illinois
Pollution
Control
Board, James
R. Thompson
Center,
100 W.
Randolph
St.,
Suite 11-500,
Chicago,
Illinois 60601,
the
Respondent’s
Proposed
Discovery
Schedule,
a
copy of
which is
attached
hereto
and hereby
served
upon yotr’
Paul
J. Oleksak
:
-v
Attorney
At
Law
100
Atkinson
Road,
Suite
11 OF
Grayslake,
Illinois
60030
(847)
543-9000
Attorney
Number
Bruce A.
Slivnick
Attorney
At
Law
707
Lake
Cook
Road,
Suite
316
Deerfield,
Illinois
60015
(847)
714-0503
Attorney
Number
6181410
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
CL,ll’j9
°PFjC
urr
IN THE
MATTER OF:
)
Sr4rE,
)
Pollutj
0
4fLlN,
JOSEPH & VICTORIA
MORRISSEY,
)
‘8Oard
)
Complainants,
)
)
v.
)
PCB 09-10
)
GEOFF
PAHIOS and ALPINE
)
AUTOMOTIVE,
)
)
Respondents.
)
PROPOSED
DISCOVERY
SCHEDULE
NOW COMES the
Respondents, GEOFF
PAHIOS
and ALPINE AUTOMOTIVE,
INC.
improperly
noted
as ALPINE
AUTOMOTIVE,
by
and
through their attorneys,
Paul
J. Oleksak
and Bruce
A.
Slivnick
and as
and for its
Proposed
Discovery
Schedule:
1. Both
Parties
to Propound
Written
Discovery
to
Each
Other: October
31, 2008
2. Both
Parties
to Respond
to Written
Discovery Propounded
to
them:
December
5,
2008.
3.
Oral Depositions
of
Fact Witnesses
(non expert)
to be completed
(90 days): March
5,
2009.
4. Status Hearing for
setting of
Expert
Discovery
shortly after March
5,
2009
5.
Respondent’s
counsel
had two
telephone conversations
with
the Complainants
relative
to this schedule.
The first
conversation
occurred
with both Complainants
on
October 2,
2008 right after
the
telephonic
status hearing
in which this schedule
was discussed.
The
second
conversation occurred
on October
10, 2008
between
Mr. Morrissey
and Bruce
A.
Slivnick
fro
the
Respondent
and Mr.
Morrissey
indicated
that
he had
no
objection
to
this
schedule.
Respectfully
submitted,
GEOFF
PAHIOS
and ALPiNE
AUTQ?4OTIVE,
INC.
,
By:
—‘
‘-
Attorneys
for
Respondent
Paul
3.
Oleksak
Attorney
At Law
100
Atkinson
Road,
Suite
11
OF
Grayslake,
Illinois
60030
(847)
543-9000
Attorney
Number
Bruce A.
Slivnick
Attorney
At
Law
707 Lake
Cook
Road,
Suite
316
Deerfield,
Illinois
60015
(847) 714-0503
Attorney
Number
6181410
2
S
CLERK’S
OFFICE
Certificate
of
Service
STATE
OF
ILLINQI5
Control
Board
Bruce
A. Slivnick,
an
attorney
hereby
certify
that
I
served
this
Notice and
Proposed
Discovery
Schedule
to
each
person
to
whom
it
is
directed
by
depositing
the
same
in the
Regular
First
Class
U.S.
Mail
from
Deerfield,
Illinois
60015
prior
to 5:00
p.m.
on
October
10,
2008.