Exhibit 24
JEAN ROACH
10-26-2006
..PORE _ '.E ILLINOIS POLL-: . :
CON TFOL BOARD
PICTIE :ykL ToypnNI,
9 , nitioner,
PEORIA OUT
: ROARS,
p-wranaent .
of JEAN ROACH, , material
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.
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nr ice anc - ne ~Ivtonne
Tuart Rww
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WE,vnolRTE,.a, and norarl Public
id : State of TIIor . Truisn,j,
October 2w
A, 14 ;, w- 416 Main trees, Suite -46-,
Peoria,
mxen~in a at or, L
11 :1C a .m .
UPEARANCES :
~LEP, ESQUIRE
.uncas
Street, Suit.
21,
Illinois
611 ,
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Pc-orbs,
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behalf
f the FCKI .onni ;
SkVID A . BROWN, ESQUIRE
.
B .aiA & Brown
. . N :air . Street
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Page I
FE%Pl& DISPOSAL COMPANY v . PEORIA COUNTY BOARD
I? C E? 0 (D -- 18 14
JEAN ROACH
10-26-2006
wait_ - , EDC
t~r_s cutter ENC,
Mart
_ter,
N C N N
WITNESS
JEAN RO .=.`_'F
Examination by Mr . u -pr
,
EXHtBItC
T
EI
Roach
cF Euhibit Inc .
Roach
Roa .-P: Exhibit No .
Roach Exhibit N-c.39
indicate=
L .
- ocnse1
; -
act
s were -.rhdrawr by rctit~ t
Fa e
PELPIA DISPOSAL COMPANI
PEOEiA COUITY BOAPC
PCB06-184
JEAN ROACH
JEAN NIARIU: ROACI I .
a material a itncss hcrom . being duE sworn .
exa nined and testified as Ibllows :
f:XAMINA""I ION
Bl' MR . Nit I :I .1 .1'R :
graduated from high school in Wisconsin . Then I
spent a year at the L niversit) of Wisconsin at Osh
posh
. transferred to Bradles where I earned nts 13A
and then ms MA .
-
-
•
What is your master's in?
A I think it was secondary ed . It's so long
ago . I believe it was in secondary education . No .
It probabl was in primary education now that I
think about it . I sot the secondary as
undergraduate
. So it was a priman . yes .
•
Are you employed at the present time?
A No .
•
W' hen were you last employed outside the
home?
A I retired from teaching in 2001
.
•
What was your last position in the teaching
profession?
A It was at Mossv ille Grade School teaching
sixth grade .
•
What does our husband do?
A He's retired .
Q
What was his profession?
A He was a university professor in Russian
history and director of international programs .
Q At Bradley?
A At Bradley
.
Q When did he retire?
A 2005, 1 believe it was . It's 2004, 2005
.
I'm actually not sure .
Q
Is he still doing any part-time things in
the nature of employment?
A No .
Q
Are either of you licensed Realtors or
brokers?
A No .
Q
What caused you to get involved in the
opposition to this landfill expansion?
A In January, I was reading my Sierra Club
newsletter and there was an article about it . I
began to do research, and I've just always been
pretty interested in the environment and also quite
interested in quality of life issues like air,
w
ater . e t cetera
. So that's what -- that was the
impetus for me to get involved .
Pages 3 to 6
PE 1A
DISPC3AL COMPAtIY
PEORIA COUNTY BOARD
PCB06-184
Q
A
Q
A
Q
Would you state your full name, please?
Jean M . Roach . Marie Roach .
Is it okay if I call you Jean?
Sure .
You're here today with your attorney
Mr
. Wentworth
A lbs .
Q Let the record show this is the discovery
deposition of Jean Roach taken pursuant to
1-":
subpoena, in accordance with rules and scheduled by
agreement of the parties .
16
Jean, what is your address?
1 y
A 837 Last I lishpoint retrace . and that's in
Peoria
. It's 61614 .
1
Q How long have you lived at that address?
A t en years .
Q Who do you reside there" ith?
A Nlc husband .
Q
His name is Elmo?
Page -1
A Yes .
I .
2
Q What is your telephone number?
2
3 A 692-0334 .
3
4 Q Do you have a cell phone that you actively 4
5 use?
6 A Yes . 1 do .
6
7 Q
What is that phone number?
7
8 A 696-3597 .
8
9 Q
Do you have an E-mail address that you
9
10
regularly use?
10
11 A Yes .
11
12 Q What is that?
12
13 A That's jeanroach . altogether .
13
14 jeanroach(alhotmail .co m .
14
15 Q Do you use any other E-mail accounts or
15
16
addresses?
16
17
A No .
17
18 Q Does your husband have a separate E-mail
18
19
account?
19
20
A No .
2 0
21 Q
Does he use E-mail?
21
22 A Yes .
22
23 Q
He uses also jeanroachat hotmail .cont
2 3
24
A Yes .
24
10-26-2006
Q
Do you ever post on any of the local blogs
vas
A
No .
Q
What is your educational background?
A N' ell . I'm originally from Wisconsin . I
JEAN ROACH
10-26-2006
g--
since I've been retired I've been . you know .
looking at and deciding where I would like-- what
organizations I would like to support .
When I was teaching . I didn't really have
the time to do that .
•
Jean, do you and your husband have any .
adult children that live in the Peoria area?
A No .
•
Before the landfill expansion project
started, did you know Joyce Blumenshine?
A No .
• So it would be fair to say that while you
were members of the Sierra Club it was pretty
nominal and inactive before all of this started?
A Yes .
•
After you read the newsletter from the
Sierra Club, who did you contact about further
involvement?
A
I think that I -- I alight hay e contacted
I(\ce . I'm actuall\ not certain because then I
also -- there were friends that I spoke vv ith about
the issue that knew something about the issue . and
it may hay e been them .
•
Do you remember who those friends were that
you spoke to about the issue that knew about it?
A It was Some people at Braile . It w as some
friends at Braille) .
•
Are any of those people that made public
15
14 comment at the hearing in this case?
-
A
I don't think so .
1 F,
Q Before the landfill expansion issue came to
17 your attention, did you have any special knowledge
l F about hazardous waste management or disposal or
'
about heavy metals, asbestos or other toxic
materials?
A
No
.
•
Do you have an family experience with
exposure to any toxic materials?
A No .
i-
i
oceanic a nlenlher otPeoria families . It vvas that
oc --those oho were concerned about the issue were
meeting . and I attended the meeting and I don't
cv en know at that point it' l knew it vats Families
or it it was Sierra Club .
But it vvas--vou knovv . both groups just
seemed to me to he working together .
•
where did those meetings take place at?
A Panache . lake' icvv Lillian were the two main
places that vv c met .
•
Any at the Universalist Unitarian Church
A Not that I attended .
•
Who was the leader of this opposition group
that as you say came together?
A Well
. I would sav it vvas very much
ajoint
etfon . bill it there vv as going to he a leader . I
suppose it w : s Kiln Conv ecse in the sense that she
sort of was uwrdmattng things
. I would sav it
\\ ;a \ er\ much a joint etlorl ` \k e were lust all
concerned about the Issue .
• When you say you were all concerned about
the issue, can you tell me how many is represented
by the word all?
A Well . I know Iliad but not because he's in
N isconsin . I le's gone to Wisconsin since then .
•
When did he live in Peoria?
A You know . I don't know other than he vv as
attending the meetings in Ianuan and in March . and
]'ill not -- I realh don't know .
Pages 7 to 10
P'G'a2 :A DISPOSAL COXPAINY
PEORIA COUNTY BOARD
PCB06-184
1
Q
I assume you area member of the Sierra
Q Are you also a member of Peoria Families
2 Club?
Against Toxic Waste?
3 A Yes .
A Yes .
4
Q Is your husband?
Q How did you come to join that group?
5
A I think we have a joint membership
.
A I belie\ e that it
\\as
that nrr\ lie %\ hell I
in
7
Q How long have you been members of the
contacted toA CC then there was - it scented to ]lie
Sierra Club?
that the' were working together . It all sort of
B
G
c\ol\ed .
-
A You know
. I don't know . I would sav
-
probably for tour or five years . I think fnole
I don't know it there was a nlonlent where I
A Be IS or ?0 . but I would sat\ the community
i in general then . It became a group w ithul the
1 -.
Conlinunit\
. So I Think it would he hard
10 Pill it
. _ number on that .
Q How many people would attend these meetings
typically?
A
I vv mold sav 10 to 12 . Ill to 12 people .
nwv he 15 .
'-
Q You're originally from Wisconsin . Do you
1 know Brad Stone?
JEAN ROACH
10-26-2006
Q Have you worked with him on any tasks
A Yes .
Q What board members did you talk with?
A On the telephone
. Brian Meginnes -- I mean .
Brian Elsasser
. excuse me. and Bob Baietto . Bill
Prather, Eldon Polhemus
. I think that might he ii .
Q I got out of that Prather, Baietto,
Polhemus and Elsasser.
A Maybe \\'idmer. I'm not certain whether I
spoke with him on the telephone or not.
Q Why those five or six?
A Well . A\ idmer is nn representative
. In the
case of Brian
. the only phone conversation I had
with him is with the very first E-mail that I sent
to public comments or to all of the board mcnmhers .
He responded by calling me to say that he
understood that it was an important issue and that
he would be looking at all of the evidence . It was
his phone contact with me
.
In the case of Bill Prather because I spent
ms career in Chillicothe and he's a Chillicothe--
lie's been a countv board member and Prather is sort
ofa name in Chillicothe . W'ho else .?
Q
Well, when did you talk to Mr . Prather?
A I actually don't remember . Oh
. I think I
Pa 10
spoke with him at a county hoard meeting . I'm
actually not certain . I think I night have tried
to call him . I'm not sure I actually made contact
with him
. I do know I spoke with him once at a
count\' board meeting
.
Q That leaves us with Baietto and Polhemus .
A And Polhenius because he wasn't at the first
vote, and so it was a contact to let him know
that -- hope lie was looking at all of the evidence
because it was important to look at all sides of
this issue and Baietto is a -- I actually think lie
was the principal at Richwoods High School when I
student taught there . From one fellow educator to
another .
Q
All of these contacts took place between
November 9th, 2005, and May 3rd, 2006?
A Yes .
Q
All of them were for the purpose of
expressing your view regarding the landfill
expansion?
A Expressing shy view and directing them to
the evidence, to he sure to look at the evidence .
what had cone out as part of the hearings, what had
come out as part of the --
was in the public
Pages 11 to 14
PEOP,IA DISPOSAL COMPANY
PEORIA COUDTY BOARD
PCB06-184
related to the activities of Peoria Families?
A Yes .
3
Q What specific tasks have you worked with
4
him on?
5
A Well, not specifically with Brad .
6
Q I'm talking about with Brad specifically .
7
A I don't know that I -- well . maybe with
8
Brad specifically in some of the things with the
9
IEPA .
10
Q What things has Peoria Families done with
11
the IEPA?
12
A
Met with then . discussed concerns .
13
Q
Is that a meeting that took place last
14
month?
15
A I don't think so . I was not in that
16
sheeting
. I did not attend that meeting .
17
Q Was there a prior meeting with the IEPA?
18
A Not that I know of.
19
Q You said you worked on the IEPA matters
20
with Brad Stone?
21
A
Via the internet . Nothing personal . I
22
haven't seen Brad in -- I don't know .
23
Q Have you been to any IEPA meetings?
24
E SOP
A No . I hay e not .
1
Q Did you participate in preparation of any
2
materials submitted by Peoria Families to the IEPA? 3
A I did .
4
Q
What materials were those?
5
A
Q
I in particular worked on the conclusion .
Did you work on a power point?
E
7
A No .
8
4
Q When you first started getting involved in
9
1 0 this process, did your husband get involved with
10
you?
11
A Not initially . but he did its a progressed .
12
Q Would it be fair to say that you got him
13
educated and then he got involved?
14
A Isuppose .
15
1 o Q
Between the two
of van, who was more
16
1?
active? You or your husband?
17
19 A I don't know . Probahlh me .
18
9
Q Do you recall sending various E-mails to
19
2 0
the members of
Peoria County Board?
20
2 A Yes .
21
Q Let's talk about contacts with the board
.
22
23 First of all, did vou ever talk to any county board
2 3
members by telephone?
2 4
JEAN ROACH
10-26-2006
record .
•
Directing them to specific evidence or just
to all the evidence!
A
I think sometimes sped lie --
'cll . hut
it's a general thing . I lealth issues_ the water .
those (sere the things that -- that stns the et idencc
that seemed particillarlr pertinent to nme . the
aquifer issue and the health issues
.
•
\ oil never called a board member to say, I'm
just calling to tell you to look closely at all the
evidence including Peoria Disposal Company's
evidence, did you?
A Probahlr not . I don't think I probahir
said look at --
•
In fact, you made it clear that you were an
opponent of the siting?
A Oh . N cs
.
• You would in these conversations direct
them to look at evidence that you felt justified a
denial of the expansion?
A Yes
. I would st\ primarih I did that
.
N es .
•
Mr. Polhemus would have been contacted
between April 6th and May 3rd
A
I believc--son knot( s'hal . I think that
phone call was hetbre because I think lie told me he
wasn't certain "helher he t\ as going to collie on
April 6th . I actuall' think it seas prior to as
I'm thinking hack on that eon'ersalion
.
I le vsas ill
wt,]
he said that he hadn't been
to the board meetings
. and he was ill and said Ile
didn't know v hether he'd he up to contiuu on the
April 61h meeting . So I heliete it \tas helbrc
the April 6th meeting .
•
Why would you have targeted him for a phone
1
call if you had no prior connection with him :'
A I don't knots thin I targeted hint as much as
ha scented to he -- he'., a Democrat and he -- there
didn't seem to he ap hods in the group t\ 110 \%0N
nccessarik Iron his dtstrtct, and so last to gnc
him a look al the e\ idcnac kind of a con\ ersatton .
• Did you and the other members of the Peoria
Families group divide up county members for the
purpose of determining who was going to personally
contact whom?
A I don't recall doing that .
•
Well, was it one of the strategies of the
2 4 Peoria Families that all board members should be
d
personally contacted by members of Peoria Families!
A I don't knot+ about ht ntcmhers of Peoria
paint. bill ht menthols of the comnuutily
. s es . that
we acre --
canted them to he contacted ht niemhers
of the communit_t svho tell stronglt about the issue.
cs,
•
Felt strongly meaning negativeh!
A Yes .
•
Did you ever attend any county board
meetings in addition to the meetings at the 111)0
Hall?
\
Yes,
•
Did you ever speak at art' of those county
board meetings'!
A One .
•
Which one?
V I think it was the
tort
first one vw hen the
ground rules were had for the -- for the expansion
process .
•
Let's go to that subject then . A meeting
where you said there were ground rules discussed?
\ Yes .
•
What was your understanding of what these
ground rules were
.qe
A
I hill it was to he an open process and thin
the comntunitr was
--
that citizens were lice to
speak with an\ and all of the how'd members on the
issue . that the hoard members \sere instructed not
to gi\ c u position . net er to state their position .
That Ihcx vtcrc in the process of gathering
wtorntalmn and (acts, hill that al all \ (line it,
elected othetais the could and should listen to
the constituents .
•
This is what you learned at a county board
meeting that you attended?
A
)
.
es .
•
Do you remember who the speaker was or
speakers were that communicated that understanding
to you!
\ Well . that was quite emit in the process .
I don't knots whether it stas Mr . Brown or it it was
kcv in [ .,on, . Scented to me it was alt altoinc\ . hill
I'm not sure .
•
Would it have been Mr. Atkins
A Min be .
•
Early in the process meaning --
A Fart .\ in the process for ate .
•
Somewhere in January, in the
Pages 15 to 18
PE-?1F. DISPOSAL COMPANY +. . PEOP :A COUNTY BOARD
PCB06-184
JEAN ROACH
10-26-2006
A
Yes .
•
Did you have an understanding as to what
the county board members ware to base their
_ ; decision on?
1_
A
The act, as giv en to them as the) came out
1
ol'the hearing and came out Of
Public comment .
.An'thing that was put into the public record
.
•
"'ell, if they were to base their decision
on the facts, what in your mind was the point of
them being contacted outside of the hearing process
by members of the public?
A lust to reinforce the intornwtion that was
coming out in the public hearing and the public
comment . 1 here was a lot of information and I fell
it w\ as important to -- s ou know . thev tt ere being
bombarded with information . It was important to
reiterate fix them .
•
So your understanding of the rules was that
contact with board members outside the hearing
process was appropriate as long as it was limited
to discussion of material in the record?
A Yes .
•
And by discussion of material in the
record, you felt it was fair to point them towards
certain material, correct?
A Yes . I think they were more general
conversations . look at the health aspect . look at
it's over the aquifer .
•
You pointed them to looking at the fact it
was over the aquifer, right?
A ( \\ itness nodding head tip and down.)
•
Whether or not that's a true fact, you
pointed them there?
A Yes
. It was my understanding it was --
• Did you feel it was fair to comment on the
credibility of things in the record as in so and
so's statement wasn't believable but somebody
else's we believe was believable?
A I didn't have those kinds of conversations
.
•
But did you feel that it would have been
appropriate in addition to pinning them to things
in the record to analyze or give them your analysis
Joyce Blumenshine since their depositions?
:A
1spoke with .lo y cc .
•
W hen was that??
-A On Iue,da%
.
•
Who else have you discussed the deposition
A Could > ou repeat -- could s ou ma> he clarilj
tt hat
sot'
re asking'!
•
Well, did you meet with any of them?
A No .
•
Did you ever go to any board members'
:qa
homes?
A No .
•
Did you distribute materials on a
door-to-door basis?
A Yes
.
•
Did any of those doors happen to belong to
county board members?
A No .
•
Were you involved in editing or selecting
content for placement on the Peoria Families
website?
A No .
•
Who ran the website, to your knowledge?
A I think Ted Converse .
•
W'ho was the fact checker for Peoria
10 : Families publications?
1 7
A I don't know if we had a fact checker .
•
Well, when you guys would, you know, issue
a flier or a leaflet, was there someone designated
to make sure that those things were true and
accurate?
A Oh . yes . I think -- I think as a group we
did that . I don't know that there was a designated
person . I think there were a lot of, you know,
4
Pages 19 to 22
PE'4IA DISPOSAL COMPANY . . PEOPIA COUNTY HOARD
PCB06-184
Januarv-February area?
of things in the record?
A
\'es .
A I didn't do that
.
Q \ on didn't get invoked until January?
Q Would that have been appropriate, though,
\ Right .
had you done it?
Q This meeting took place before the start of
A Don't knot, . I didn't do it . So --
the hearings at the ITOO Hall?
Q Have you talked to either Kim Converse or
i
process with besides Mr
. Brown or Mr
. Went" orth?
13 \ MN husband .
1
Q Anyone else??
\ No .
Q What you tell your husband is privileged .
i -
Did you tell -- did you ever have any other
personal contacts during the process with county
1-
board members besides telephone conversations??
JEAN ROACH
•
Did you have any conversations with any
board members at county hoard meetings or before or
after county board meetings
A Yes .
•
What board members would You have talked to
•
Did anyone ever tell you that you were not
supposed to draw county board members' attention to
evidence that you thought was particularly relevant
i
or important?
1"
A No .
•
How many such conversations would you have
had before, during or after meetings with various
board members in total?
A
I think those --
I think Baietto was that
Egg_
%sy lira) meeting when the ground rules were laid .
then those other three were alter the tote on
April 6th . that's it .
•
Do you remember a meeting of the Peoria
Families group where Kim Converse talked about the
ground rules and took the position that they were
undemocratic and unfair?
A No .
•
Did you regularly monitor the Peoria
Families website?
A I don't know about reguhnI . nwnitor
.
Looked in it periodicalh .
•
Did Tom Edwards ever attend any of your
meetings?
A Yes .
•
How many of those?
A I don't knot% . a couple . I would sat a
1
Ly Couple,
•
Do you consider him a member of Peoria
Families Against Toxic Waste??
A I don't think lie considered himself a
member of them .
•
Did you ever go any meetings of Citizens
For Our Environment?
rules during the hearing process applied to Peoria
Disposal Company and its representatives?
\
I he same ground rules as the ground rules
that we had
.
•
That we were also free to talk to county
A I ha e know ledge of a phone call Irom
\-0r . Mcginncs to M7. 1-.Isasser w hich w us --
t% high was
supposed to ha c been a threat that he'll net er
hold another republican position if he t ores the
w a% that lie does .
•
How did van get that knowledge about this
phone call?
A I belie'c it was Kim ('on erse .
•
How did she get her knowledge?
Page
:\
I don't know .
•
So you heard it from someone who heard it
from someone?
A Probahh .
•
Any other even secondhand knowledge of
contact between a PDC representative and a board
member while the process was going on?
.
A Not that I know (it . no . I just assumed it
%t as going -- it was taking place .
•
You didn't have a factual basis for your
assumption . though . did you?
A No .
•
Let me show you what has been marked as
Exhibit 76 and -- 86, excuse me, and this is a
group exhibit, and we'll send you and Mr . Wentworth
a copy and ask you if these are true and correct
copies of E-mails that you sent . Take your time.
A IN itness perusing documents
.) Yes
.
•
Those are all true and correct?
A Yes
.
•
Generally, how many E-mails did you send to
board members?
\
I kind of think that's it .
•
This might be the sum and substance of
Pages 23 to 26
IP. DISPOSAL COMPANY
PEOPIA COUNTY BOARD
PCB06-184
before, during or after county board meetings?
A
Pat Ilidden-Allen Maer . Boh Baietto and
Bill I'rather .
board members and direct their attention to certain
parts of the evidence that we thought were -- was
important?
Q What was the purpose of those
conversations?
A Say thanks for sour vore\
to drat their
attention to something that was
--
had been
mentioned in the meeting
.
' ;:
A Yes .
Q
Do you know whether any of that happened?
:A I assumed so .
Q
Other than assuming, do you have any
knowledge that any of that happened?
10-26-2006
just discussion, ghoul . all right . %vtrue do twe set
A No .
this inlorntation . how should we state this .
Q What was your understanding of" hat ground
JEAN ROACH
10-26-2006
them'!
A
I ttould sas it prohahlt is .
•
If I can direct you to item C in this
exhibit . I was looking through this one which I
just sort of randomly picked out anti wanted to see
if there's anything in there about pay particular
attention to the evidence and make your decision on
the facts, and what I found instead is language
that says, I believe you must vote no on the
expansion of the PDC hazardous waste dump.
Am I misreading this E-mail?
A No . I said that .
•
At the end of it you say, PDC's business
1 ! interests are not worth gambling with the lives of
children . Please vote no . Right?
A
1'es .
•
In fact, in this entire E-mail, the word
evidence does not appear, does it?
A No .
•
The word fact does not appear, does it?
A No . but there is information about lire and
that whole issue came up in the public hearing
. teas
_ ° part of the public record .
•
I understand there are assertions by you in
~uab
the E-mail, but the word -- neither the word fact
. . nor evidence appears
. correct?
A Correct .
•
Wouldn't it be fair to say that this E-mail
was intended to convey your very strong desire that
board members who read it and receive it vote no on
the application?
A Yes .
Q And you hoped obviously in spending the
1'5 time to write this that board members would
-- consider that in making their decision?
A I don't knots about consider . Consider it
aniong the es idenee . N es . One more piece ol . one
snore t ietc on the purl of the constituent \0 10 0 ould
he aIketed bt that expansion .
•
So the answer is you did want them to
consider your desire along with everything else
'. ? they were supposed to consider?
1
A I'nl not sure xt hat t ou're getting at .
•
What was your purpose in writing this
E-mail then?
A lit let (hem know that I teas tent concerned
about the possibilitt of lire and of children close
to the site .
Q Well, this doesn't say I'm concerned about
fire and children and want you to think about that .
It says, I want you to vote no based on my
concern, right?
A Yes .
•
I mean, you had concluded in your a" it mind
before you wrote the E-mail that the PDC expansion
4 with regard to the fire and children issues raised
in this E-mail was a bad thing?
A Yes
.
11_
Q What did you want board members to do with
1L that information?
A I'anted theta to look at the risks inu,hed
tt ith grunting an expansion .
•
Does it say in this E-mail look at the
risks involved or did it say please vote no?
A
I think it sat s look at the risks bt the
comment there is t crt real danger of flue due to
gases Iron this site and adjacent sites as
est ;thlislted Iron the tcstintnm M espcrts --
•
Does it say look at the risks, Ms . Roach
A
I didn't word it --
•
So county board members would have had to
read Your mind that you really didn't want them to
qC
vote no, you wanted them to look at the risks,
correct?
MR . N'EN I WORI 11 : Fill going to object to
that one . I hat's so hu speculilt loll that I don't
think it's capable of c\ ell being ansxtered .
MR MUE:I .I .ER
: I sill withdratt it
.
RY MR . MUI :LLh:R :
•
During this process, did you ever talk with
Carol Trumpe?
A
I don't recall it I did I did tell her
1
thank xou alter the tote . I don't recall it I did
~_ tit other time .
•
Which rote would it be that you told her
thank you lifter?? The April vote or the May vote?
A
I actuall_r think it was both .
•
Do you have a personal relationship with
Carol Trumpe?
A No .
•
She's not a friend of yours?
A
No
.
•
Is she an acquaintance?
A
No .
•
Do you remember appearing at a Peoria
Association Of Realtors meeting with your husband?
Pages 27 to 30
i'E_;p.IA. DISPOSAL COMPANY
PEORIA COUNTY BOARD
PCB06-184
JEAN ROACH
10-26-2006
you nor your husband are Realtors, correct?
A Correct .
Q How is it that you came to appear at that
. meeting?
A Via phone call, w ith the pent in Area
Realtors . their association . w ask them to -- as
it was part of the education ellurt that we were
in olsed in to ask them to look at possible real
i estate
ramification,.
economic rantifcations .
16
Q Who had initiated that contact with the
Realtors Association? You or the Realtors
Association?
A
I slid .
Q Is there any particular reason" hy that
22
duty fell to you as opposed to some other member of
Peoria Families?
2
A
I think it might lime been -- I think there
29 was just discussions . and it might hare been ms
idea that it seemed appropriate to contact them .
Q Was the gist of your initial contact to the
Realtor Association in the nature of are you aware
that the expansion of this dump is likely to reduce
property values?
12
MR . N'ENTWORTH
: I think she already
answered that . George .
THE WITNESS
: I can't do that here .
B Y MR
. MUELLER :
•
Following up with the Realtors, you
contacted them, and how did that get to the point
of your appearing at a meeting of the Peoria
Association Of Realtors?
A
Because I requested that we would like to
speak . It was a conmmnit) issue
. Realtors are
involved with their community and a very important
part of
their work and that this was a community
issue and that I'd like to speak with them about
it .
•
W'ho are you talking about at the Realtors
Association?
A Dallas --
I don't know what her last name
is .
P~:ae
•
Did she indicate to you that they would
give you an opportunity to speak?
A Yes
. She did along with the I'D(' . It would
he an e' en-handed
. that both sides would he aired
Ibr the local Realtors
.
Pages
31 to 34
PEORIA DISPOSAL COMPANY V .
PEORIA COUNTY BOARD
PCB06-184
A I would say that . yes .
Q Now, you didn't have any evidence that
Q Now, on that occasion, March 27th, when
that occurred who spoke? 1'ou or your husband?
property values would be reduced, did you?
A M' husband did most of the speaking
.
A
Actually . quite a lot . There's quite a lot
Q You did a little bit of it'!
17 written on the -- on the internet and there's lots
A Yes .
of sources of real estate magazines that there is
Q Would you characterize your husband's
evidence that that is a reality across the counts
.
manner at that meeting as being hostile?
Q Can you direct me to even a single,
A No .
specific source which confirms what you call that
Q Would you characterize his manner as being
reality?
confrontational?
h
A
I can't here . I mean, if I had the
A No .
. ?
internet and I had my notes and my information . I
Q Did he ever during his presentation come
1 E could . I can't do it here . I don't have anything
into close, physical proximity to members of the
here .
(oulter family for the purpose of emphasizing a
Q Do you deem the internet to be an
point that he might have been making?
t
authoritative source of information?
A
Don't recall that . I don't think so .
A
It can be .
Q
I mean, as you heard it, was there anything
Q It can also be a source of lies and
rude or unprofessional in your husband's
exaggeration as we learned in another deposition,
presentation?
A Yes .
isn't that correct?
Q When was that meeting?
A Other . sure .
A
the end ui March sometime.
Q So the answer is you cannot point me to a
Q
March 27th?
single source on --
that corroborates your
A ('ould he .
conclusion that proximity to landfills negatively
Q Now, you've already told me that neither
impacts real estate values?
JEAN ROACH
10-26-2006
A
I''ould characterize it as strong_ as 'cr'
strong. I wouldn't characterize it as rude .
•
Well, strong as in eloquent, persuasive
his position on the landfill expansion?
A I'm not sure I knot' "ho Doug Ste'tart is
.
•
Did you ever call any representatives of
National City Bank regarding the bank's position on
the expansion?
A Yes .
•
W' hat was the purpose of that call?
A To let them kntm that as -- I hank at
National Cit' and that I was disappointed with
his -- aetuall' . I think it was more to ask "Its he
would ha'e written something in support othee
landfill and to express to him mN disappointment as
a -- w ills his support 01 the landfill .
members to vote no?
A
No
. I would sa' the purpose was for then'
to become inlormed about this was all intportall
issue hetole the eommunit' and to heeonte cducaled
about it and then to contact hoard memhers haled On
their Yiew .
•
Well, wasn't it a constant theme in the
written materials issued by Peoria Families and on
their website that members of the general public
should contact their board representatives and urge
them to vote no?
A Yes .
•
And you participated in that on an active
and organized basis, correct
A Acti'e
. fill not ,[Ire''hat'on mean bi,
ogunized .
•
Did you go door to door distributing
leaflets that contained that material?
A l CS .
MR . \1 1IPLI .I :R : N c'rc going it) lake a
couple minutes
. N e may he close to being finished .
Pages 35 to 38
PEOP :A OiSPOSAO COMPAIIY
PEORIA COOIITY BOARD
PCB06-184
Q Did you threaten to take your business to
(Recess from 12 :00 it) I2
:05I
any other banks?
Ill' MR . MI, l[1 .1 .IR :
A
Q
No .
Did you imply that the bank's ongoing
3
Q Jean, did you write an article to the -- or
-aqe
letter to the Peoria Journal Star that was
support of the landfill would maybe cause you to
published on February 26th, 2006?
look at other banking alternatives??
A If I could look at it . I did write to the
A I don't think so .
4 Peoria Journal Star . So maybe I need to look at
Q Did you participate in contacts with
5
it .
educational institutions regarding the landfill?
6 Q (Exhibiting document.)
A I or instance.'
7
A
Yes . I wrote this .
Q Presentations to schools?
8
Q
Did you include the copyrighted PDC logo
Q
A NoLetting
.
information to schools or school
109
Journal
with your
Star?letter
or was that inserted by the
children?
11
A It must have been inserted by the Journal
A No .
12
Star
. I did not do that . I sent -- I believe I
~ . .- Q Did you contact any schools regarding your
13 sent this E-mail . I'm not that computer literate .
1 opposition while the hearing process was going on? 14 I couldn't have done it.
A No .
15 Q Let me show you what we have marked as
Q Did you contact any homeowners associations 16 Exhibit 89 and ask you to look at that and tell us
regarding the proposed expansion?
17 if that is a true and correct copy of an E-mail
A Yes .
18 that you wrote on or about April 6th .
Q Which ones?
19 A Yes .
A Mine which is the I lighpoint I lomeowners :
20 Q Who was the E-mail to?
1 and . actualh . I think that's the look one I did .
21 A To Bob Baietto .
Ile contacted 1[dgewildo
our homeowners association
.
22 Q In that statement or in that E-mail, you
Q W as one of the purposes of that contact to
23 state that Patrick Engineering has a conflict of
encourage those people to contact their board
24
interest?
speaking --
A Yes .
Q --or strong as in combative?
A Strong as in the first instance .
Q Did you ever call Doug Stewart regarding
9
JEAN ROACH
• Can you give me a single piece of factual
information that supports your assertion that
Patrick Engineering had a conflict of interest in
advising the county in this process
A
No .
•
So that assertion by you really would be
beyond information that was in the record, correct?
A I don't think I sa„ this as be' and
information in the record .
•
Well, the only information in the record
was that Patrick Engineering was a professional
consultant for the county in the process .
Ilow do we get from there to Patrick
Engineering had a conflict of interest?
A Because the'' re in the same business as
1'I)C' .
•
I'm in the same business as Mr. Wentworth
.
I don't think that gives him a conflict of interest
in representing you today, does it
,1
A
No .
•
Would it be fair to say that by
April 6th at least the comments and
communications with and to board members had
expanded beyond pointing to items in the record to
now editorializing about what you think various
information meant and signified?
A No . I don't think --
MR
. WI :NI WORIII : Objection .
MR . MI1IJIl :R : She anssccrcd the
1' question
.
MR . WI!N I WORII I : But you lust said
plural
. and s'e're onIN looking at one here .
know county board members' position on the landfill
expansion .
A It demands to knit NN hat the' -- Ns hat is
their position in terms of looking at both sides of
1C the issue.
•
I don't see the reference to both sides of
A
It doesn't speciticalh sin that . I hat "\ as
1E nmc intent .
•
What is your position on this expansion,
that's what you wrote, right?
1 Yes.
•
In fact, let's read the whole sentence
here, I sent this message 10 days ago and have
received no response . response being all in caps .
Are you elected officials who have a responsibility
to your constituents? What is your position on the
the issue, those words anywhere in these F-mails .
Can you point me to that'! Maybe I missed
expansion?
That's what you wrote .
MR . WEN I WORI 11 : Do Non understand the
question?
1111 : W I I NI .SS : I'm not sure .
BY MR . Nit itI .LER :
•
l on wrote that, what I just read into the
record, didn't you?
A Yes . I'm looking at this date and this sNas
helbre the ground rules had been stated at the
coon' hoard meetmg . and so m, guess is that n'
language is that''' because I didn't understand at
that point that the hoard menthe's "Nere not allossed
Pages 39 to 42
PErPIA D :SP .^.SAL
COMPANY s . PEORIA COUNTY BOARD
PCB06-184
MR . Mt'II .I .IfR : I hat's tine . She
anssccrcd the question .
BY MR . MI'FLLI :R :
Q Let's look at Exhibit 90 . Strike the
reference to 90.
1
to Lie their position .
It ssas at the subsequent hoard meeting
NNhich Ns as sometime in I'ehruun that then the ground
rules sere established . and so I understood that
hasicalIN that's "h' nobodc had responded to this
.
Let me show you 87 and 88 -- well,
1
Q Did anyone respond -- Mr. W'idmer apparently
20 87 first . Can you tell me what this represents?
2Z
responded to your E-mail of January 30th, though .
A
This seas the s erN first I1-mail I helics c I
2- didn't he?
2 4
sent to all the count' hoard members .
Q Well, I'm seeing a reference here, I sent
this message 10 days ago and have received no
A Yes . he did .
Q Did anyone else respond to that E-mail?
'I here yeas one other one . Who 'eras it? Oh .
10-26-2006
A I state it's a pussihilii'
response, response in all capitals .
Q Was that a fact?
A
Oh .
,
es . I sent the original 1 -hen I
A
Possihili' and stated Nsh, . It's in the
heard Iron, no one . I sent the lollo~s-up that I
stone business as PD(' . building and maintaining
has e recd' ed no response .
land III IS .
Q This basically' is an E-mail that demands to
JEAN ROACH
10-26-2006
6
24
Jeff Joyce .
•
Let me show you Exhibit 88 and ask you if
that represents Joyce's response .
A Yes . it does .
•
Now, is this the two E-mails -- the string
of E-mails, the January 21st and January
30th one, which Mr . Elsasser responded to by
telephone?
A
It is .
•
Are you a member of River Rescue?
A No .
•
You are a member of the Moss-Bradley
A I believe that was on the telephone .
•
The first vote being the April 6th vote,
correct?
A Yes .
Q Did you call her?
A Yes .
•
What was the purpose of your call?
A
1 o tell her that I 'N as ashamed that IIIn
representati'c would bane NNritten racist remarks in
the bloe and that in no "Na' represented mN t iests as
somehod' in District 11 .
•
What racist remarks are you making
reference to?
A NIe is N'idmer's bloe Site .
•
That conversation happened before the \lay
12 meeting, correct?
A Do N on slant to repeat the --
• Was it an organized effort on the part of
Peoria Families to have their members and the
24
public contact hoard members with their views and
Pages 43 to 46
D1SPSSA . . COMPAIS':
PECP.IA ccurrv RCAPD
PCB06-184
Homeowners Association?
A
Q
Yes .
A
Did Lynn Scott Pearson know that you were
Q
A
Q
A
No .
Have you ever spoken with Jim Thomas?
Yes .
When?
At a Democratic dinner in Mac
. I think it
an opponent of the landfill expansion?
A
Q
I don't think so . but I don't knoll .
Well, you had spoken at the public
hearings, hadn't you?
was in May .
A No .
Q
Q You had spoken at a county board meeting,
A
Before or after the vote?
It was after the vote .
21 though?
Q Did you ever speak to him before that time?
2)
A One count, hoard meeting
. Nes-theters
A
-
.
Q
No .
Are you active in Democratic politics?
24
frst one .
Q You had sent previous E-mails to Lynn Scott
6
A
Q
Somewhat, yes .
Are you a committee person or have any
Peace 46
Pearson urging her to vote no . hadn't you?
A
Q
the ones that I sent to e'erchod'\
hut .
Assuming she's of average intelligence, she
official role in the party?
A
Q
No .
Do you serve on any committees such as
would have known if she read suur
IF: mails if you
nominating committees?
were an opponent to the landfill?
A
Q
A
Q
No .
Have you ever spoken to Mike Phelan?
I don't believe so .
Have you ever E-mailed Mike Phelan other
'.0
A She could hate . She has a lot of people
that contact her. too . I don't hclic'e that I NN as
ancbod Special to her .
Q \P ell, were there a lot of other Peoria
than the E-mails that we have already identified?
-. Families people that were contacting her, to your
A
Q
No, I don't believe so .
Now, when I say speak with, I mean in
1
knowledge?
A I don't knoNS .
person at any location or on the telephone . Have
Q Was it organized effort to have Peoria
1' you ever spoken with Lynn Scott Pearson?
1 Families members deluge board members with is mails
A Yes .
~6
or phone calls?
Q
A
Q
When?
I believe it was after the first vote
.
Where would that conversation have taken
2r
A No . I don't think so .
Q If I take the word deluge out of that
question and substitute it with contact. would it
place?
then be a fair statement?
JEAN ROACH
10-26-2006
believed to be Mr. W idmer's racist remarks?
A Probahl .
1 3
Q Did you speak with Mr. W'atkins at any other
Q Well, probably or do you recall doing it?
A
Actually I recall his -- at a theater
production that his children were in seeing him
there and telling hint thanks then . His children
were in a performance at Peoria Players . and I saw
him and recognized him and told him thanks for his
ote .
Q Was that before or after May 3rd?
A You know . 1 don't know . It was whenever
Cats was at Peoria Players .
Pages 47 to 50
1A DISPOSAL COMPANY v . PEI PIA COUUTY DCAPD
PCB06-184
opinions?
Democrat to offer niv support in his reelection
A Yes .
campaign
. So sometime in the last few weeks .
Q Have you ever spoke within Junior Watkins?
Q Did you ever speak to him before May 3rd,
A Yes .
2006?
Q W hen was that?
A Not that I know of. no . I don't think so .
A I believe it \\ a, sometime hetneen the lx \,,
Q
Did you ever speak with Jeff Joyce?
otes .
A Yes .
Q What was the purpose of that call?
Q When?
A I o tell him thank v on .
A Probably it was after the vote to say
Q Did you also apologize to him for what you
thanks .
_1
ever try to communicate with him?
Q
A
One of my favorite musicals .
A I don't knoll
. I don't know that I did . I
Yeah . it's wonderful
.
2
don't really recall
.
Q
A
Q
A
Do you know Dr . Rodney Lorenz?
No
. I do not .
aqe
I assume you know John McLean?
Yes .
Q What about Allen Mayer? Have you ever
spoken with him?
A
To tell him thank you .
3 Q
When was that?
Q Was he a regular attendee of Peoria
4
A
After the first vote .
Families meetings?
5 Q On the phone or in person?
A No .
6 A In person .
Q Did he attend some of those meetings?
7 Q
Where?
A I don't think so .
8 A At the ITOO .
Q Do you know who the principal financial
9 Q
The actual night of the first vote you
benefactors were of the Peoria Families group?
10
spoke with him?
A No .
11
A Yes .
Q Did you contribute to the effort other than
12 Q
Mr. Watkins, did you speak with him in
N our time?
13
person or by telephone?
1< A Yes .
14 A I believe it was by telephone .
1
.I
Q
What was the amount of your contribution?
15 Q Did you ever speak with Dave Williams?
.A Probably somewhere between 1,000 and
16 A I really don't recall . I might have gone
S I .500 .
17 up -- there was a lot of them after that first
Q That would put you in the category of true
18 vote, and I may have gone up and said thank you
.
believer, I assume?
19 Q Did you ever call him on the telephone?
A Well, I believe you put your money where
20 A Not that I recall .
)our beliefs are .
21 Q Did you ever speak with Tom O'Neill?
Q Do you know Dr . Vidas?
22 A Yes .
A No .
23 Q When?
Q Do you know Dr. Zwicky?
2 4
A
Actual l, rather recently to --as a
A No .
ime other than that phone conversation?
1-
A
Q
I don't belie'eso .
I take it that was by phone, right?
L-
16
A
Q
A
Q
I helie\c it a as . scs .
Did you ever speak with Phil Salzer?
No . I don't hclie\e so .
Well, from one educator to another, did you
JEAN ROACH
1 6 May 3rd vote?
17
A Oh, before .
l. "
Q
Do you consider him a member of Peoria
-" Families?
2 ;i
A I don't know .
2 1
Q Did he ever come to any of your meetings
other than the press conference?
A None that I attended .
Q Do you know Joyce Flarant?
Pages 51 to 54
PEOP.IA. DISPOSAL COMPANY v . PEORIA
COUNTY
BOARD
PCB06-184
10-26-2006
Q Do you know Dr . Parker McRae
1
A Yes .
A No .
2 Q
How cloven know her?
Q Do you know Dr . Steven Smith?
3 A Well . I mean . I know the name because she's
A No .
4 president of Planned Parenthood and she seemed to
Q Do you know Dr . McGee?
5 sort ofjoin the effort . So she has attended some
A No .
6 meetings .
Q Then I'm going to guess that you were not
7
Q Do you know Mary Harkrader?
involved in the Peoria Families effort to get the
8
A I know of her . and I have met her at
medical community to support them, that other
9
Democratic party functions
.
people would have done that?
10 Q
Do you know Lisa Offutt or Peter Offutt?
A Y'cs .
11 A Yes .
Q My statement's correct?
12 Q How cloven know them?
A Yes
. Your statement is correct
.
13
A The% attended meetings .
Q Do you know Beth or Jeff Akeson?
14 Q They're Peoria Families people?
A I knoxk who the' arc .
15 A I assume so, yes .
Q Obviously, you know Tessie Bucklar because 16 Q Do you know Chris Ozuna-Thornion?
she was an active member of Peoria Families?
1
A I do not .
A I kno"N 1 essic .
18 Q Do you know Bill Scott?
Q Was her husband Tom also an active member? 14
A No .
A I would say no .
20 Q
Do you know Diane Storey?
Q Was he involved in any way in getting the
21
A I know who she is .
speaking engagement with the Association Of
22 Q Did she attend any of your meetings?
Realtors?
23 A Not that I know of.
A Not that I knot' ol .
24 Q
Do you know Mayvis Young?
Q
A
Q
Iron know all of the Converses, I presume??
Yes .
Did any -- do you know whether Converse
A
Q
A
t
Yes .
"'hat's your relationship with her?
I saw her at county board meetings and at
4
Marketing did supply printing and other similar
services to the Peoria Families group?
different functions . not at meetings
.
Q Did she ever attend --you just answered my
A I don't think so . but I don't know .
6 question .
Q
A
Q
A
Q
Do you know Bill Cook?
Well . I know of him
. I've met him .
In connection with this expansion proposal?
Yes .
Where was that? Just at the hearing or at
7 A No .
Q Do you know Barb Van Auken?
A No . I do not . I mean . I know of her
because of her political work .
MR . MUFLLFR : I think we're done .
a meeting?
T hank you ven much .
A I think the time I niet him was at a press
conference that we had at the I'nitarian Church .
(Further deponent sauh not
.)
1 C Q
Was that before or after the
JEAN
ROACH
10-26-2006
_'..rst
sworr :
-
1,
, .~
s ,
e '_ru ..
and r
.
'
:,e
.aid
;
e te. :stir
_,-
arr.i
__ ite
_ said W
rid alt--!W
u
-anscrir
-
_he testimony
aforesa
CO'_:NT
PEORIA
euciu
rr a
the Court
y c_
, ee_ia, state
i-roofs, t
:tereby
cert_fy shat
he-- ; : ,
Tore,
T ursa ,
Oc=
r
26t
006,
--- by
acreared
before me
-_
r P ir :
Ft teet, Suit
.
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10-26-2006
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10-26-2006
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10-26-2006
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JEAN ROACH
10-26-2006
Page 60
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10-26-2006
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10-26-2006
Page 62
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10-26-2006
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10-26-2006
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2003 5 :19
understand 27 :24 votes 25
:19 47
:7
25 :7,9 28 :18
wrote 29
:7 38 :7.18
2004 6 :8
42:3,12
vs 1 :5 55:5
31 :1 3 42:13.17
41 :18 42 :2.7
2005 6:8.8 14:16
understanding
45 :14 46 :6,10 .11
2006 1 :12 14 :16
17 :23 18 :14 19 :8
W
49:13 .15 50 :9
X
38 :2 49 :4 55 :920
19 :24 20
:16 25 :2
waived 56 :13
51 :7 55 :15
X 2 :9
56 :4,17
understood 13 :16
want 28 :16 29 :2.3
we'll 26 :15
204 1 :16
42 :17
29 :1134 46
:21
we're 37:20 40 :13
Y
21st43 :6
unfair 24 :7
wanted 17:4 27 :5
54:11
Yeah 49:22
26 2:16 55 :9
Unitarian 9 :20
29 :13 30 :1
whereof 56 :16
year 5 :6
26th 1 :12 38
:2 56 :4
52:14
wasn't
14:7
16:3
while 7 :21 26:7
years 3 :21 7 :9
27th 31 :4 34 :6
Universalist 9 :20
20 :19 37 :7
36:14
Young
53
:24
unprofessionaluniversity
5 :6 6 :3
waste 8 :18 9 :2
whole 27 :22 41 :20
Z
3 2 :12 55
3:9
34:23
24 :20 27 :10
until
19:3
water 6 :23 15 :5
Widmer
56:8
13 :8,11
Zwicky 50 :23
3rd
49
14:3,18
:16
5215:16:24
I
Watkins 47 :3,13
42:19
JEAN ROACH
10-26-2006
Pace 66
PER-'. COMPANY v . PEORIA COUNTY BOARD
PCB06-184
30th 42
:20 43 :7
360 2:3
38 2:19
4
402 :17
416 1 :12,19 56
:5
432 :18
5
528 1 :16
54 55:9
6
6th 15 :24 16:4.9,10
24 :3 38
:18 40:3
44 :22
61350 1 :17
61550 1
:23
61602 1 :20 2:3
616143 :19
692-0334 4 :3
696-3597 4 :8
7
76 26:14
8
837 3 :18
862:1626 :14
87 2:17 40 :19.20
88 2:18 40 :19 4')-"
89 2:19 38 :16
9
9th 14 :16
9040:17.18
Exhibit
25
CARA ROSSON
10-26-200(6
BEFORE THE I LLINOIS POLLIT=CN
CONTROL BOARD
PEORIA
DISPOSAL. C)M_AN'_,
PEORIA COINTY BOARD,
Resoonpent .
deposition cf SARA ROSEON, a material
'tress
_al_od o
na_ian c -suant
_e -
_ ._ Sccremc
Rules
they pertain
the taki
of ~
.very l p .. . it 1
before .era N .
Giftos,
RPR and N
Pu>_ _- in and for t .
County
of
Peoriaand State of Illinois, on Thursday,
October 26, 2006, at 416 Main Street, Suite 1400,
Peoria, =l-inois, coltmenc_ny at the hcur of 9 :00 a .m .
APPEARANCES :
GEORGE MUELLER,
IRP
CC
cw
Stre-'-,
,-'attr
Ot_ .,wa, I_rlnc_5
a .
JANANI NAIR,
;IRE
BRIAN .
. MEGINN E ESQUIRE
Elia
He :Cir jes, Riffle
hett,
u Main Street, .ii •- e _4" .
.-
Peoria, I_lincis
6160 :2
on behalf of the
t-ioner ;
DAVID A . BROWN,
Back, B_acK
Brown.
10_ South Main Street
.
Morton, Iilino_s kS0S
behalf of the Respondent ;
)NO . PCB O6-l84
Paae 1
PEOP.TA DISPOSAL COMPANY - . PEORIA COUNTY
BOAPL
PCB06-184
CARA ROSSON
10-26-2006
)AVIC ; ~ . WENTWORT9, E Q~=RE
h s_e'.ce
, ;ill~arrs, G he
Srto
ctr_s
Peoria, Ilolooris 61602
behalf
Sara Rossor ;
ALSO PRESEN'
: :
Royal Coulrer, PDC ;
Chris Coul_e-, PDC ;
N D t N
PIITNESS
CARA RCSSO
..
.
Exarr._ca`ion hr Nr . Noel_er
.
*EXI88I3ITE'
'_PENT =PIEP
Rossor : ~roor: P.xt cit
Ross ;.- : Exhibit Nc . '80
Rossor : E>:hi :it. Nc .
Rossor: Exhicir No .
pq . lc
Rossor: Exc_hi ;
ND .
. . . pg . 24
Ross-r: Exci_ No .
.
.
. c. a .
Rossor,
oar No . 8E
loci cat
e:hih is were wi ! .arawr .
. :ocriseattached r.ererc .
Paae 2
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
CARA ROSSON
blogs?
A
Sometimes .
Q Do you know what alias, nicknames or other
16
•
Are you employed at the present time
Yes .
•
Where?
A Bradles l'nitcrsit ,
•
In what capacity?
A I'm a research anal' st .
•
How long have you worked for Bradley?
A
Coming up on tno vears .
•
How long have you lived in Peoria?
A Coming up on two yeas .
•
How did you get involved in the opposition
to the landfill expansion?
A Started attending thelinivcrsalist
I nilarian Church here in Peoria .lanuan and the
first seekend oc wcnt oas neo member neekend
. It's
kind of o by oe went that weekend lhey Stood up
the new official members in the front of the Church
to neleonte them . and him and Ted Converse t\cre too
of those people .
"fhcs mentioned something about lighting the
landfillL and I approached her alter the set, ice
and said . hey . I'd he interesting in helping .
Q
Any particular reason why you wanted to be
interested in helping on a landfill expansion case?
It's pretty dull stuff.
A Seemed like the right thing to do
.
•
I believe at some point you made a
statement about allergies that you have?
A Yes. I think so .
•
Can you describe the allergies that you
have?
1
A
I had a doctor in I allahassee . Florida .
diagnose me with tshat's called generic or general
rhinitis
. So I hasc post nasal drip just about all
6 year,
1
Q Have you ever made the statement in any
"B blogs or in any communications to
county board
members or in any statements or submittals at the
public hearing that you believed your allergies
were caused or worsened by the presence of the
Peoria Disposal Company landfill?
A
I don't remember.
•
As you sit here now, do you believe that's
Pages 3 to 6
PECP.rA DISPOSAL COMPANY v
. PEORIA COUNTY BOARD
PCB06-184
10-26-2006
CAR A ROSSON .
Q What's your highest level of education?
a material witness herein . being duls scorn
. oa,
A I ha% e a master's degree .
e\ ain ined and Iestitied as Ibllows :
Q In what and from where?
I-NAMINAIION
%
In theater research from Florida State
NY MR . MI l .I,i,i R :
I tinesit
.
1 I
Q Would you state your full name, please?
A Cara (iazelle Rosson .
Q
Is it okay if I call you Cara?
A Sure .
Q Cara, you are here today with your attorney
David Wentworth?
A Yes . I am .
1 _
Q Let the record show this is the discovery
13
1 -
deposition of Cara Rosson taken pursuant to
14
1 s
subpoena, in accordance with rules and scheduled by 5
agreement of the parties .
What is your address?
1
5
A 901 Fast Mossv 'lle Road
. Peoria . 61615 .
1
Q How long have you lived at that address?
19
A A little oser a v car.
2'1
2 - Q
Who do you reside there with?
2 1
22
A My husband and m' tno hoes and in dog.
22
2 3 Q
Where is your husband employed?
24 A l Ie works at 13radles .
Q
A
oe
In what capacity?
lie's a theater professor .
2
Q
A
W hat is your telephone number?
579-2737 .
1
7
Q
use?
A
Do you have a cell phone that you regularly
Yes .
t
7
B
9
Q
A
And what is the number of that?
339-9733 .
1 G Q
Do you have an E-mail account that you
11
regularly use?
A Yes .
1 : .
1 i Q
What is that E-mail address?
1 I
A C ara . caratmgrope .co m .
11
Q Do you also post regularly on various
identities you use when you post on blogs?
21
A
Q
Cgazellel2,
Is that the only one you ever use?
2 -
A Yes .
22
2
Q
A
What is your educational background?
Could you he more specific?
CARA ROSSON
10-26-2006
I
the case?
A
A couple pieces . Hms Mould soil like me to
yuantitj?
•
Whatever way you can .
A About a pace north ma -\he of intbrnmtion
\ hen thinking ofa svehsite
. one pace of a \tchxitc .
a page worth .
• Were you the person that provided the label
toxic waste stacks for a photograph that was on the
Peoria Family website?
A No .
Q Do you know who did that?
A No
.
Q
Do you have any specific knowledge gained
before your involvement in the landfill matter
regarding hazardous waste management or disposal
A No .
•
Do you have any specific knowledge gained
before sour involvement in the landfill matter
regarding heavy metals, lead or asbestos?
A Passing knmvledgc about ashcstos I roll u\
dad .
•
What was the--tell me more about your
dad's connection with asbestos .
NIIt. WI :N I WOI(III : (icorge. I don't
Ec, e ~0
understand the relevancy of this line of quest ion .
I never have . and now that we're getting into her
personal stuff about her family . I -- I'm not
trying to he difficult . I just really don't know
where you're going and how it's relevant to
anything that's--
MR . MUELLER : It's a discovery
deposition . and to the extent that there's been a
lot of statements made about various kinds of toxic
materials by Peoria Families and their members
and
others. I'm just trying to understand the basis
of
people's knowledge . It's pretty preliminap _ and
I'm not going to go into depth .
MR . WENTWORTH
: Fair enough .
THE WITNESS : My dad is--wasa
mechanical -- he's retired, a mechanical engineer,
and I think there were jobs at the company he used
to work for where they do remove asbestos . So I
learned . and then news stuff on asbestos, you know .
you hear about schools having asbestos removed .
that kind of thing .
BY MR . MUELLER :
Q
Do you have any family members or close
friends who have been impacted by heavy metal,
Pages 7 to 10
PEOP :A DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
A
Q
I think it's possible .
Has any expert ever told you that your
allergies could be worsened by the Peoria Disposal
Company landfill?
A Expert --
Q
Doctor, scientist of any kind?
A I don't remember et cr being told that .
L
1
Q How close do you live to the landfill?
A Not loo . I think I'm on the opposite side
of tow n .
--
Q After your meeting at the Unitarian Church,
11
-' did you join a group called Peoria Families Against
13
'. 4 Toxic Waste'
1
7
7 6
A Yes .
Q W hat is your understanding of how that
1
u
group is organized and how it operates?
A I'm not sure-- hots do s oil
--
Q Well, is it a corporation?
20 A No .
22
21 Q Does it have officers?
r
22 A No .
22 Q
Does it have a board of directors?
2= \ Nr
Q Then who runs the group?
1
A Kim ('omersc . me . Joyce Blunienshine. It's
2
a group effort .
3
Q You mentioned Kim and Joyce. Would you say' 4
they're the two primary people?
5
A Yes .
6
H
Q To your knowledge, does Peoria Families
Against Toxic Waste have a membership list?
8
A No .
9
10 Q
Does it charge dues?
10
1 :
A No .
11
12 Q
Were you ever involved in adding or editing
12
1 3
content on the Peoria Families website?
13
A Yes .
14
Q What was your involvement in that process? 15
A I would I\ pe paragraphs or put information
16
7 together and f.--mail it to I ed Converse .
17
Q What was your understanding of who was
18
responsible for maintaining the website?
19
22 A led Converse .
2 0
Q Who provided the substantive content on the 21
_2
website? Did Ted or did you?
22
23
A I-vcrvbod'- There"asno--e Cr'hods .
2 3
24 Q
How much of it would you say that you did?
24
CARA ROSSON
10-26-2006
asbestos or other toxic materials?
A Not to my knowledge .
Q Do you remember on the website what
specific page it was that you added to it ?
A I scanted them to hear it as an elected
official .
Q What did you hope they would do with your
opinion once they heard it?
Pages 11 to 14
DISPOSAL COMPANY
V .
PEORIA COUNTY BOARD
PCB06-184
A No, I don't remember .
Q Are you a member of the Sierra Club?
A No .
Q Are you a member of Citizens For Our
A
That's their job .
Q Did you understand the decision that the
county board members were going to make on this to
be a legislative decision?
Environment?
A No .
Q Have you ever been to any meeting of the
1_ .
A Not sure . I'm not sure .
Q Well, you're the person that used the term
legislative .
Sierra Club?
11
So my question is, did you understand that
A No .
13
this was a legislative process?
1 4 Q To your knowledge, who handled the funds
1
A Yes .
1 - for Peoria Families?
Q Who told you what the rules were regarding
16 A Cindy McLean .
in
contacting board members?
1 7 Q
What was the role of John McLean in the
A
It %%as-- I think %se cot it Irons Uu%c
11 formation or operation of the Peoria Families
Brown . Yeah .
19 group?
i - Q Dave Brown told you it was okay to contact
A Very little .
2'0 board members directly outside the hearing process?
21 Q
When the hearings began in this case, what
22 A I think there was mention of it in the
2 2 was your understanding of the rules regarding
22 paper about the process . I don't recall it
s
direct contacts with board members outside of the
hearing process?
Pace 1 2
A My understanding was that I was allowed to
contact them to express my opinion as a constituent
but that they were not supposed to respond .
Q Then in your mind, what was the purpose of
4
speciticallc .
Q Well, to get Dave off the hook, did you
Page la
ever talk to him personally about the rules of the
process?
A No . not until -- %sell . the first time I
talked to Uas e personally was this morning, so. no .
G
P
11
contacting them to express your opinion?
A As a constituent . they're my legislator or
our legislators . So it's part of their job to hear
the voice of the people as an elected official .
Q
So, obviously, you wanted your opinion to
be taken into consideration in their
decision-making process?
A
I think it's part of their job to know my
opinion .
Q So the answer is yes?
F
e
u
Q So you read something somewhere that you
believe may have been a quote or a statement by
Dave Brown but you can't remember where, is that
fair?
A Yes . It ini~;ht h i%e been in the paper .
Q Did any of your comembers in Peoria
Families ever discuss with you what the rules of
the game were so to speak?
A I think we discussed it in meetings. Nes .
Q And would it be fair that Kim Converse
A I'm not sure
what
you mean the answer --
11 ` orchestrated those discussions or lead them in
16
could you repeat the question?
terms
of
talking about what you could and couldn't
17 Q
So you wanted board members to take your
do?
1
R
opinion into consideration in making their
A Yes .
19
decision?
Q Now, you indicated you thought it was
2 1.
A I wanted them to hear my opinion . It's
their job to figure out what they take into
appropriate to give board members your opinion?
A Yes .
22 consideration .
Q Did you also think it was appropriate to
Q Either you wanted them to consider it or
2 :4
give board members information of a factual nature?
24 you didn't?
A Information that was also submitted to the
CARA ROSSON
10-26-2006
F
record . 'Cs .
•
Did you think it was appropriate to give
A I
flC
Cr thought about it that tta) .
•
Did you think the same rules regarding
•
Cara, do you use any other E-mail addresses
besides Carangrope.com?
effort," is this something that you sat around and
compiled information and you went to the computer
and typed it?
A I don't remember how it teas compiled . I
know what people you got the facts from that you
didn't have at your immediate disposal?
A Other members of Peoria Families .
•
Which ones on this specific document?
A God, I don't remember .
•
Did anyone ever tell you not to talk to
county board members?
A No .
•
One of the documents you produced, and I
don't even know if we're going to mark it, is a
letter from State's Attorney Kevin Lyons dated
March 20th, 2006, to William Rutherford .
My question is, how did you get a copy of
that letter?
A No .
•
Did you speak on the telephone with any
Pages 15 to 18
PB.OPIA DISPOSAL COMPANY v . PEORIA .;,OtO]TY BOARD
PCB06-184
g- 16
ac, g,e
1F
A I ha'e a stork I`-mail . crosson'an
either
MR
. WIINTWOR I'11 : Do on
need to see it?
4
F
b radlec .ed u or bumaikbradles .ed u .
11111 WI I NESS : Yes . I need to see the
letter .
MR . MI'1(I .LL:R : this is 82 .
Q Did you use that E-mail address for any
communications with the county board in this case?
A
Q
No .
Do you have an E-mail address that is
(Rosson Exhibit No . IC marked)
RY MR . Nit :'I :1.1 FR :
carar&dougrosson .com ?
Q Let me show you that and ask you if you
1 ;1
A that one died .
Q
When did that one go out of effect?
A We stopped pa' ing that hill in the
know how you came into possession of that letter.
A I assume it came front the public record . I
don't remember .
~1 beginning of this summer . I don't remember .
Q Was William Rutherford a member of Peoria
12 Q The only names that you post under in blogs
Families?
1
would be Cara or c.gazellel2?
13
A No .
14
A Yes
.
1
Q Did he ever attend any meetings?
I
1c
Q Let me show you what's previously been
1 G
1
A Oh . no .
marked as Exhibit 65 and ask you if you know who
Q I think I might have asked this . Did
1 ? prepared that document .
1
anyone ever tell you not to talk to county board
20
A
Q
I think I did .
Now, you say you typed it . Did you also
1'^.
I S
members or communicate with them directly outside
the hearing process?
provide the content in it?
A No .
21
A That was a group ellhrt .
Q Did you speak personally with any county
22 Q
In other words, when you say "group
22 board members during this entire process?
board members commentary on information in the
record, meaning whether you thought the information
was good or bad?
just remember toping it mostly .
Q Where did you get your facts from in this
particular document?
i
9 Yes . I thought that ttas appropriate .
Q Did you want board members to take into
6
`c
A The second place is score card . Somchod'
had that at one of our meetings . The TRI came from
whichever the TRI website is . Do yon want the to --
I can sort of go fact by fact .
Q I don't need to go fact by fact. I want to
consideration in their decision-making process the
substance of any comments you might have made to
them on information in the record?
_ ;
contacting board members outside of the hearing
process applied to Peoria Disposal Company
1 e,
A
Q
Sure .
Are you aware of your own knowledge of
1 6
1
whether Peoria Disposal Company did contact board
1
members outside the hearing process?
1 P
1 a
A I hate no idea.
1 i~
2 -
MR . MIIh7 IJ'R : Oil the record
.
20
21,
(Discussion ott the record
.)
BY MR . MU11.I .ER :
CARA ROSSON
10-26-2006
A Three .
Q Only three different ones?
A I don't remember the exact number . Three .
A No. not that I know of.
Q Let's go through some exhibits here
. The
first one we've marked as Exhibit 79 . and I show
you a copy of that and ask you if-- this is a
group exhibit, by the way, being A through C, just
ask you if these are copies of E-mails that you
sent to the people indicated on the dates in
question .
A Yes . We haven't got through all of them
.
Okav .ves .
•
Then let's get to Exhibit 80 which appears
to be an E-mail string between you and Kim
Converse . l'ou can disregard the one at the top .
and ask you if, in fact, that's an accurate
representation of those two E-mails .
Actually, there's three there it appears
--
no, two . I was right the first time
.
A Yes . that's me .
•
Then I'll show you what we've marked as
Exhibit 81, and ask you if you can identify what
this is .
A A press release I wrote .
•
For whom?
A
For Peoria I-antilics .
•
Where did you get the information from in
P, e
this press release?
A The doctor bins . came from the doctors off
of-- off of their-- tile websites . They have
little bins on the company websites or whatever .
•
I'm guessing that you would have had to
communicate directly with one or more doctors to
help you prepare this press release, is that true?
A Actually, no .
•
Then who did you get the information from
meeting . too . We had a meeting at Peoria Ear,
Pages 19 to 22
PEOPIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
1
I
maybe four .
as to which doctors were opposed and so forth?
Q Were you involved ever in going door to
A Oh, I got that through Peoria Families in
12
door on anything?
their meetings .
A Yes .
Q Well, do you remember who at Peoria
1
Q
Where did you go door to door?
Families provided the information?
1-) A
Q
In the Edgewild Neighborhood .
Did you hand out fliers at people's homes?
A
Q
Kim .
Did you ever have any direct conversations
A
Q
A
Q
A
Q
Yes .
Who designed those fliers?
Tessie, I think Tessie put them together .
Do you know who printed them?
A bunch of people printed them .
Did Converse Marketing do any of the
1?
21
with any of the doctors mentioned in this exhibit?
A
Q
A
Yes .
Which ones?
I talked with Dr
. Vidas, maybe Dr . Zwicky .
That's it .
Q
A
Where did you talk with them at?
printing of fliers?
Dr. Vidas -- oh . Dr
. Crane . he was at that
feae 19
county board members during this entire process?
A I might have left a voice mail for Bill
Prather, but I never spoke to anyone .
Q Why Mr. Prather?
A Because I --
'-
6 Q
Did you send letters to any county board
members?
A E-mails .
Q So the answer to letters is no?
A No .
6
11
MR . WENTWORTH : George started to
1 2 interrupt
. Is this November 9 through May 3rd?
--
BY MR . MUELLER :
13
Q Yes . Well, I'm assuming that you didn't do
anything before you got involved in January 2006,
1
1 6 is that correct?
A No . I did not or that's correct . sorry .
Q So I'm talking about from the time you got
involved until May 3rd?
A I don't remember sending any letters . I
2C
21
remember E-mails .
Q You did send a number of E-mails to county
board members?
A Yes .
21
Q Did you send F-mails to all county board
members or target specific ones?
A If I sent
-- I think I sent them to most of'
them .
Q
How many different E-mails would you say
you sent to county board members?
1
e
CARA ROSSON
10-26-2006
\ose . throat and --
•
\ hen you sa) we had a meeting at Peoria
tar, \ose . Throat . who's "sac
A Mc tad Kiln ( omcrsc .
•
Met ssith sshom there?
A (ial, /sslcks and Vidas and ( rant .
•
Do you remember when that meeting happened
?
A No . awhile ago . It ''a, be lbre I "rote Ihls
press release .
•
Before they testified?
A I don't remen]her when then testified
. So I
don't remember .
•
But you met ssith them sometime before this
Families group?
4
A No .
•
Did any doctors ever attend any meetings of
Peoria Families?
A No .
• I'm looking at the Peoria pundit blog where
u you posted a message that said in part, I've done
.0 hours and days of research, talked to county hoard
members .
You previously testified that you did not
7 3 talk directly with any county board members in this
case.
1 ~
Does that refresh your recollection as to
whether you did or didn't?
A No . I didn't talk to any of the county
hoard members .
•
Well, then let's mark this as--we'll copy
^ this page. We'll get back to this .
Let me show You what's been marked as
2 2 No
. 83, and ask you if this is a true and correct
copy of an E-mail that you sent to the forum with
"'
4 copies to boards members on March 9th .
A Yes. I assume so .
•
Well, is it -- I mean, look it over and
tell us whether it is.
A
It look, like it is . sex .
•
Okay . The second paragraph in this E-mail
t is they don't seem to be considering the fact that
Pleasant Valley Middle School and several
residential areas overlook the toxic site .
Where did you get that information from?
A Driving through the area .
•
Is that your--
~-
A Gooele Earth
.
•
Well, which is it? Gargle Earth or driving
2C
A Not personally .
•
It's a fact that is not -- was not
previously in the record, isn't that correct?
A I don't remember.
•
Well, the reason I'm asking is because you
said you thought it was appropriate to comment to
county board members on facts in the record .
So my question is, where in the record did
this fact come from?
A
I he pleasant Vallcs Middle School fact :'
Q
Yes .
14
A I assume it "as in the record . It ryas
something I "as aware of lirom meetings .
•
Would it be fair to say it was something
you believed to be true but you weren't sure
whether it was?
A I had never stepped onto the grounds of
Pleasant Valley Middle School . So I can't
s
ax . n
o
.
•
Who did the fact checking for Peoria
Families?
A I :'er)hody .
•
Did anyone check your facts in this
Pages 23 to 26
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOAPD
PCB06-184
press release ohyiuusI)
:'
~~ through?
1
A
Q
Yes
.
N ho else %% as present besides the five
1r,
A
Q
Both .
Are you telling us that the landfill is
P people that you identified?
7 _ visible from Pleasant Valley Middle School?
1E A Ms lwn-scar-old Gahrlel .
1
;
A
It's up the hill lions it .
1 ° Q Do you remember who arranged that meeting :' 1 ? Q Well, you said they overlook the site . So
2
ryas it at the request of the doctors or at the
2 C
I'm assuming you looked and could see over the site
request of Peoria Families?
_4
from the location you've identified?
A I think it ''as hoth . Could you repeat the
A
I ncserspecilicalls --did 1? 1 don't
grtestion one more lime"
re nneniher es er going onto the grounds of Pleasant
Q Do you remember who arranged the meeting?
Vallcs Middle School .
Pap-= 24
A Kim Consersc and Dr
. Vidas .
Q Were any doctors members of the Peoria
Poyc
Q So that's a fact that's not verified,
correct?
CARA ROSSON
10-26-2006
A That's what I did here
. yes
.
Q You did not (to any of your personal
research to verify whether it was a true fact,
23 correct?
A
I took it -- like I said . I took it train
got contributions from any doctors?
A I didn't do the hooks . So I can't say for
tire .
Q Were you the main fact checker for
2 4 publications and other printed material prepared
Pages 27 to
30
c>FIA DISPOSAL COMPANY v . PEORIA COUNTY BOAPD
PCB06-184
1
particular letter?
the article which was about some on of ITA
2
A I would have . I distributed it to other
r eport
. t
o the best of ms knowledge.
3 members .
Q .As you sit here now, you can't identify
4 Q
Pardon me?
4 that article or where you read it, is that true?
5
A I would have done my own fact checking . I
A It was something we submitted to the
6
distributed it to other members to read .
record .
7
B
Q Now, then yon stated that the facility was
rated number one in air pollution in the State of
Q You believe you took it from something -- I
P
thought you said before you read it in a newspaper?
9 Illinois in 2000 having emitted over
A Printed it out .
1 0 18 million pounds of pollutants into the air.
Q Was it in a newspaper or was it --
11
Where did you get that information from?
A I read newspaper, online .
12 A It was -- I believe it was a newspaper
Q Or a submittal?
13 article .
13
A I read newspapers online . I printed it
14 Q
Do
you take everything you read in the
14 out. and I belie'c it was submitted to the record .
15 newspaper as fact?
MR . MIJE1 .I .NR : let', take a llse-mintile
16 A No .
1 r
break . We nms he finished or s as dose to
17
Q
However, you in this letter referred to
l i finished .
18 this particular statement as a fact?
-
(Recess tiont 10 :00 to 10 :05)
19
A I believe the newspaper article was about
'_
Bl' MR . MI'11 .112 :
20
an EPA review, submit--you know, quantities
Q Did you go to the meeting with the IEPA in
21 measured by the EPA . Illinois EPA .
Springfield recently?
22 Q
This date March 9th is actually after the
A No .
23
hearings .
Q Were you involved in the preparation of
24
Were you at the public hearings?
materials for that meeting?
_'aye
Pa,y
,
4
A Which ones?
Q The ones in February at the ITOO Hall
.
A I think I was -- is that w hen there was
se cral days in a row?
4
A No .
Q Did you ever send any E-mails to other
Bradley faculty members encouraging them to join
the opposition?
Q Yes .
A I was at one of them .
6
A
I don't think so . no . none that "aren't
alread' part of Peoria Families .
F
- .5
Q Were you at the public hearing in February
where evidence was elicited at the Annual Air
Pollution from the Peoria Disposal Company facility
is measured in the tens or hundreds of pounds?
A I don't remen'her .
Q Nonetheless, you wanted the county board I
take it to believe that the statement that
IS million pounds of air pollution is released
annually was a fact?
Q What other Bradley faculty members are part
of Peoria Families?
A Rick Stalling. Richard Stalling .
Q Anyone else?
A
That's the onls one I can think of right
nc
Yeah
. I think that's it
.
Q Is Dr. Crane a member of Peoria Families?
A Dr . Crane_ no .
Q When you went to the meeting at the Ear,
5
A I was merels citing, what I had read in the
Nose & Throat ('enter, did you receive any
-? article that I Ibund .
contributions from any of those doctors?
1 ? Q Well, you don't indicate it as citing to an
A No .
l . 9
article. You mention it as a fact, right?
Q
Do you know whether Peoria Families ever
CARA ROSSON
10-26-2006
hired local general engineering firm Patrick
Engineering?
A Yes .
•
Where did you get that information from?
A that tsas nn knowledge Irom the hearings .
•
The hearings that you attended one day of,
1 1 correct?
12
A I attended hearings with the \ otes tt ith
1
s
the--hack in I ebruun . Rhich hearings')
•
The hearings with the evidence you attended
Engineering?
A No .
•
Let me show you what's been marked as
Exhibit 85 ; and, again, this is a submittal from
the Peoria pundit blog, and if I direct you to near
the bottom of the page about the fifth line up, do
you see where it says, I have done hours and days
of research, talked to county board members, talked
with Illinois state officials, EPA and State's
Attorney's office, attended every public board and
committee meeting .
Is that your statement?
A That is ms statement here . yes .
Q You've testified today you never talked to
any county board members".
A I did not . no .
Q So when you made this statement, you were
not being truthful?
A I ttas not . I was exaggerating .
•
Did you ever talk with Illinois state
officials?
A Personalk .'es .
•
Which Illinois state officials did you talk
to about this?
A I have to think . Tom Davis .
•
Who's he?
A I have to think . He works -- he's an
attorney in -- he's in Springfield . I'm sorry
. I
don't remember which department .
EPA maybe .
•
What did you talk about?
.A The hearings. we talked about the hearings .
•
Who is this person Bill by the way that you
seem to address your comments to?
A
Bill Dennis, he is Peoria pundit .
•
Did you talk to EPA officials?
A I think that Tom Davis might have been with
he EPA . again . sorry .
•
Is he a state or federal person?
Page
Pages 31 to 34
PE'9PIA DISPOSAL COMPANY v . PEORIA COUNTY ROAPD
PCB06-184
one day, right?
A I believe so .
Q
Based upon that one day, it was your
knowledge that PDC had hired Patrick Engineering?
A Based upon nt) attendance during the Ma' and
-
1
A Tom Davis . state .
Q You said you talked to the State's
Attorney's office .
Who did you talk to in the State's
Attorney's office?
2a the April h earings . i t \gas im knowledge that I'M
A Again, that's probably Toni Davis .
2' had hired Patrick Engineering as well as the day
Q He's also an assistant state's attorney?
22
that I attended in Fchruan .
A Yes. yes .
23
Q Did you ever bother to check those facts
Q Would that be the Peoria County State's
24
and learn that Peoria County had hired Patrick
Attorney?
1 and released by Peoria Families?
2 A No .
3 Q Who would you identify as the main fact
4 checker?
4
5 A It was a group effort . depended on who was
6 tjpin_ .
7 Q So it would he fair to say there was no
8 main person that did that?
9 A True .
10 Q
You're a researcher, though, by training
11
and vocation, aren't You?
11
12
A
Yes .
12
13 Q So you understand about fact checking?
1 s
14 A Yes .
1
15 Q And even with that, they didn't rely upon
1
16 you to carry that ball?
1 6
17 A No . they didn't .
1 ~'
18 Q Let me show you what's been marked as
1 ^
19 Exhibit 84 . I didn't mean to fire that at you
20 across the table . It just slid .
21
This appears to be a submittal by you again
22 to the peoriapundit.com/blo g --
23 A Yes .
24
Q -- dated in May.
pay
Is this a true statement or is this a true
1
4
copy of your posting?
A Yes .
Q If you look at the last line you say, PDCC
CARA ROSSON
10-26-2006
reminded me of an item on my list.
Who is Brad Stone?
A Brad, he's a member of Peoria Families .
•
Where's Brad Stone residing at the present
time?
7a-7o 36
A
Ile's in Madison . Wisconsin . lies in
\k: isconsin . I think it's Madison .
•
Do you believe he's in Madison?
A
I think it's Madison . 'Cs .
•
When did he live in Peoria, if ever?
A
In the spring . the' Ii' ed here .
•
What's his wife's name?
A
Julia .
•
Is Mr . Stone affiliated with the University
of Wisconsin?
1 :
A Not to m' knot' ledge .
12
Q
What does he do for a living?
1=3
A lie runs sonic kind of computer business .
4
Q Do you happen to know his phone number or
. - address?
- 6
A I don't know his address . there's an off
i chance his phone number is in my cell phone .
186
Q When's the last time that you had any
'16 communication with Mr. Stone?
2C
A
F.-mail earlier this %\eck .
21
Q
I think we've confirmed that Tom Davis was
22 a person you talked to in Springfield?
23
A Yes . I le "as in Springfield lot sure.
24
Q
Your best recollection is he's with the
(Further deponent saith not .)
Pages 35 to 37
PE')FIA O=SPOSAI . COMPAI :Y v . PEOP.IA
COUNTY BOAPD
PCB06-184
Q So the majority of the statements in that
way to Springfield to meet with hint?
paragraph are, in fact, not true statements, is
that correct?
1
A
him .
Q
I never went to Springfield to meet with
A They're an exaggeration .
Then how did you talk to him?
Q What was the purpose of your exaggeration 1
A On the phone .
prior to the final vote?
1 6
Q
A
How did you get his name and identity?
A No purpose . just got carried away .
That I don't remember . I might have looked
Q
then .
Well, I don't have any other questions
Hang on . For what it's worth, Mr . C'oulter
it up on the state website .
MR . MUELLER : Thai's all we hare .
Thank you .
Faae
A No .
Q Who did you talk to in the Peoria County
State's Attorney's office?
state EPA?
A That or the attorney . I'm sorry .
Q Or is it with the .Attorney General's
A
Nobody that I remember .
Office?
Q Y on indicate that you attended every public
A He might be with the .Attorney General's
F
board and committee meeting .
Office. sorry
That's not true, is it?
Q Do you believe he's a lawyer?
A No. Because I didn't attend the whole 'seek
A Yes . I'm pretty sure he's a lawyer .
of February -- in February
.
Q What was the purpose of your going all the
CARA ROSSON
10-26-2006
-ATEF ILLINOIS
ES
cOON^_i
PEORIA
i
Aa_ :a M . Giftos, -SR,-
R-R, ana 1; a
ui f .~or the
7
I Lnc'_s
, her b ._ertify
-
on Ihurs i .y, Opt her Zcth,
ealIv acceared
before m
.
4 .6 Min Street,
40 , Peor_a,
ROSSON, a arterial ;:!mess herein .
further certify that the said witness was
by me first
swcr- : to
_e
whole truth and nothing
h
Lt - : :e
T" he cause
aforesaid ; -hat -he testimony -Then u ;.ven by s id
witness w . rep= t_ed sr_en~graph .a_Ty by me ___ the
esence said witness arid a_- r 'a_'.^.s
red-,,o
to
ty~pewrit_-_ and
foregoing is a ._t__ and correct
transcript or the testimony so given b
_y
said witness
as aforesa : .a .
to t~er certify teat the. signature of tae
witness was not waived .
farther certify -}:at T am not counsel for
nor in any way related to aT_y of t:
.-
,,rties to this
suit, nor am I in any way -r.tere e
the outcome
thereof' .
In tes-_
:roomy where
. t,
-unto
set my
lend and.
m notarl 7 sea un to/s day, Monday,
November 1/rh,
06 .
i:ana .
_i_tes,
Reporter
(- -e
Illinoisof
encires
OFFICIAL SEAL
AANA M GIFfOS
NOTARY PUBLIC
.
STATE OF ILLINOIS
MY COMMISSION
EXPIRES:07R4N7
Page 39
PEOPTA DISPOSAL COMPANY V . PEORIA COUNTY BOAPD
PCB06-184
about 6:1,9
.15 9 :4
9 :20.22 10 :1 .9 .20
13:22 14:1 .16
15:11 19:18 27
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29:1 31 :13 33:6
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1 :14 2:1
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31
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28 :17 .19 29
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C
CARA ROSSON
10-26-2006
Page 40
cause 39 :8
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cell 4 :5 36 :17
Center 30:16
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39:12 .14
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29 :16
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34 :9
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39 :22
committee
13 :11
35 :6
communicate
18:18 22 :6
communication
36:19
communications
6:18 16 :4
PEO _A DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
assistant 34 :21
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3 :8
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CARA ROSSON
10-26-2006
Pace 41
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10:8 38 :8.11
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6 :11
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PEORIA. DISPOSAL COMPANY
V . PEORIA COUNTY BOARD
PCB06-184
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10-26-2006
Page 45
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124 2:3
13th 39:17
1400 1 :12,18 39:5
182:19
27
:10 28 :14
2
20th 17 :22
2000 27:9
2006 1 :12 17 :22
26 1 :12 38:9
26th
39
:4
3
32 :12 38 :9
3rd 19 :12,19
312 :21
33 2:22
339-9733 4 :9
360 2:1
37 38:9
4
416 1 :12.18 39:5
5
5281 :1_5
579-2737 4 :4
6
61350 1 :16
61550 1 :22
61602 1 :19 2:3
61615 3 :18
65 16 :16
7
79 2:16 21 :2
8
80 2:17 21 :10
812 :18 21 :19
82 2:19 18:4.5
83 2:20 24:22
842 :21 31 :19
85 2:22 33:4
9
919:12
9th 24:24 27 :22
9 :00 1 :12
9013 :18
CARA
ROSSON
10-26-2006
Page 46
PE' )R
:A DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
14:3 19 :14 272 :13
X
24:19 25
:2 .13.19
X 2 :9
26:7 28
:18 32 :21
35 :17
Y
went
5
:20.21 16:24
Yeah 13 :18 30 :12
30:15 37:11
year 3 :20 6 :16
Wentworth 2 :2
years 5 :13 .15
36 :10
19
:15 38
:920
withdrawn 2 :23
39 :4.17
witness 1 :9 2:10
204 1 :15
3 :2 10 :15 18 :2
212:16.17.18
39:6.7.9.10.11 .13
24 2
:20
Exhibit 26
0
PEORIA COUNTY BOARD,
)
Respondent
.
)
The deposition of AMY CONVERSE SCHLICKSUP, a
material witness herein, called for examination
pursuant to notice and the supreme court Rules as
they pertain to the taking of discovery depositions
before Aana M
. Giftos, CSR, RPR, and Notary Public in
and for the County of Peoria, and State of Illinois,
on Thursday, October 26, 2006, at 416
Main Street,
suite 1400,
Peoria, Illinois, commencing at the hour
of 3:45 p.m .
APPEARANCES :
GEORGE MUELLER, ESQUIRE
528 Columbus Street, suite
204
Ottawa, Illinois
61350
and
JANAKI NAIR, ESQUIRE
BRIAN 3 . MEGINNES, ESQUIRE
Elias, Meginnes, Riffle & Seghetti, P
.C .
416 Main Street, Suite
1400
Peoria, Illinois 61602
on behalf of the Petitioner ;
DAVID A . BROWN, ESQUIRE
Black,
101 south
Black
Main
& Brownstreet
Morton, Illinois 61550
on behalf of the Respondent ;
2
1
APPEARANCES : Cont'd
2
HAL SCHLICKSUP, ESQUIRE
124 southwest Adams, suite 360
Page 1
102606 Amy schlicksup .txt
1
BEFORE THE ILLINOIS POLLUTION
CONTROL BOARD
PEORIA DISPOSAL COMPANY,
)
Petitioner,
)
-vs-
)NO . PCB 06-184
3
Page 2
3
102606 Amy schlicksup
.txt
3
Peoria,
Illinois
61602
4
on behalf
of Amy Converse schlicksup ;
5
ALSO PRESENT :
6
Royal Coulter,
PDC ;
7
Matt Coulter, PDC ;
8
I N D E X
9
WITNESS
10
AMY CONVERSE SCHLICKSUP
11
Examination by Mr . Mueller pg .
12
13
EXHIBITS
14
None marked .
15
16
17
18
19
20
21
22
23
24
0
1
AMY CONVERSE SCHLICKSUP,
2
a material witness herein, being duly sworn, was
3
examined and testified as follows :
4
EXAMINATION
5
BY MR . MUELLER
:
6Q
would you state your full name, please?
7A
Amy converse Schlicksup .
n
102606 Amy schlicksup .txt
8
Q
How do you want to be addressed?
9
A
Amy .
10
Q
That's fine . Thank you . Are you here
11
today with your attorney Hal schlicksup?
12
A
Correct .
13
Q
Let the record show this is the discovery
14
deposition of Amy schlicksup taken pursuant to
15
subpoena, in accordance with all the applicable
16
rules and scheduled by agreement .
17
could you give us your address, please?
18
A
4533 Grandview Drive, Peoria Heights,
19
Illinois, 61616 .
20
Q
who do you reside there with?
21
A
My family .
22
Q
what's your husband's name?
23
A
Andrew schlicksup .
24
Q
what does he do for a living?
1
A
He works at Caterpillar
.
2
Q
what is your telephone number?
3
A
685-8410 .
4
Q
Do you have a cell phone that you regularly
5
use?
6
A
I have a cell phone that I sometimes --
7
it's like a car phone .
8
Q
Did you make any phone calls ever to county
9
board members on your cell phone?
10
A
Never .
11
Q
what is your highest level of education?
12
A
A bachelor's degree .
Page 3
4
E
102606 Amy schlicksup .txt
13
Q
From where and in what subject?
14
A
University of Illinois, communications
.
15
Q
Do you have an E-mail address that you
16
regularly use?
17
A
Yes .
18
Q
what is that?
19
A
Amyc@conversemarketing
.com .
20
Q
Is
that a business E-mail or a personal
21
E-mail?
22
A
Business .
23
Q
Do you have a personal E-mail account that
24
you use?
1
A
Not really
. i use my daughter's if I --
2
Q
where are you employed?
3
A
Converse Marketing
.
4
Q
what's your job responsibility there?
5
A
Can you be more specific?
6
Q
well, what's your title?
7
A
vice president .
8
Q
How long have you worked at converse
9
Marketing?
10
A
Ten years .
11
Q
so you would have worked there when Peoria
12
Disposal company was a client of Converse
13
Marketing?
14
A
Yes .
15
Q
Did you ever do any direct work for Peoria
16
Disposal company while you were --
while they were
17
a customer of converse marketing?
Page 4
5
0
102606 Amy schlicksup .txt
18
A
I did not .
19
Q
was there any information that you ever
20
gained about the operations or practices of Peoria
21
Disposal company that you used or revealed to any
22
other person in connection with the landfill
23
proceedings?
24
A
No .
1
Q
When did you become -- let me back up
. Did
2
Converse marketing provide anything of value to the
3
Peoria Families Against Toxic waste by way of
4
consulting services, advertising, printing, any of
5
the kinds of things that the company does?
6
A
Nothing .
7
Q
Now, your brother's Ted Converse?
8
A
Correct .
9
Q
You're a member of the Peoria Families
10
Against Toxic waste?
11
A
No .
12
Q
You are not?
13
A
No .
14
Q
Do you know who maintained the website of
15
Peoria Families Against Toxic waste?
16
A
I don't know -- not -- no .
17
Q
Did you ever provide any material or
18
editorial content that ended up on that website?
19
A
Nothing .
20
Q
when did you first become involved in the
21
opposition to the landfill expansion?
22
A
can you clarify that question?
Page 5
6
0
0
102606
Amy Schlicksup .txt
23
Q
when did
you --
24
A
I think I have an answer .
1
2
3
4
5
6
7
A
No .
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Q
okay . Go ahead .
A March 30th
when I -- the date I sent this
is the date I did
anything that had to do with the
landfill situation (indicating) .
•
Did you attend any of the hearings at the
ITOO Hall in February?
• were you encouraged by anyone at the Peoria
Families Against Toxic Waste to contact your county
board representative?
A
I
believe I was on an E-mail chain, but I
don't even recall what was on that E-mail, but it
talked about -- I believe there was --
I'm trying
to remember whether it was an E-mail or a
conversation but said there's a date to contact the
county board if you feel like you want to have your
opinion heard, but I don't recall whether that was
an E-mail or a passing conversation .
•
Is
the E-mail that you've provided which is
I believe dated march 30th or march 29th the
only communication that you ever sent to county
board members?
A
Yes .
Q
1
A
Yes .
Did you know Meg whitmer?
Page 6
7
8
D
Page 7
102606 Amy
schlicksup .txt
2
Q Did you ever talk
with her about the
3
landfill proposal?
4
A Never .
5
Q Did you ever
go
to
any of the board
6
meetings at
the ITOO Hall in
April
or may?
7
A
Never .
8
Q Did you submit
any written comment besides
9
your own letter?
10
A Nothing .
11
Q
Did you ever talk personally with Michael
12
Phelan about anything between November 9th, 2005
13
and may 3rd, 2006?
14
A Never .
15
Q
Did you ever talk to anyone else in which
16
there was a conversation about finding an opponent
17
for Mr . Phelan in the selection if he did not vote
18
against the landfill?
19
A Never .
20
Q
Never heard anyone else talk about that
21
either, is that correct?
22
A Correct .
23
MR . MUELLER
: Let's take a very short
24
break .
9
1
(Recess in proceedings .)
2
MR . MUELLER
: Amy, thank you very
3
much
. We have no further questions .
4
5
(Further deponent saith not
.)
6
0
102606 Amy schlicksup .txt
10
1
2
6
PEORIA COUNTY BOARD,
)
7
Respondent .
)
8
I hereby certify that I have read the
foregoing transcript of my deposition given on
9
October 26, 2006,
at the time and place aforesaid,
consisting of pages 3 through 9 inclusive, and I do
10
again subscribe and make oath that the same is a
true, correct and complete transcript of my
11
deposition so given as aforesaid .
Page 8
BEFORE THE ILLINOIS POLLUTION
CONTROL BOARD
PEORIA DISPOSAL COMPANY,
)
Petitioner,
)
-vs-
)NO . PCB 06-184
0
24
sheet(s) .
noted .
102606 Amy Schlicksup .txt
Please check one :
AMY CONVERSE SCHLICKSUP
subscribed and sworn to
before me this day of
, 2006 .
STATE OF ILLINOIS :
: SS
COUNTY OF PEORIA .
I, Aana M . Giftos, CSR, RPR, and Notary
Public in and for the County of Peoria, state of
on
Illinois,
Thursday,
do hereby
October
certify
26th, 2006,
that heretofore,
personally appearedto-wit,
before me at 416 Main Street, Suite 1400, Peoria,
Illinois :
AMY CONVERSE SCHLICKSUP, a material witness
herein .
I further certify that the said witness was
by me first duly sworn to testify to the truth, the
whole truth and nothing but the truth in the cause
witness
aforesaidwas ; that
reported
the testimony
stenographically
then given
by me
by
in
saidthe
presence of said witness and afterwards reduced to
typewriting, and the foregoing is a true and correct
transcript of the testimony so given by said witness
as aforesaid .
I further certify that the signature of the
witness was not waived .
I further certify that I am not counsel for
nor in any way related to any of the parties to this
suit, nor am I in any way interested in the outcome
thereof .
Page 9
Notary Public
My commission expires
I have submitted errata
No corrections were
11
U
102606 Amy schlicksup
.txt
17
In
testimony whereof, i hereunto set my
hand and affix my notarial
seal on this day,
18
Thursday, January 4th, 2007
.
19
20
Notary Public
21
22
Aana M . Giftos, certified shorthand Reporter
(State of
Illinois License #084-003571)
23
My commission expires 07/24/07 .
24
Page 10
E,-~hiBit 27
CATHY STEVENSON
10-26-2006
POLIoTI
TO T:<OL
yRO
s
Fr)_AR
?`
,
Z h
31
-''. C
. :
E'' .D,.)
ons
Asia
1=tos,
.u
,arv ru ~_~. _n aru _,_ the
County c
and ;.tare
,I1_ccis, on Thursday,
October
eor'_a,
_ :nc
'mrrer
. gin"
ci
:37
-
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JA : :AwI OA~k, =dQG_nc
B3La.P; ~ . h_ECINTEI, ES4l'r:. . ..
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:he
EAU .,
Q)FIT
Page I
75PO 3 A : . COMPANY
PEOEII+ COUrIY L+OAP.L
PCB06-184
CATHY STEVENSON
10-26-2006
r
Examinarion by Mr . Mue'__er
.
EXHiB1-T
) 71F E: : .'
S
c E . :hibi
,,~eca-. .=or. E . :h1 ri`
~ : :h :b_~
vw-e :,
counsel ;
at _ached he •-etc
Page 2
PP,v7IA. DISPOSAL COMPANY
PEOPIA COUCTY SOAPD
PCB06-184
CATHY STEVENSON
10-26-2006
C
(A 111) :\ . s 11 vl.NSt I\ .
:I m :uerial wiuicss herein . being duls s"Orn . was
esalnined and Iesldied as lblloo5 :
If\ANII\ :\ I ION
13\' MR . Yll'11 .LI .LR .
•
\\lml d y ou state sour name, please?
\ ( athn n A . Stc clison .
•
\ In are here today a ith your attornes
Mr . Schlieksup?
A
I ani .
•
Let the record show this is the deposition
of ('athnn Steyenson taken pursuant to subpoena and
in accordance with rules and scheduled hs
agreement .
lion would you like me to address %ou?
A Lath' 'c line .
•
Thank you . (ath .N, can you give us your
address :'
A 4536 North Miller
Asenuc in 1'curia Height,
IIImois.
•
Ilon long lone \ on Iii ed at that address?
\ I en s ears .
•
\\ ho do you reside there u ith?
A Ms hushand Rob Vtesemon and III' daughter
Elizabeth .
•
Where is your husband employed?
A Smith Barnes .
•
As a broker?
A Yes .
•
What is your telephone number?
A 685-7681 . area code 309 .
•
Do you have a cell phone that you regularly
use?
A I do . 309 --
MR . S('HLI('KSLP : Counsel . what is the
relevance?
MR . MUELLER : We're checking sonic
phone records and so forth .
MR . SCHLICKSLP
: What's the relevance
of that?
MR
. MUELLER : With regard toes pane
communications ss ith county board members .
THE WITNESS : I can tell you I never
made a call to a county board member .
MR . SCHLICKSLP : Thai's fine . For
that purpose . I don't have a problem .
Go ahead and tell hill
.
THE WITNESS : 309-453-6954
.
BY MR . MI, ELLER :
• Let's actually move right forward based on
what you're going to volunteer so I can expedite
this .
Did you ever call any county board members
during the time that the application was pending?
A
It's niV recollection I did not . I think
I -- this is -- I stay have attempted to call
NIr . Phelan early . early on .
Then I think something came out in the
paper that said they could not contact or talk to
you
. So I think that was it . So I Ina' have left a
message
. and that was
--
that would have been it .
•
Did any county board members call you?
A
No .
•
Do you have an E-mail address that you
regularly use?
A I do .
•
W hat is that?
A Rts3rniinsightbb .cont .
•
What is your highest level of education
just by way of general background?
A A bachelor degree .
•
In what field?
\
I iliance .
•
Are you employed outside the home?
:\ Not amniore .
•
Where were you last employed?
A
It was Baslcr I lcalthcare Professionals. It
was a spinoll'that would hale been called
.Allegiant
IIcallhcare .
•
How long ago" as that?
A
I lcli there in 1998 .
•
While you were there, did you form arty
acquaintances or acquaintanceships with any of the
doctors that made public comments or testified at
the landfill expansion hearing
:'
\ No .
•
Do you have any personal or family
experience with exposure to toxic materials, heavy
metals or asbestos?
\ No
.
•
Do you have any training or expertise prior
to your involvement in this project with hazardous
waste management or disposal?
A No .
•
When did you become involved in the
opposition to the landfill expansion?
Pages 3 to 6
D=SPC.SAL COf9PAtJY .' PLC! :A COU!:"Y 8OAPC
PCB06-184
CATHY
STEVENSON
10-26-2006
A
I don't think it wwas until -- I had been
approached in November of last year. I think it
was kind of sketch.\ to sign a petition, and I
refused to sign the petition because I realk
didn't know too much about it .
Then I think I billowed things in the
paper, and so I'm thinking sometime Februan maybe
.
When you say invoke
. I would sac --
•
I will follow up on that . When did you get
active in terms of doing things?
A When you sir, active be doing things--
•
Volunteering time or effort on behalf of
any citizens group involved in opposition .
A I wasn't a member of a citizens group
. I
would say I prett\ much was independent_ and that
probably wouldn't have been --you know . putting up
card signs would have been not until Nlarch
probably
•
. sometime in
March.
Are you a member of the Peoria Families
Against Toxic Kaste Group?
A I'm not .
•
Have you ever been?
A No .
•
Is there a reason why You did not join with
them?
A I ne%cr ease it unuidswi0n . I %sas me%cr
asked .
•
Have you ever been to any of their
meetings?
A
I ha\ c not . I ss Clot to the Sandra
Stemgraher prescntutitn . but that was not u
meeting .
•
[lave you donated money to Peoria Families
Against Toxic waste?
A I did donate names for the Sandra
Steingraber . and I think I ease them Sl0ll %%hen thev
%sere asking tar said signs .
•
Are you a member of the Sierra Club?
A No
.
•
Are you a member or have you been a member
of Citizens For Our Environment?
A No .
•
Do you know Joyce Blumenshine outside
having talked to her casually at the siting
hearings?
A No . I do not .
•
What was your understanding about the rules
which governed the siting procedures in terms of
contacts between citizens and counh board mcmbers?
\
Iheonlsrole I\\asa,sareofwaswhent
canto uu1 in the paper that hoard inenthcrs were not
allowed lo--Kcs inLyons .State's \norncs .said
that the\ could 1101
Clint IluutWine with--the\ Could
not hag a consenmion with ntc
. hot I s%as not
as' are of amsthing
.an' otherstipulmion-
•
\\ er e %oua,sarcatanytime ofans
limitations on sour ability to contact board
members s% ith dour opinions or s iews?
V
I was assure of the public comment date :
hosseser
. I''as lull assure that that was the end ota
point in time that I could no longer Coal tnunicate w
Ills
hoard member and express ans 0111111011 its a
concerned ciliien .
•
[)lot you eser hasc A
con,crsation nith Kim
Cons erse about what the rules for the siting
proceeding %sere?
\
No
. I maul . ills conlelsat loll mill hint v%a
pretty limited . Prohahh the most I learned about
the siting criteria \%a, al -- either in the paper
or one of the meetings %%hen the_% talked about it
''as haked ill the criteria itself :
•
Kim is a loose relatise of %ours?
A Correct .
•
By marriage, isn't she?
A Right .
•
Do you see her frequently on a social
basis?
A I see her at Illh hirthdaN parties . On
that side
. there's two children . So it would he
limited to twit or three times a .\car . and the) lust
joined Peoria Count% C'hth'%high we're a memher oil
I .s en moss and then I would see )let there
. No . I
would nal .';s we're regular . social --
•
All right . She's been identified by a
number of people as the de facto leader of the
Peoria Families group, and what I'm wondering was
whether you ever went to her to get advice on how
to do the opposition or whether she ever came to
you to enlist your help with things that she was
interested in related to the opposition?
A \\ hil l I would Ilave receised linen Kim were
I -mails that they generated a list of I think
ans one w ho had sent a tenet or 1-
..-ill ail Io the
pu1ie comment list and then the) drafted an F
: mail
contact list .
I think that's where I would reccisc Peoria
Pages 7 to 10
DISFO3
C .. PAII'
: oI
. PECtPTI, ;OU119'1 [1')ARD
PCB06-184
CATHY STEVENSON
10-26-2006
to send those E-mails?
A
I wouldn't call it inspiration, but I -- my
motivation, if that's what you're asking me, to get
involved was based on . as I said . I read things in
the newspaper . I was concerned about some of the
issues regarding the trench C I or whatever it is :
but regarding the older section of the landfill and
that was in the paper and there was sonic breach
that was -- there "as agreement be both experts . I
was concerned about that . I felt strong Is enough
about it that I wanted to speak at the hearing
about it .
That prompted me to attend portions of the
hearing
. and having attended portions of the
hearing . I was concerned or I had
-- I guess I was
concerned about the fact that there seemed to he a
lot of time spent discrediting witnesses for the
opposition
.
I felt more time should be spent on -- it
was a simple case of there's some holes
. you get
the answers, you provide the answers, and
\ Oil
mote
On .
So I felt -- in that situation . I didn't
feel
--
I felt like the burden of proofs' as on
citizens, not on the applicant
. That concerned me
as a citizen just as an individual .
•
How many days of the public hearing in
February did you attend?
A
I think I was there for three
. I think it
was .
•
You said you thought there was a lot of
time spent on discrediting the --
A In the time that I was there .
•
In the time that you were there?
A Yes
.
•
This was hack in February?
A Well, actuall\ maybe March . I don't know
the exact dates of hearing .
•
Well, the hearing was five consecutive days
at the ITOO Hall .
A Okay .
•
So that's the time period . I'm not trying
by discrediting the opposition witnesses other than
me cross-examining a couple of them?
A
Aell . it mast base ban son cross-examning
their . I tell that in its opinion and it ill,( -- I
elt that the public had the right to express their
opinion . and I felt that should he respected .
I didn't feel son here respectful of that
right . and it kind of just . I don't know . energized
file . sshatescr . I lust tell it wasn't appropriate.
and it -- lot file pe onalh a made me ,_o home and
,start to do sonic research and look into it and get
more Ins ohed m the issue .
•
The Peoria Families group maintained a
website
:\ Yes .
•
Did you periodically visit that website?
\
I did .
•
That syebsite and publications, fliers and
the like put out by Peoria Families on a pretty
regular basis encouraged individuals to contact
their county board members to urge them to vote no
on the application .
Did your seeing that literature and/or
seeing the website cause you to believe that those
kinds of contacts with county board members were
appropriate?
V1R . S('111 .ICFSt'P : I want to interrupt
here . (ieorge, souse asked a lot there . \k list don't
sou break that doss n . and the tlrsl puns mire kind
of making a staicnient .
N hs don't son ask her first it that's what
she saw on the ss chste rather than sou trs to has c
i
her assume that that's aetualh w h a
t was there .
then follow it
tip
with the last pun of the
question .
MR. MI!III .I .I(R : I think it ssas clear as
it sent
. but Cur enough . We'll break it down .
Dl' NIR . M L 1,111A
•
N ere you aware that Peoria Families'
literature and their website was encouraging the
public to contact count) board members to urge them
to vote no?
Pages 11 to
14
F I
t :_ : . ., 4O"'FA"Y ' . . FEORIF
UIITY HOARD
PCB06-184
board members
though, when the witnesses were testifying?
A
Q
I did .
Where did you get the idea or inspiration
\
Q
Yes .
Can you give me an example of what you mean
Famil E-mails or sshate%er. but like man' of then .
to trick you with dates .
I didn't even read them in some cases .
A Vu. no- I lust don't hase the exact dates .
Q You did send a number of E-mails to county
Q That's the hearing you're talking about,
CATHY STEVENSON
10-26-2006
1
b
A
I don't know if I recall that direct]) . I
know it was urging -- my impression at least and mf
involvement w ith asking people to put signs in
their yards related to that was that people weren't
aware and the) weren't aware of what was going on .
They weren't even aware in mans cases the board
Members -- the) thought the_% were going vote on the
issue themselves .
-
So . no . I don't know that that's what I
took away from it . I took away from it it was
educational, and it prompted me to do some research
on my own in terns of what information was out
there . I didn't necessaril' just take theirs
. I
did a lot of searching of websites and things as
)cell .
•
Did you ever communicate any of the
information that you got in your searches to any
county board member?
A No . My F-nails were -- I obviously read
them . Most of them were reactions to a document
that had --
either a doer rent or a meeting that I
sat through . but nn recollection is that's what my
E-mails were based on .
•
Did anyone ever tell you that it was not
appropriate to contact board members with your
views outside of the hearing process?
A No .
•
Were you involved in placing yard signs in
various areas of the county?
A In a limited area of the county . yes .
•
W' hat area of the county?
A In the neighborhood I live in which is
Peoria Fleights
. kind of Grandview Drive . and then
in the Edaewild Subdivision .
•
Is that something you did on your own or on
behalf of Peoria Families?
A Basically on my own . INN sister . obviously
Tessie Bucklar. had asked if I would help
distribute some yard signs and I told her I would .
We did it on I think two afternoons
.
•
Were you able to get some yard signs into
the yards of a couple of local doctors?
A Yes
.
•
Which ones?
A
Dr
. Rhode lives by us . Dr . McRae . Dr. Norm
Meyn who he had actual] contacted us asking for
one . the Akesons . Dr . Akeson, the) had actualls
asked for one
. There's another doctor on Prospect .
I can't think of his name . lie's an e)e doctor .
I hose arc the ones I can think of right now
•
Now,
the two doctors that asked for signs.
who did then contact to ask for them?
:\ 13cd1 Akeson had called me Mr, . .\kwon
. and
c
mkcd for one . Norm Me) n I think had s nt an
I -mail to the the wchsne I hen that's how we cot
them .
•
If sou weren't a member of an) citizen
groups, how would Beth \keson know to contact ou?
\ I low would Beth Akeson know to contact nc?
Q 1" .
.\ Because she saw lie sign in nt' \ ard . \\ c're
friends . I Bean . there's-- but shedefnnch sans
the sign in nix
s
and and she uucnded portions of
the hearing-
• Did Nou escr speak directly with ans counts
board member during the time that the application
was pending?
A No .
--
Q Did \ou eycr attend and regular counts
board meetings other than the hearings which wcre
at the ITOO Ibill?
A No
.
P- :yF
•
Did you ever send any letters by regular
mail to any county board members?
A No .
any
Q Let me show you what we've marked as
Exhibit 90, and tell you that this is what we
believe is a copy of some of your E-mails . It's a
group exhibit, and all we want you to do is review
them and authenticate them as being true and
correct copies of E-mails that you would have sent
or that you did sent], I should say
.
A ]]lose appear to be nv It-mails .
•
Let me show you what we've marked as
Exhibit 91, and this appears to be a letter you
would have written to the newspaper . Do you recall
writing that?
A Yes .
•
What did you mean by the current breach in
that letter?
A
I here was an article in the paper That -- I
think I rclcrred to it earlier that stated that
(here \N u, a preach and that both en ironrnental
e\parts on both sides
. and I'm semiyuoting I think
the paper . hN stn ing that both sides agreed that
there was a hrcach in the older section of the
a
Pages 15 to 18
PEOP
"ISP[SAI, COMPAEY
PEORIA COUNTY BOAPD
PCB06-184
CATHY STEVENSON
10-26-2006
andlill .
•
I'm particularly interested in where you
remember or believe you got the word breach from .
A The% ma% ha, e called it a leak . Breach .
I'm not -- I doll t -- it's kind of semantics to me .
but I hasicall, was referring to the article that
was in the paper .
•
That was --
MR . SCIII .ICKSI'P
: George
. I Inst want
to dunk something . \\ ha
t you had referred to
1 1 when
v
oil handed ('alhs the docununts earlier it,
group exhihit vsas I-:xhihit 90?
13
MR . MI 1 1-.I_CIJt : Yes .
MIR . IRS(,I11 .1('KSl'P : U'hat''e hale is
eshihiI entitled I:yhihi1 104 is ss hat she Ies icssed
and handed hack -
(IJiscusslon oll the record .)
131" MR . Nit II :I .I .FR :
1
Q Was Mike Phelan pour elected county board
member?
A Yes .
•
I think you indicated that you had learned
at some point earh on that you could express your
views to county board members but they were not
1
able to express theirs to you, is that correct?
A Ms understanding is correct is that w hat I
read ill the paper said that the public hoard
tncmhers could not or ss cry ads iced not in
eonmnillicatc to -- so ss babe, they could or
couldn't . it lust said that the\ ss ore ads iced I
hclicse not to communicate to citirans . vCs .
•
If I can show you a copy of a three-page
document which we're marking as Exhibit 92, this is
I will represent one of the documents that you were
11 kind enough to furnish us today .
['his purports to be an 1:-mail from you to
. .
Michael Phelan, correct?
A Correct .
•
Is this a true and correct copy of that
E-mail
A It appears to he a true and correct cops oI
tile I
:-mail . \es .
•
I notice that the second paragraph on the
first page is a one-line paragraph that says, I
would be interested in knowing your position on
this issue.
A Correct .
+
Q (( an you explain for us why if you had heard
2^
9 ,
or read that county board members were not to
express their opinions as late as March 2nd you
were still inquiring of Board Member Phelan what
4
his position was?
A First of all . I don't know schcn I hceamc
exact)\ aware. but ['III
conlidcnt that I did lot
--
iN on look Lit an' thin , else . I ncver . esen
cncouraecd it .
My guess is that this inav has r hccn -- rust
likels sots hctbre I hccumcaware ol'that . I don't
has c the exact date of that : hoses er. I feel s en
conlidcnt that I would not
have
done that Laid that
most likels -- this is 'hen -- "hen I casc'on the
dates
\
\hell
I Lot in\oked- this is scr\ close to
the initial part of it . I'm s eq conlidcnt that I
would not have hccn aware of that at that time .
•
If I were to tell you that March 2nd is
after the end of those five days of consecutive
hearings with witnesses at the ITOO Hall, would
that refresh your recollection as to when you
became aware of the hearing rules or procedures??
A That would tell me that this seas hclbre .
Because as I mentioned . I didn't really e\ ell
!n et
ins ohed until that point . It seas alter those
hearirnLS. and if sou refer there . suti lI see that
this is hasically pro iding him the c0loolenls I}ont
the tearing itself :
•
Now, you have me confused because I thought
that you said you attended most of the hearings
E because you were already involved . Now you're
saying you didn't get involved until after them .
A No . I said that I got invoked because I
a read some articles in tile paper that alluded to
this . whatescr sou'd like to Call it . hrcach oi-
l '. leak . and that made me decide to attend portions oI
I :: the Public hearing .
13
AI the Mondas
--
so I -- I know I was there
nn tile Sanodan hclbrc this and then that Mundav
1' cscninu I think it %v as . it was a Mondas . I actuall.\
went and I presented this
information at that time .
and that was what I would consider my initial
imokement .
•
was when you made a public comment at the
hearing?
A Yes .
•
Then this letter to Mr . Phelan post dates
that?
A
13s I think a few das s . I don't know if
Pages 19 to 22
P=i, 99`t!PAI,Y v . PEORIA COUNTY BOARD
PCB06-184
CATHY STEVENSON
10-26-2006
Its-- I don't remember the ewct date, of the --
•
Now, if I can show you a cope of what we've
marked as Exhibit 93 . this again is a document
which you were kind enough to furnish to us, and I
would ask you if this represents -- is a true and
correct copy of an E-mail string between apparently
you and Patrick t rich on the dates indicated .
1'e, . It appeals to he . s c, .
•
First of all, how did you know that -- who
Patrick ( rich was??
\
1'nh in inc to thlnl, caactl w here -- I had
attended - . again . I'll) not sure esacth what this
was . but I had attended a meeting al the I IOO 11,111
ss here he presented the counts hoard's -- I belies e
Ile presented the counts hoard', recommendation is
what it was . but I don't remember w hat that mectim
;
was called .
•
Your recollection is actually very good .
If I can direct you to the response from Mr. Urich
on the bottom of the first page, the one starting,
Cathy, I just got off the phone with Mike Phelan .
A
Right .
•
What is that in response to and how did
Mike Phelan get involved in this series of
r :
communications?
A I have no idea . I assume Patrick Urich
must have received m< L-mail and I'm assuming he
,must have looked to see what district I was in, and
he must have contacted Mike Phelan to sa_v I
received this . That's the -- those are all
assumptions . all speculations .
•
You'll see the last thing he says in this
note at the bottom of page I, Feel free to contact
Mike or I with any questions .
A Okay .
•
Did you contact Mr . Phelan after receiving
that information?
make clear that thev were -- sure that thev were
clear that I was not part of the so-called
opposition group that they -- I think he was
referring to Peoria Families, and that was that .
• You just used the word they several times
in your- answer . Who are you referring to? You
felt that they were trying to use you to negotiate
.
Who were they?
A If ton read the comment that is there and
the fact that Patrick and Mike sent me the E-mail
and then When then made that c
omment . i t made tile
feel uncomfortable that I sent back and just said .
Hec . I've got nothing to do with that and I don't
want to be put in the middle hasicalI'
•
So you must have gotten a separate E-mail
from Mike Phelan then?
A I did not .
•
It says . I received your two subsequent
E-mails, to Patrick at the top of the first page .
A Okay . So I've got one is this really
leneth_t one I sent . two is this other one .
•
Did you ever get the spreadsheet?
A Yes . I did .
•
And what did you do with the spreadsheet
once you got it
\
I looked at the spreadsheet and I did pass
it on . I think I sus in here it's ou'd like she to
pass it on or I will go ahead and pass it on . So I
passed it on to my sister and told her if she
r
scanted to pass it on to someone in the group feel
h cc to .
•
That explains what I was inquiring about
.
Let's take a very brief break . We may be done .
(Recess in proceedings .)
B1' MR. MUELLER :
•
Just a few more brief questions .
Were you involved in soliciting or
PCB06-184
A
I did not and I don't believe. and I'll
double check right here, that I even copied him on
my responses or communication hack and forth . It
doesn't appear that I did .
Q Well, isn't Mr
. Phelan copied then on your
next E-mail after that, the one dated April 20th?
organizing the medical professionals oppositions to
the expansion in any way, shape or form?
A
Q
A
No .
Do you know Dr . Yidas?
I ha\e hand of his name . and that was the
Iron time I'd e\ cr seen him seas there .
A Oh, yes . I will tell you why that was . If
Q Do you know Dr. Zwicky?
you look at that bottom paragraph . I felt as if
A I do know DI' . /sticks
.
they were trying to use time to negotiate sonmething .
L
Q Did you ever talk to him about this
I did not want to be put in that position .
proposal
If he was involved in that . I wanted to
A Proposal mcaning7
Pages 23 to 26
___-
_C :-0PAL7't
PEORIA OnUATY BOARD
CATHY STEVENSON
10-26-2006
Q The landfill expansion .
A We talked at the hearings and . I mean .
m aybe at a cocktail party or something he mad have
4
said something about it . but not in depth . Tic) .
5
Q Do you know Dr. Lorenz?
6
A No .
Q Obvioush, you know Dr . McLean?
8
A I've probabl% only met Dr . McLean a couple
9
of tines and talked to him .
10
Q I think you said you placed a sign in
1'_ Dr . Parker McRae's yard?
12
A Yes .
13 Q
So you know him?
14
A Yes .
15
Q
Socially?
1 c
A
lie's a neighbor, a friend .
17
Q
Dr. Steven Smith?
1 8
A
lie's a friend as well .
19 Q Dr. McGee?
20
A I do know Dr . Jim McGee
.
21 Q How do you know him?
22
A There's two . One is a radiation
23 oncologist . His daughter goes to school with our
2 4 daughter and has been friends forever . and then
1
there's another one that's a radiologist that I
2
just know him socially through the Country Club .
3
Q I'm going to ask you about Bill Scott . Do
4
you know him?
5
A I don't think so . Is he a physician?
6
Q
He's a doctor .
7
MR
. MUELLER : Thank you ven much .
8
Cathy . We don't have any other questions .
9
10
11
(Further deponent saith not .)
12
13
14
15
16
17
18
19
20
21
G2
23
24
Pages 27 to 28
?EC .%.IF. DISPC3&7 . COPIPAtJY V .
PEORIA COUNTY LOA PD
PCB06-184
CATHY STEVENSON
10-26-2006
STATE
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APPEARANCES
1 :14 2:1
appeared 30:4
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20:17 23 :8
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CATHY STEVENSON
10-26-2006
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PEOPP. :A CJUM"Y DUAPE
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PCB06-184
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PCB06-184
CATHY STEVENSON
10-26-2006
Paqe 32
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corrections 29 :15
Coulter 2 :6 .6
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30 :14
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10-26-2006
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10-26-2006
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10-26-2006
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DIANE STOREY
10-23-2006
BEFORE THE ILLINOIS POLLUTION
CONTROL BOARD
PEORIA DISPOSAL COMPANY,
1
Petitioner,
)
I
-vs-
)NO . PCB 06-184
PEORIA
COUNTY BOARD,
Respondent .
The deposition of
DIANE STOREY, a material
witness
herein, called for examination pursuant to
notice and the Supreme Court Rules as they
pertain to
the taking of
discovery depositions before Aana M .
Giftos, CSR, RPR, and Notary Public in and for the
County
of Peoria, and State of Illinois, on Monday,
October 23, 2006, at 416
Main Street, Suite 1400,
Peoria, Illino_s, commencing a-_ the hour of 2 :00 p .m .
APPEARANCES :
GEORGE MUELLER, ESQUIRE
528 Columbus Street, Suite 204
Ottawa, Illinois 61350
and
JANAKI NAIR, ESQUIRE
BRIAN J . MEGINNES, ESQUIRE
Elias, Meginnes, Riffle & Seghett_, P .C .
416 Main Street, Suite 1400
Peoria, Illinois 61602
on behalf of the Petitioner ;
DAVID A . BROWN, ESQUIRE
Black, Black & Brown
101 South Main Street
Morton, Illinois 61550
on behalf of the Respondent ;
Page 1
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
DIANE STOREY
10-23-2006
ALSO
PRESENT :
Royal Coulter, PDC ;
Chris Coulter, PDC ;
Matt Cculter, PDC ;
Jeff Coulter, PDC ;
Jane`-
LeMaster .
N D E X
WITNESS
*Indicates exhibits were withdrawn
by Petitioner's
counsel ; not attached hereto .
Page 2
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
DIANE STOREY
Examination by Mr . Mueller .
. . pc . 3
*EXHIBITS
IDENTIFIED
Storey Exhibit No . 44
.
. pg .
26
Storey Exhibit No . 45
.
. pg .
27
Storey Exhibit No . 46
.
. pg . 30
DIANE STOREY
1n-2
,
~-nnnti
1
9 the opportunity to record this deposition, and just
10 for the record, we're declining that request, but I
1 did want that in fairness to you to be on the
12 record .
13 A Thank you .
1 4
Q Let the record show this is the discovery
15 deposition of Diane Storey taken pursuant to
15
16 subpoena, scheduled in accordance with rules and by
1? agreement of the parties.
21
19
Ma'am, have you ever had your deposition
1 ri
19 taken before in any case for any reason? 1 9
20
A No.
20
Q I'm going to ask you a number of questions
21
22 about matters relating in one way or another to the - 22
2 3 Peoria Disposal Company application for siting
23
approval and the process that people went through
_ _
Page 4
1 in terms of reaching a decision on that
1
2 application .
2
3
If you don't understand one of my
4 questions, feel free to have me rephrase it .
Everything we say is being taken down by a court
6 reporter . So only one of us can talk at a time,
6
7
and we should avoid
trying to cut each other off or
7
8 talk over each other . Is that clear?
8
9
A Correct .
9
10
Q You also need to avoid nonverbal
10
11 communications such as nodding your head or shaking 1
1
12 your head because as I said everything is being
12
13 taken down . Do you understand that?
1 3
'4
A Ido .
15 Q You understand that you are under oath!
15
16 A Correct .
16
17 Q What is your address, ma'am?
1
18
A 5136 North Montclair Avenue . Peoria
18
'_ 9 heights
. 61616 .
19
20 Q How long have you lived at that address?
20
21 A Nine years.
21
22
Q 11 hat is your home phone number?
22
23
A (30916X5-2126 .
Q Do you have a cell phone that you regularly
24
today?
A Janet LeMaster . L-E-M-A-S-T-E-R .
•
What is her relationship to you and her
reason for being here?
A Friend . support .
•
W e are going to tell you that ordinarily
you do not have the right to be accompanied by
anyone other than an attorney in a dep ; however,
we're going to waive that with regard to
Mrs . LeMaster.
age 6
A Thank you .
•
Are you employed at the present time?
A Yes .
•
Where?
A District 150
. Peoria I leights School
District and SEAPCO . I substitute as a teacher and
as a registered nurse .
•
Approximately, how many hours a week would
you work?
A As many as the% call me
. It's a PRN . as
needed basis. I vvas called today but declined to
come here .
•
When is the last time you worked full-time
outside of the home?
A One year ago
.
•
Where was that?
A Illinois Department of Public Health .
•
What was your position with them?
A I lealth facility surveillance nurse for
long-term care facilities .
•
If I understand you correctly, you've got a
master's in education, but you're an RN, also?
A Yes_ correct .
•
During your career, were you mainly a nurse
Pages 3 to 6
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
1 use?
2 A Yes . I do .
3 Q What is the number of that?
4
A (309)453-4667 .
Q Do you have a personal E-mail account that
6
you regularly use?
A
No . E-mail, oh, yes .
Q What is your E-mail address?
9
A Dastorer28sbcelobal .net .
1 0 Q What is your highest level of education?
11 A Master's .
12 Q In what subject?
13 A Education .
11 4 Q By the way, who is the person with you
Page 3
1
DIANE STOREY .
a material witness herein . being duly sworn . was
3 examined and testilied as tbllows :
EXAMINATION
11Y MR . MUELLER :
F Q Would you state your full name, please?
A Diane Store% .
g
Q Ms. Storey, I understand you have requested
DIANE STOREY
10-23-2006
Pages 7 to 10
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCBO6-184
Page
rage 9
or an educator?
1 Q So it's just coincidental that the group
A Well . when you said throughout my career
.
2
was formed around the time or shortly after you
do you mean h\ number ol'N ears"
.5
learned of PDC's intention to seek expansion?
Q 1"es.
4 A Coincidental yes .
A More as a nurse .
5 Q Who was the founder of the group?
Q In your job as a nurse in the past, have
6 A It vcas a group effort . I don't know if
you had occasion to form acquaintanceships with any 7 there was an' thunder .
of the doctors who participated in or testified at
6
Q Are you -- is the group a corporation?
the hearing on this case?
'" A No .
1 0
A No
.
10 Q
Just a voluntary association?
1 i Q So you would not know Dr . Parker McRae or 11 A Yes .
- Dr. Smith, Dr
. McGee, Dr. Zwicky, Dr . Vidas,
12 Q Does it have officers?
3 Dr. McLean or Dr . Lorenz?
- 3 A No .
4 A On a personal basis?
- 4 Q Does it maintain a membership list?
Q Y es.
A No.
1 r A No .
1 6 Q Does it have a mailing address?
1 ~' Q What is your marital status, Ms . Storey?
A No . not oflicialls .
I o A Divorced .
1 8 Q
Were you the principal person responsible
1?
Q Do you have any adult children living in
'' 9 for the formation of that group?
2
Peoria County?
' 20 A
No .
2 1 A No .
21 Q Who would you say the principal person was
22 Q When did you first learn about the Peoria
22 responsible for the formation of Citizens For Our
23 Disposal Company application?
23
Environment?
2 4 A Will you explain that by application?
24 A It was a group effort . I can't put it --
Page 8
Page 1C
Q When did you first become aware of Peoria
1 that responsihilit
.
% on am one person including
2
Disposal Company's request to expand their
n)\ self'.
landfill?
3
Q Well, who were the other individuals that
4
A June of last year. 2005 .
4
were part of the group effort?
0 Q Now, you have signed some letters as a
A Tom was there
.
6 representative of a group called Citizens For Our 6 Q That would be Tom Edwards?
7
Environment, is that correct?
A 1 om Edwards . yes
.
8
A Correct .
8
Q Anyone else?
9 Q
What is Citizens For Our Environment?
9 A I can't remember everybody . just --
10
A A group of citizens who are concerned about
13 Q Was it your idea to form this citizens
11
the health and environment of this comtnunit_y .
11
group?
12 Q When was the group formed?
12
A Not necessarily .
13 A Last year, 2005 .
13
Q Does that mean that it might have been your
14 Q Was it formed before or after you learned
1 4
idea?
15 of the Peoria Disposal Company's intent to seek
15
A I may have contributed . but
--
16
expansion of their landfill?
16 Q Was it Mr. Edwards' idea to form the group?
17 A After .
1
A I call speak Ibr him .
18 Q So would it be fair to say that the group
18 Q There's another group he's associated with
9 was formed for the purpose of participating in the 1 9 called River Rescue?
2C
expansion hearing process?
20 A Correct .
21
A No . I don't think it's fair to say that
.
21 Q Is this a separate organization from River
22
It was formed -- Citizens For Our Environment can
2-
Rescue?
2 3 be about any environmental issue . This was just
23 A Yes.
24 one issue that happened to be -- come up .
24
Q Are you a member of River Rescue?
DIANE STOREY
10-23-2006
Pages
11
to 14
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
Face 11
:ace __3
A
Q
A
No .
Are you a member of the Sierra Club
No .
1 A No . thec're not .
Q How many members do you have?
A I don't know . It's an open polies
4 Q Are you a member of Peoria Families Against
4
membership .
5 Toxic Waste?
5 Q Can you tell me approximately how many you
6A
Q
No .
Have you ever been a member of any of those
6
have?
r
groups that I just mentioned
8
AQ I
Has
ssould
the
sas
group
20 .
raised any money?
9
A No
.
9
A No
.
10 Q And does Citizens For Our Environment have 1C Q Has the group spent any money?
1 i regular meetings?
11 A Yes .
A I'sill clad F . It has meetings but not
12
Q What has Citizens For Our Environment spent
13 necessarib regular .
13
money on?
4
Q When's the last time your group had a
14 A
The ssabsite .
15 meeting?
15 Q What's the address --the address
of
the
'_ 6
A I oauld ofThand say April macbc .
1 6
Citizens For Our Environment website?
7
Q Where did that meeting take place at?
7 A C'itizensibrouren'ironmcnt .com .
18 A It took place in carious restaurants .
Q Is that actively maintained at the present
1 9
Q Were any of those meetings ever recorded?
1 9
time?
20 A Recorded such as?
20 A Yes .
21 Q I notice you brought a tape recorder here
21
Q
Who arranged for the acquisition of that
22 today and wanted to record this meeting. So you
22
domain name?
2 3 apparently understand about the technology of
recording voices .
23 A
Q
I did .
Who controls the content on the website?
Page 12
Page 14
1 A Yes .
1
A I do .
Q Were any of sour Citizens For Our
2
Q Other than you and Mr . Edwards, can you
3 Environment meetings ever recorded in the same way? 3 name any other members of Citizens For Our
A No.
Environment?
Q N ho was present at the April meeting?
A No .
6A
I can't recall .
Q ('an you recall anyone that was present?
6
Q Now, you brought with you some documents
that appear to be printouts of the various pages on
8 A I can't recall mnselfeven . I may have
8
your website, is that correct?
9 been there myself. It varied .
9
A
Correct.
10 Q Well, I'm just interested in the most
1 :1 Q
Are you the author of all of these
11
recent meeting that you had, if you can recall the
1_
documents?
12
name of any particular person that might have been
12 A No. I am not .
1 3 there?
13 Q
Who is the author ofthem?
A Myscll .
1 . 4
A I am an author of part of them and 'I om
'_ 5
Q WIas Mr . Edwards there?
A 1 don't ran v~C:r .
15
I .dssards is author of sonic of them . Bill Rutherlbrd .
Q
Pardon me
1, Q Did Mayvis \bung ever come to any of your
17
A William L . Rutherlbrd .
18
meetings?
18 Q
Anyone else?
19 A Sometimes .
19
A That's all .
20 Q Did John and/or Cindy McLean ever come to
20 Q
There are some photographs that apparently
21
anyr
of your meetings?
212
are on your website?
22 A Sometimes .
22
A Correct .
23 Q Are the% members of Citizens For Our
Q Who provided those photographs?
24
Environment?
24
A I did .
DIANE STOREY
10-23-2006
Pages 15 to 18
G=.npTr
nTCDncnT r1.1ANV
.
. PFCPTn rnr,Flmv
PfAPr
PCB06-184
Page 15
Pace
Q Where did you get them from?
A My camera .
2
being there was to demonstrate against continued
operations at the facility?
Q These are all photographs taken by you?
3 A No .
A Yes .
4
Q Isn't it true that another purpose in your
6
Q These pictures that you took were on the
6
being there was to discourage trucks from entering
landfill tour?
or leaving the facility?
F
A Correct .
Q Now, some of the pictures I'm looking at
H
10
A
Q
Q
No .
1'ou were strictly there to count'A
fo count trucks'?
Yes.
appear to be in what I will call a sepia tone
--
10
A
That's my --
'_ 1 Q --
or is that your printer?
11 A
That's --
I guess so .
2
A
Yes . It was running out of ink .
12 Q Do you remember how many people were there
13 Q Are they displayed in color on the website?
13 on the day that you were there to count trucks?
14
A Yes, they should be
.
14 A No .
15
Q When did you tour the PDC facility??
15
MR . ROYAL COLLIER : I can tell you
1 6
A About a year ago
.
1 6 that . too .
1 7
MR . ROYAL COULTER : November 14th .
17 BY MR . MUELLER :
18 2005 .
1 ft Q
Now, what was your understanding of the
19 BY MR . MUELLER :
20
2
procedure that was going to used by the county
2 0 Q Have you been on the property at any other
board in making a decision on the PDC application?
time?
21
A To revietc the evidence .
22 A No .
22 Q And what was your understanding of what the
23 Q Did you go to the property for the purpose
23
decision was going to be based on?
2 4
of counting trucks with other individuals shortly
24
A I he evidence .
1
Page 16
after May 3rd, 2006?
Q
Page 18
Was it also your understanding that the
A
Would you repeat that?
2 evidence would he brought out at the public
3 Q Did you go to the PDC property for the
3 hearing?
4 purpose of counting truck traffic shortly after
4 A The evidence brought out h} who?
5
May 3rd, 2006?
5 Q
By anyone that wanted to bring evidence
6
A
I didn't go on the property .
6
out?
? Q Were you outside the property at that time?
7 A Yes.
8 A I was outside the property .
8 Q
Now, if all of those things were your
s Q
What was your purpose in being there?
11
understanding, why did you communicate with county
1 C A It was a wonderful, beautiful day . We were
10
hoard members outside of the hearing process?
1 1
looking at the trucks .
11 A Would you repeat that . please?
1 2 Q
Any other purpose?
12
MR . MUELLER : Ifvou would read it
13
A No .
13 hack . please .
14 Q
We had heard that it was cold out that day
14
(Record read as requested.)
-- actually.
15
THE WI NESS : My understanding that
16
A
Breezy but nice, clear .
1 6 were alloosed to communicate with county board
1 ? Q How many trucks did you count?
17 members Ihey'republic officials .
18 A I don't recall .
10 13Y MR . MUELLER :
1 9 Q How long were you at the site?
1 o
Q '*%hat was the purpose of those
2 0 A Maybe a couple of hours .
20 communications, though?
21 Q Did you keep any written record of the
21 A To give information .
22
number of trucks you counted?
22 Q Information that you wanted board members
23
A No
.
23 to consider in making their decision?
2 4 Q
Isn't it true that the purpose in your
24 A Information to consider. yes .
DIANE STOREY
10-23-2006
F'3ge
Q So you weren't content with just
information that the county board members would
receive at the public hearing You wanted them to
have additional information that would be given to
them privately by y ou . i s that correct?
A Well . when \ou sa% the word content
.
information was given to them h me .
Q Let me ask it another way . You've
A
Q Who else?
A Mr . llsascr
.
Q When did you visit him?
A
I don't recall .
Q Would it be during the application time as
you called it?
A You hale to define the application time so
I hare this correct . Gise me the dates
.
A I don't know it the' went during the
c
hearing or not
. During the hearing'! Let's
clarity
. You're sitsing that when I went to the
otllce it was during the hearing!
•
It was while the application was pending,
wasn't it --
IN During the application .
•
-- Mrs . Storey?
A It was during the application time .
•
And my question then is, would it have been
appropriate in your mind for Mr
. Meginnes or I
during the application time to go to board members'
offices to give them additional information?
A I don't know . I can't answ er that .
•
Did you visit any other board members at
their home or office besides Mr
. Prather?
Yes .
Page 22
•
How about November 9th . 2005, through
May 3rd, 2006.
A Okay
. During that time?
•
Yes.
A Yes .
•
What was your purpose in going to visit
him?
A Give information
.
•
What information did you give him?
A A letter . information from Tom Edwards
.
•
Did he receive that information from you?
A I gave it to him
.
•
I mean, he didn't reject it and say I'm not
supposed to take anything from you, did he?
A No . I'm sorry .
•
You were busy writing. Can you tell me
what you just wrote?
A Why?
•
Well, I asked you a question . You started
writing something, Mrs . Storey . I assume it
pertains to the question or the answer, and I'm
just interested in what these notes are that you're
making .
A
I can ask you the same question
.
Pages 19 to
22
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
testified
that you understood that the county board
9
was to make its decision based on the evidence that
10
came out at the public hearing, correct?
11
A Yes .
12
Q But you felt it was necessary to give them
13
additional information outside the public hearing
14
that you
decision,
wanted them to use in making
right?
their
16
A
Q
Yes .
Well, don't you think that that was really
1e
then violating
the whole purpose of trying to get a
1 9
decision made based on the evidence
at the public 20
hearing?
21
A No. not a siolation . You use the word
22
violation .
23
Q Then what did you think it as if it wasn't
24
Page 20
4
a violation?
A As a citizen of Peoria Counts . we have a
right to
speech .
talk with them . We have freedom of
Q Now, did you think PDC had the same right
that they
could contact board members privately
6
outside
A
the hearing process?
You sac prisatel' . If l write-- I don't
6
know .
Q
house
Well, let's see . You went to Mr . Prather's
to talk to him?
a
U
11
A I did not go to his home .
12
Q Where did you talk to Mr . Prather at?
13
A IIisotlice .
14
Q That was a private contact, correct?
1S
A 'that was a contact .
16
Q Was anyone from PDC present during that
1
meeting?
1F
A I was not aware .
19
Q Do you think it would have been all right
20
for me or Mr . Meginnes to go to board members' 2
offices while the hearing was going on to give them
22
additional information?
23
DIANE STOREY
4
9
A Okay, yes .
10
Q Now, did you participate in the public
•
So the answer to my question then he did
not refuse to take the paper?
A Correct .
11
hearing?
•
What was your purpose in visiting
12 A Yes .
Mr. Prather?
13
Q Did you participate in the public hearing
A To give him information .
14 as a representative of Citizens For Our
•
What information did you seek to give him?
15 Environment?
A
A letter by Toni Edwards .
16
A Yes .
•
Did he take it or did he refuse it?
1?
Q
Were you given an opportunity to
A He took it .
1
F
participate as fully as you wanted to?
•
Did you visit anyone else besides those two
1 9 A Yes .
board members?
A No . I don't recall .
•
Did you attempt to visit anyone else
besides those two board members?
A Yes .
2 C
Q What additional information then did you
21 feel it was necessary to give to the board members
2 .2 that you couldn't provide at the public hearing?
23
A My opinion .
24
Q You were not prevented from giving your
Page 24
Page 26
•
Who else did you attempt to visit?
1 opinion at the public hearing, though, were you?
2
A I don't recall
.
2
A No .
3
Q As closely as you can remember, what was
Q If I were to show you a letter to William
4 the date on which you visited Mr
. Prather at his
4 Prather dated April 25th which says, Thank you
5 office?
for your effort and research on the landfill
6
A I don't recall
. It ""ould ha' c been
6
application
. I enjoyed talking with you not long
.lanuan .
% ago and know that you realize how hard Tom has
8
Q Pardon me?
8 worked on this also, would that refresh your
9
A January
9 recollection as to when you talked to Mr
. Prather?
10 Q January sometime?
1 0 A Who was that to?
11
A Yes .
11
Q
Mr . Prather.
12
Q
All right . I notice that you also sent
12
A I don't recall that .
13 letters between April 6th and May 3rd to those
13
(Storey Exhibit No
. 44 marked)
1 county board members who voted on findings that 14 BY MR . MUELLER
:
15 would have been favorable to Peoria Disposal
15'
Q
I'm going to show you a copy of a letter
16 Company, is that right?
1 6 and the envelope that went with it that we're going
17
A Would ynu repeat that?
17 to mark as Exhibit 44 and ask you if that refreshes
19
Q Did you send letters between
12 your recollection as to when you wrote to
19 April 6th and May 3rd to board members who
19 Mr . Prather and when you spoke to him .
20 voted on findings that were favorable to PDC^.
20
A Okay .
21
A Yes .
21
Q Does that refresh your recollection as to
22
Q
That would be to
Mr . Polhemus, Pat Hidden,
22 when you would have visited Mr . Prather to speak
23 Tom O'Neill, Robert Baietto, Tim Riggenbach and 23 with him?
24
Sharon Kennedy, correct?
24
A Yes . yes . sir .
Pages 23 to 26
PEORIA DISPOSAL
COMPANY v . PEORIA COUNTY BOARD
PCB06-184
10-23-2006
Q
tell us
Page
Mrs. Storey, do you --are you willing to
what you just wrote or aren't you?
2
A
Q
Yes .
You asked them to reconsider their
A It's just what you said .
2 position, didn't you?
Q So you're writing my questions down?
4 A I said please consider.
A That one I did .
.. Q Well, I'm looking at a letter hereto Tom
Q Can you answer that question?
6
O'Neill that says, Please consider the --
A
Mr
. Elsasser
I had put down that I gave the paper to
without him refusing it .
c
reconsider the impact of expanding the hazardous
toxic landfill .
DIANE STOREY
10-23-2006
Q Then I will show you what's been marked as
10 Exhibit -- or what's going to be marked as
11 Exhibit 45. These are some documents that you
12 actually were kind enough to present to us today
13 and ask you if each of those letters in there is a
1 '. true and correct copy of letters that you sent to
13 the board members whose names appear on them?
16
A Repeat the question .
1 .7
Q I think the question was, are the letters
1
18 that you're looking at now true and correct copies
9 of letters that you actually sent to board members
20 on the dates indicated?
21
A WellL this letter I don't ha' e dates . I
22 didn't -- that was the problem . So it's close as
23 well as I can remember
. A lot of stuff I didn't
24 keep . The others --
1
4
5
6
- information and I had a hard time retrieving .
8
9
1 0
11
12
13
14
1.5 hearing on behalf of Citizens For Our Environment
1 6 besides you?
1 7
A I don't recall . I don't think so .
18
Q Do you ever read the Tall Grass Sierran?
19
A Yes.
2 0
Q In the January-February issue of the Tall
2 1 Grass Sierran, it's January-February 2006, it lists
22 you as the treasurer of Citizens For Our
23 Environment .
2 4
Is that a correct statement in that issue?
10
y
treasurer for Citizens For Our Environment?
C
A Well, I started off to he the treasurer but
-'- wasn't able to do it as you have to have a bank
account and I had no hank account
. So I couldn't
_3 collect money .
1 4
Q Who initially appointed you to be the
:> treasurer in the event that money came in?
16
A
I volunteered .
10
Q You received no contributions as a result
P of that listing in the Tall Grass Sierran?
'_ 9
A I think I received two and --
2 0 Q
Do you remember in what amounts you
2'- received contributions?
2 2 A No .
2 4
23 Q
Do you remember what you did with those
contributions?
Page 30
A I sent them to the Sierra Club to the
treasurer, who was the treasurer of the Sierra
Club .
Q So you did not keep any money that was
contributed?
A No . I did not .
Q You didn't spend it either on antilandfill
activities?
A No .
(Storey Exhibit No
. 46 marked)
BY MR . MUELLER :
Q Next exhibit number is going to be 46 . Let
me show you a group of letters that we're going to
mark as Exhibit 46, and these appear to be dated
i
April 17th and appear to be thank yous for a vote
16 against the application on April 6th .
17
If I can show you those, ask you if those
18 are true and accurate copies and did you, in fact,
19 send them to board members.
2 0
A Correct .
21
Q
What was your purpose in sending out those
22 letters?
2 3
A Thank them for their hard work .
2 4
Q Did you ever have any input into the
Pages 27 to 30
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
P
Cage
Q
A
Q
When did you visit him now?
Sometime in April .
By the way . Exhibit 44 that I just showed
4
A Actually . it was incorrect . I'm not the
treasurer .
Q
A
Who is the treasurer?
you, is that a true and correct copy of a letter
I think it was Grace somebody .
that you wrote to him?
-- Q Not treasurer of the Sierra Club, treasurer
6, A Yes . my signature .
6 for Citizens For Our Environment?
c
(Store% Exhibit No .
45
marked)
A
Q
Right . No .
BY' MR . MUELLER :
In January of this year, who was the
Page 28
Q But, otherwise, they're true and accurate
1
copies?
2
A As close as I can --
3
Q
Okay
. Did you throw away some letters that
4
you sent
to board members?
5
A Well . on np computer. I lost some
6
Q
What information did you lose on your
d
computer?
9
A The letter but it's in the county hoard .
10
It's in the record . It's an open record . No
11
problem . Just couldn't get it . All this was sent
1 2
to the hoard .
13
Q
Did anyone else appear at the public
4
DIANE STOREY
10-23-2006
Pages 31 to 34
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
Paae 31
1
contents of the Peoria Families Against Toxic R'aste
Q Well, then what unusual clothing did you
4
website?
-.
i
wear?
A No .
Q Did you personally or anyone on behalf of
A
Q
Unusual . no .
Nothing unusual?
5
Citizens For Our Environment contribute toward the
A Casual clothes .
E
9
cost of any billboards, yard signs or advertising
against the proposed expansion?
6
?
8
Q Casual clothing. Did you ever wear
headbands to a county board meeting?
A No .
A No .
11
Q Did Mr . Wentworth at the hearing represent
`'
10
11
Q
it?
A
You never wore a headband with a sign on
No .
Citizens For Our Environment, also?
A No .
17 Q Did your group pay any portion of
12
Q Do you remember being at a county board
1 3
Mr . Wentworth's representation?
1?.
meeting in January of 2006 where vote wore a sign on
14
A No .
14
your head that said stop the insanity?
16
Q Did your group contribute anything toward
15
16
A
Q
It's not a sign .
the fees of Mr . Norris or the internet landfill
What was it?
77
opponent G . Fred Lee?
17
A It seas a baseball cap .
18
A No .
16
Q The baseball cap had stop the insanity sewn
19 Q
Did you go to county board meetings to
19
into it?
20
express your opinion as well as to public hearings
20 A Correct .
21 on the landfill expansion?
21
Q Who had that baseball cap made up?
22 A Yes .
22
A I did .
24
Q What was your purpose in going to the
23
24
Q
A
How many such caps did you have made up?
county board meetings?
One .
1
Page 32
1Q
Page 34
A
Pardon me?
lit inform .
3
Q And to let them know that you wanted them
2
3
A
Q
One .
to vote no?
Just the one. What was the insanity that
4
A To talk about the water . our environment .
4
you were having to stop?
5
our health issues .
5
A Pollution of our encironmcnt .
6 Q Did you take signs with you to any county
5 Q
At that point, you hadn't even heard the
8
board meetings?
7
8
evidence yet at the public hearing, had you?
A What signs are 'uu
relining
to?
A What day did cou sac that was?
C4
Q Oh, signs such as stop the dump type signs?
? Q At the January county board meeting .
10C A No . that I don't recall .
10 A No . It wasn't--
12
Q Did you ever --
were you ever told not to
Q The February county board meeting?
12 display signs at county board meetings?
A It was afierwards . yes .
_ 3
A I don't recall.
13 Q Do you still have that stop the insanity
14 Q
Did you dress in any costumes when you went
'_ 4
hat?
15
to county board meetings?_
5 A I don't know .
1 6 A Could you define costume?
16
Q When you went to county board meetings,
1 7
Q Well, you're here today in what I would
17
would you typically go there with Mr. Edwards?
11
consider to be normal business attire
.
1?s A Rephrase that question or repeat it .
1 u
Did you wear things like headbands or
1
Q Did you ever ride with Mr . Edwards or he
20
strange T shirts to county board meetings?
2 C
with you going to and from county board meetings?
21 A Based on that d efinition . n o .
21 A No .
22
Q You strictly wore business attire when you
22
Q Do you remember going to the April county
23
went to county board meetings?
hoard meeting?
24 A No .
24 A Yes .
DIANE STOREY
10-23-2006
Pages 35 to 38
PEORIA DISPOSAL COMPANY v .
PEORIA COUNTY BOARD
PCB06-184
,'age
33
Q Did you speak out against the landfill at
4
A Yes. this one here (indicating) .
2
that meeting?
Q The one on the right, that says Citizens
4
A
Q
Yes .
Is or was Jean Roach a member of Citizens
Celebrating :t terThe Vole .
A Correct .
5 For Our Environment?
Q That's also at Panache?
6 A Not that I recall .
6 A Yes .
Q How about Janet Kelly?
7 Q Who's that wearing the rabbit ears?
A
Q
No .
How about Nancy Lawless?
E
9
A Ann. I believe .
Q Ann who?
.
18 A No .
10 A It's a long name. Kirch something
.
Q How about Ann Kirchgessner?
11 Q Is she a member of your group or has she
12 A Not that I know of
.
12
ever been?
13
MR
. MUELLER : We're going to take a
13
A No .
14
short break
. I'm pretty close to being finished .
14 Q Do you know her personally
16
is
16
(Recess front 2 :45 to 2 :52)
BY MR . MUELLER :
A No .
Q Do you know Jean Roach personally?
1 % Q In the materials you brought from your
1 A No .
18
website, Ms
. Storey, is a photograph of I guess
a
18 Q [lave you ever spoken with her other than in
19 dinner had on May 3rd, after the county vote, is
1 y the hearing room?
2 C
that correct?
2 C A I may have
. may not haw known her .
2 7 A Are you referring to that picture
21 Q Did you or anyone on behalf of Citizens For
22 (indicating)?
22
23
Our Environment ever talk to any hoard member about
Q Yes .
the fact that they would be opposed in the election
A
Yes .
24
if they voted for the landfill?
1 Q Where was that dinner held?
Page 36
1
Page 36
A Did yon sas talk to them? Is that what you
2
A Panache .
said?
3 Q Who was present?
Q Yes .
4 A I see Tom Fdsards and I was there .
Do yon
A No .
5 want the people in the picture? I don't know
.
5 Q Did you ever indicate that or did anyone on
6 Q I'm trying to remember--trying to know if
6
behalf of Citizens For Our Environment ever
you remember the other people that were at that
7 indicate that to a board member in some way other
P
dinner
.
8 than talking to them directly?
9
Was it your group only or kind of a
A Yes .
10 coalition of other citizen groups as well?
1 0 Q Who was --who were the board members that
11 A
Yes . Anybody that wanted to go there .
1'_ that was indicated to?
12 Q Approximately, how many total people would
12 A I don't know specific hoard mcmhers
.
13 you say were there?
13 Q How was it indicated if it wasn't done
14 A Oh . at least 20
. 25
.
14 directly?
1 5 Q Now, there's some more pictures that you
15 A 13v l etter . b y
intormational letter .
16 have, three more .
16 Q Now, who wrote those letters?
1 ,
Are they of the same party at the same
1
A Tom Edwards .
18place? Those are the ones that you're looking
at
:8
Q Your recollection is that the gist of the
19 now, ma'am?
1
u
letters was that the board members voted yes on the
2 0 A Ilerc (indicating)!
2 0
expansion they would
-- they could expect
21 Q Yes .
21
opposition in the November election?
22 A No . This was the hearing.
22
A Repeat that .
2 3 Q What about the one on the right and the one
23 Q Was it your
understanding from these
24 underneath?
24 letters that it was communicated to board members
DIANE STOREY
10-23-2006
A No .
Q Did you ever attempt to have any
communication with Mike Phelan other than the
letter already identified from him?
A No
.
6
Q Now, you're reviewing some notes here . Are
those documents that have been presented to us?
A No
.
It's a list of the hoard members'
9 names .
l. 0
Q Where did you get that list from?
11 A From Tom .
12
Q It's one of his fliers?
-.3
A Yes, right .
1 4
Q
Did you ever go door to door to hand out
15 fliers for Mr. Edwards?
1 6 A Door to door who?
1?
Q To the public?
"16
A To the public?
19 Q Yes .
20
A Yes .
21
Q What areas did you go door to door in?
2 2
A My own neighborhood, Peoria Heights
.
23
Q Who's your county board member?
24
A Mr . Phelan .
4
Pa ;e
that if they voted yes on the election they could
expect opposition in the November election?
A Correct .
•
You didn't help write those letters?
A
No .
6
Q But you saw copies of them?
A Yes .
•
Did you keel) any copies of those letters?
4
A I'm looking . No . no .
19.' Q Do you remember if Mike Phelan would have
11 been a board member who received such a letter?
~ ._
A
I don't kuovs
.
1 3 Q Do you remember if Tom O'Neill was aboard
14 member who would have received such a letter?
15
A I can't recollect .
1
6 Q Did you ever attempt to communicate in any
17 way with Tom O'Neill during the time the
19 application was pending other than the two letters
19 or the letter that you've already identified to
20,
him?
21
A You have to repeat that again .
22 Q Did you ever have any communication with
2 3
Tom O'Neill other than the letter that's already
24 been identified from you?
Paoe 40
•
1'ou never attempted to visit Mr . Phelan?
A No .
•
Why not?
A I don't kno" .
Q Did you ever attempt to call him on the
6 phone?
A Yes
. I did .
•
About the landfill application, correct?
2
A Probably.
10
Q Did you ever attempt to call any other
11 board members on the phone?
A Yes .
1
13 Q What other board members did you attempt to
4
call?
15
A Mr . Elsasscr.
16 Q
Anyone else?
17
A Bill Prather . Mr. Prather .
1
a
Q Did you ever attempt to talk to or call Jim
19 Thomas?
20 A No .
21
Q Did you ever attempt to talk to or call
22 Lynn Scott Pearson?
23
A I don't recall . I don't think so.
24
Q Did you ever attempt to talk to -- actually
Face 42
talk to or call Carol Trumpe?
2
A No .
•
Did you ever talk to -- attempt to talk to
4
or call Phil Sulzer?
A I take that hack . I did . I can't remember
6 all of them_ Clarity that . -that's x% h\ I have the
list here because I don't -- I can't remember.
9
Q So Carol Trumpe you did have communication
9 with, is that right?
10
A I mac have .
1 :
Q Does your list indicate there have
12 checkmarks by people that you've actually visited
13 with or talked to on the phone?
14
A No . I didn't do that . I had delivered
1
some fliers and I had to find out where the\ heed .
16 That's v% h\ I called them . I didn't remember all of
them .
1H
Q When you delivered fliers, did you and Tom
1 9 Edwards kind of divide up the board for purposes of
2.0
he'd deliver some and you'd deliver some?
21
A
We divided them up because some lived far
22 attay .
23
Q Was it the intent of Mr
. Edwards and you to
2
4 give fliers to every single board member?
Pages 39 to 42
PEOPIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
DIANE STOREY
10-23-2006
Pages 43 to 46
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
Pa,- 4
F, -1
:
A
Q
Yes, as much as tse could.
On how many different occasions did You
2
A Well . the best way to define that, he came
to our meetings, some of them .
4
deliver fliers?
4
Q
A
Did Cindy McLean come to your meetings?
A I think two .
Yes .
5 Q Do you remember when that was?
Q Did Ted Converse come to your meetings?
6
A No .
6
A No .
Q Did you ever call or talk to Brian
h
9
Q Did Kim Converse come to any of your
Elsasser?
meetings?
A Yes .
A No .
1 C Q Let's go back. Was it Phil Salzer or Carol
1 C Q Do you know Kim or Ted Converse?
1'. Trumpe that you remembered calling now that you've
_
A No . By what identification?
12 thought about it?
Q Well, other than to identify them . Do you
14
A I don't think I called Mr . Salier. hut . sou
know them in that you've had a conversation with
know
. I'm not positiyc . I want to he clear about
them in the past?
7 6
that .
A Only after I was introduced to them, I
15
Q I understand that there were a lot of
_6
talked to them .
1I
contacts, so they all blend together after a while,
Q
Kim Converse was at the May 3rd party,
1 P
right?
asn't she?
19 A Yes .
A Yes .
20 Q How about Allen Mayer? Did you ever talk
2 C Q
Do you know Beth Akeson?
to him?
2=
A No .
A No .
22
Q Pardon me?
2
Q Did you ever talk to Dave Williams?
23 A No .
24 \ No
2 4 Q
Do you know Jeff Akeson?
1Q
Page 44
Did you ever talk to Eldon Polhemus?
1
Page 46
A No .
A Yes . I remember him .
2 Q Do you know Joyce Blumenshine?
Q Then you would have called him or went to
3 A Yes .
4 his house?
Q Did she come to your meetings?
6
A I went to his house . I think .
Q Did you ever talk to Junior Watkins?
A Yes .
Q Do you consider her a member of Citizens
A I don't recall . I don't think so .
Q Did you ever talk to Jeff Joyce?
A No.
9
For Our Environment?
A Am one who wants to come .
Q Did Joyce Blumenshine ever help you with
1 C Q Now, John McLean identified himself one
10
writing up letters, delivering fliers or any other
1 1 time as a member of Citizens For Our Environment . 1 1 task in connection with your work for Citizens For
1 2
To your knowledge, was he ever or is he a
'_2 Our Environment?
13 member of your group?
13 A No . no writing letters .
14 A You asked if he came to our meetings . I
14 Q How about any other task?
15 said he did.
15 A She did not help with the website . nothing
1 1) Q He did?
16, that I can recall .
17 A Yes .
1? Q
Do you know Tessie Bucklar?
Q So he is a member?
1H
A No .
19
A
If he wants . Anybody can come .
1 9 Q
Do you know Tom Bucklar?
2 C
Q Do you have anywhere a list of members of
20
A No .
21 Citizens For Our Environment?
2 --
Q
Do you know Kim Converse other than from
22 A No .
22 having met her at the hearings and being with her
2 -1
Q
Well, do you consider John McLean to be a
23 at the May 3rd party?
24 member of Citizens For Our Environment?
24 A No .
DIANE STOREY
10-23-2006
Pages 47 to 50
PEORIA DISPOSAL COMPANY
v .
PEORIA COUNTY
BOARD
PCB06-184
Pane
Pane
2
Q Do you know Ralph or Jane Converse other
2
A No .
than from the hearings?
Q Do you know Barb Van Auken?
9
A
Q
A
Q
A
Q
A
No .
Do you know Bill Cook?
No .
Do you know Joyce Harant?
No .
Do you know Mary Harkrader?
No .
4
5
6
E
9
A No .
Q Do you know Mayvis Young?
A Yes .
Q How do you know Mayvis N oung?
A
Through coining to Our meetings .
Q She would come to your meetings?
A Yes
.
1
. i) Q
The McLeans, John and Cindy came to your '-t!
Q Was there kind of a steering committee or
1 meetings, you said?
1 i executive group that represented all of the
12 A Yes .
12
different various organizations involved in this
13 Q
How many did they come to?
13
opposition that would meet periodically?
1
4
A I could say half a dozen maybe .
14 A You say "steering committee." what do you
16
Q
A
How many meetings did your group have?
I don't know . I never counted them .
15
16
mean .'
Q Any kind of group that specifically had
17 Q Did you ever go to any of their meetings of
1 representatives of the various citizen groups that
1 8
Peoria Families Against Toxic Waste?
18
would meet together for the purpose of coordinating
19 A No .
19 their efforts?
20 Q Do you know Lisa Offutt?
20
A Not that I leass aware of.
21
A No .
21
Q For example, we have the Sierra Club,
?_2 Q
Do you know Peter Offutt?
22
Peoria Families, Citizens For Our Environment .
23
A No .
23
River Rescue, were there ever meetings where
24 Q Do you know Chris Ozuna-Thornton?
24 representatives of those four groups would
1A
Page 48
Yes .
1
Page 50
specifically be invited to sit down together to
2 Q How do you know her?
coordinate their efforts?
3
A I met her at the party .
3
A I don't knoll . Not that then said .
4 Q Other than that, have you ever worked 4
Q Do you know Elaine Hopkins from the Peoria
5 together on anything related to the landfill
5
Journal Star?
6
expansion?
6
A Well . if you mean if I know her personal' .
7
A No .
no
. If I've met her since she's been at the
8 Q Do you know Cora Rosson?
8
hearings . that's how I first met her.
9
A Cara .
9
Q Did you ever have any one-on-one
10 Q
Cara Rosson?
15'
conversations with her other than at the hearing?
11
A
Yes, I met her .
11
A No .
12 Q How do you know her?
12
Q Anybody else from the Journal Star that you
13 A I met her at the hearings .
13
had any conversations with?
14 Q Did she ever help you on any project
14
A There was an interview at the hearings .
15 related to the landfill expansion and your
15
Q
Do you know a Terry Bibo from the hearings?
16 opposition to it?
16
A No
. I don't .
17 A No .
'
Q Or from the Journal Star?
18 Q Do you know Elmo Roach?
1 A No .
19 A No .
19
Q Have you talked to any county board members
20
Q
Do you know Amy Schlicksup?
20
since May 3rd?
21 A No .
21
A Ma' 3rd . I don't recall .
22 Q Do you know Bill Scott?
22
Q May we see your list of county board
23 A No
.
23
members that you've been referencing to help you
2 4 Q Do you know Cathy Stevenson?
2 4
recollect things as I've been asking you questions .
DIANE STOREY
10-23-2006
Pages 51 to 53
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
Paae 51
Fa0-
1 A Sure .
1 outside the hearing process?
2
Q Do you have any other materials from Tom
2
A No .
3
Edwards with you today?
3
MR . MUELLER : That's all I have .
4
A No .
4
Thank you very much
.
5
Q Thank you, ma'am
.
5
Show signature reserved .
6
Did he--or did you consult with Tom
6
- Edwards before this deposition on how to answer
7
(Further deponent saith not .)
F
questions or what approach to take?
8
'? A When you sa' consult --
9
10 Q Speak to him about the process and what to
10
expect?
11
12 A Yes . I did .
12
l. 3 Q When did that conversation take place?
13
14 A "This week sometime .
14
15 Q What did Mr . Edwards tell you about what to
15
16 expect?
16
1 7 A Not much . Tell the truth .
17
16 Q Did he give you any other instructions?
18
19
A Not realh .
19
2
Q
Did he request that you call him after your
2 0
21
deposition?
21
22
A No .
22
2 3
Q
Did you talk to anyone else about this
2 3
24
deposition besides Mr. Edwards?
24
2
Page 52
A When con sa' I talked about the
deposition-- .
--
-
3 Q Well, you know about what to expect
4 generally and how to conduct yourself?
5 A Sure .
6
Q Who else besides Mr . Edwards did you check
7 in with on those issues?
P
9
A I called the Center For I lealth and
Environmental Justice and asked them .
10
Q Where was that organization at?
11 A I assume Virginia .
12 Q What guidance, if any, did they give you?
13 A Hasicallc to tell the truth .
14 Q That organization is Lois Gibbs'
15 organization, isn't it?
16 A She's the Ibunder.
17 Q
Did you have a chance to talk to her about
1F this?
19 A No .
2 0 Q Do you know what the term ex parte
2'_
communication means?
22 A No .
2 3 Q Did anyone ever tell you that you should
2 4 not be communicating directly with board members
DIANE STOREY
10-23-2006
STATE OF ILLINOIS
SS
COUNTY 0:= PEORIA
Aana M . Giftos, CSR, R--R, and Notary
Public in and for the County of Peoria, State of
Illinois, do hereby certify that heretofore, to-nit,
on Monday, October 23rd, 2006,
personally appeared
before
me at 416 Main Street, Suite 1400, Peoria,
Illinois :
DIANE STOREY, a material witness
herein .
further certify that the said witness was
by
me _first duly sworn to testify to the truth, the
whole truth ana nothing
but the trut in the cause
aforesaid ; that the testimony then given by said
witness was reported stenographically by me
_n the
_presence of
said witness and afterwards reduced to
typewriting, and the foregoing is a trae and correct
transcript of the testimony so given by said witness
as aforesaid .
further certify that the signature of the
witness was not waived .
further certify that I am not counsel for
nor in any way related to any of the parties to this
suit, nor am I in any way interested i* : the outcome
thereof .
In testimony whereof, I hereunto set my
hand and affix my notarial seal on this day, Monday,
October 30th, 2006 .
Aana N
. G__tos, Certified Shorthand Reporter
(State of Illinois License k084-003571)
My commission expires 07/24/07 .
OFFICIAL SEAL
AANA M GIFTOS
No! AR" ''j8! IS STATE OF ILLINOIS
MY COMMUSION EXPIRES .01124107
Page 55
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
A
Aana 1 :10 55 :3.21
able 29 :11
about 3 :22 7
:22
8 :10.23 11
:23
15:16 22:1 32:4
35 :7,9.11
36:23
37:22 41 :8 43 :12
43 :14.20 46
:14
51 :10.15 .23 52 :1
52 :3 .17
accompanied
5 :21
accordance 1 : 16
account 5 :5 29 :12
29:12
accurate 28 :1
30:18
acquaintanceships
7:7
acquisition 13 :21
actively 13 :18
activities 30:8
actually 16
:15
27 :12.19 29:1
41
:24 42:12
additional 19 :4.14
20 :23 21
:12 25 :20
address 4 :17.20 5 :8
9 :16 13 :15.15
adult 7 :19
advertising 31 :6
affix 55 :17
aforesaid 54 :9.11
55 :9.11
after 8 :14,17 9 :2
16 :1 .4 35 :19 37:3
43 :17 45
:15 51 :20
afterwards
34 :12
55 :10
again' 9
:21 54:10
against 11
:4 17 :1
30 :16 31 :1,7 35 :1
47:18
ago 6 :15 15 :1626 :7
agreement') :
17
Akeson 45 :20.24
Allen 43 :20
allowed 18 :16
already 39:19.23
40:4
amounts 29:20
Amy 48 :20
and/or 12 :20
Ann 35 :11 37 :8.9
another 3 :22 10 :18
17 :4 19 :8
answer 21 :13 22 :21
23 :6.9
51 :7
antilandfill 30 :7
Anybody 36:11
44 :19 50:12
anyone 5 :22 10 :8
12 :7 14
:18 18
:5
20 :17 23 :19,22
28 :14 31 :4 37 :21
38 :5 41 :16 46:8
51 :23 52
:23
anything 22 :14
31 :15 48:5
anywhere 44 :20
apparently 11 :23
14:20
appear 14 :7 15 :9
27:15 28:14 30 :14
30:15
APPEARANCES
1 :14
appeared 55 :4
application 3 :23
4:2 7 :23.24 17 :20
21 :4.6.8.1121 .23
26:6 30 :16 39 :18
41 :8
appointed 29 :14
approach 51 :8
appropriate 21 : 10
approval 1 :24
approximately 6 :8
13 :5 36 :12
April 11 :16 12 :5
24:13,19 26 :4
27:2 30
:15,16
34:22
areas 40:21
around 9 :2
arranged
13 :21
asked 22 :19 25 :2
44:14 52 :9
asking 50 :24
associated
10:18
association 9:10
assume 22 :20 52:11
attached 2 .23
attempt 23
:22 24:1
39:16 40:2 41 :5
41 :10,13,182124
42 :3
attempted 41 :1
attire 32 :18.22
attorney 5 :22
Auken 49 :2
author 14:10.13 .14
14 :15
Avenue 4 :18
avoid 4 :7.10
aware 8 :1 20 :19
49 :20
away 28:4
42 :22
B
back 18 :13 42 :5
43 :10
Baietto 24 :23
bank 29:11 .12
Barb 49:2
baseball 33 :17,18
3321
based 17 :23 19:10
19
:20 32
:21
Basicalh 52 :13
basis 6:11 7 :14
beautiful 16 :10
become 8 :1
before 1 :1 .10 3 :19
8
:14 51 :7 54 :1 .20
55 :5
behalf
1 :19.23
28 :15 31 :4 37 :21
38
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DIANE
STOREY
10-23-2006
Page 61
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saith 53 :7
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PEOPTh DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
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DIANE STOREY
10-23-2006
Page 62
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PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
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9th 22 :1
PEORIA
DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
DIANE STOREY
10-23-2006
Page 63
year 6 :15 8 :4,13
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45 :17 46 :23 50 :20
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50:21
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309)453-4667309)685-2126
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wasn't 19 :24 21
:5
DIANE STOREY
10-23-2006
PEPORE TEE IL~_NOIS FOLLUTION
CONTROL POARP
PEORIA ..~
POSnC COM.FANY,
Petitro_:er,
)NO .
NCR
-y l 4
PEORIA CC OUNTY BOARD,
Respondent .
I hereby certify that I have read the
foregoing transcript of my deposit'_ on given on
October 23, 2006, at the time and place aforesaid,
consisting of pages 3 through 53 inciasive, and 1 do
aga_n subscribe and make oath that the same is a
true, correct and complete transcript of my
deposition so given as aforesaid .
Piease check one :
sheet(-` .
notes .
Subscribed and sworn to
before rre this
11th
day of
riClt~4t1~Q/I 2006i .
ota
y ur
I have submitted errata
No corrections were
CIANE
P GLSTSTOREY~
My commission espiresq
(U -
0 "
Page 54
"OFFICIAL SEAL"
RACHEL L
. WILSON
NOTARY PUBLIC STATE OF ~NOIS
PESPIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
STATEMENT OF CHANGE OR CORRECTION
I,
DIANE STOREY, do hereby state that I
have read the foregoing transcript of my deposition
taken on October 23, 2006, and that it is true and
correct except as may be noted below .
PAGE LINE
CHANGE :
REASON :
CHANGE :
REASON :
CHANGE :
REASON :
CHANGE :
REASON :
CHANGE :
REASON :
CHANGE :
REASON :
CHANGE :
REASON :
CHANGE :
REASON :
CHANGE :
REASON :
CHANGE :
REASON :
WITNESS : DIANE
STOREY
L\
K
I certify that this deposition was signed
in my presence by
on the day
of
, 2006 .
IN WITNESS WHEREOF, I have hereunto set my
hand and affixed my notarial seal on this day
of
, 2006 .
Notary Public
Exhibit 29
MAYVIS YOUNG
10-23-2006
BEFORE TLIE ILLINOIS rOL
:[VIION
CONTROL BOAR_'
EOfUA DISPOSAL COTMPAN' :,
Peti •_ ioner,
PEORIA COU":Ti BOARD,
Respor.aent .
The deposition of MAYVIS YOUNG, a material
witness herein, called for examination
pursuant
to
notice and the Supreme Court Rules as they pertain
the taking of discovery depositions before Aana M
.
_ftos, CSR, RPR, and Notary Public _n and for the
County of Peoria, and State of Illinois, on Monday,
October 2 -1,
2006, at 416 Main Street, Suite :400,
_ecru, ~_1inois, :-ommer:crin at the :our of
.2C a.n.. .
APPEARANCES :
GEORGE MUELLER, ESQUIRE
528
Columbus Street, Suite 209
Ottawa, Illinois 61350
and
JANAKI NAIR, ESQUIRE
BRIAN
MEGINNES, ESQUIRE
E'_ias,
4
Meginnee,
16 Main Street,
Riffle
Suite&
Seghetti,
1 40'
P
.C .
reoria, Il_ino :s 61602
behalf of the Fet_tioncr ;
DAVID A
. BROWNN, ESQUIRE
Black, B1aot & Brown.
101 South Main Street
Mo-ton, Illinois 61151
:
behalf of t_hhe Respondent_
;
)NO . PCE 06-104
Page I
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
MAYVIS YOUNG
10-23-2006
ALSO PRESENT :
Royal
Coult_er, PDC ;
Chris Coulter, PDC ;
Matt Coulter,
PDC ;
met` Coulter, PDC ;
Mr . Young .
WITNESS
MAYVIS
YOgNG
Ez:am_na_icn ng Mr . Mueller
.
EXHIBITS
None marked .
Page 2
PEORIA DISPOSAL COMPANY ~.
. PEORIA COMITY BOARD
PCB06-184
MAYVIS
YOUNG
10-23-2006
MAYVIS St 1 : YOI'N(i .
a material
ss fitness herein . being dnI\ sworn . "as
examined and testified us tollo\\1
GXAMINAIION
BY MR . Mt'I .LLI :R :
•
Would you state your full name, please?
A Maxxis Sue Young.
•
Ms . Young or Mrs . Young, I guess, I'm going
to take your deposition today regarding some
matters related to the Peoria Disposal Company
application, and I want to go through a couple of
ground rules with you .
1
Number one, you are here pursuant to a
1 b subpoena that was served on you . You are required
- .
to answer truthfully . You are under oath
.
i
Do you understand those things?
17
A Yes . I do .
1 .
Q Secondly, everything that's being said is
1 E
I
o
being taken down by a court reporter, and that
15
means that only one of us can talk at a time
. 1
2 C
will let you finish your answers and not talk over
you and ask that you do me the same courtes . Is
that clear?
_ r'
process that we're doing today?
A Yes
. Am I allowed to ask questions? Am I
allowed to ask for clarification? Am I allowed to
have a transcript when this is all over: and, if
so
. I would like to have a copy of the transcript
.
Q Those are actually very good questions, and
I will try to answer all of those . The first one
9
is, no, you're not allowed to ask me questions
;
1 C~ however, you are allowed to get clarification
and
i 1 explanation on any questions that I ask that
you
12 don't understand .
_
A That's what I meant by that .
1 4
Q If I ask you something and it's not clear
1 b to you, fairness dictates that I make it clear, and
1
you certainly have the right to do that .
A
And what if I feel the question is
irrelevant to the case at hand?
1
Q Let's cross that bridge when we come to it .
1 will try to confine myself to relevant questions .
A Okay .
Q There will be a transcript generated which
you will obviously have a right to review .
21
With that having been said, I think I
c
12
should also say let the record show this is the
discovery deposition of Mayvis N oung taken pursuant
to subpoena . scheduled by agreement and in
accordance with the rules .
Ma'am . what is your address
A
1512 Holl% I ledge,. 61614
•
That's in Peoria?
A Yes .
•
Are you employed?
A No .
•
When were you last employed outside the
home?
\
N' hen did %\c sell the business?
MIL YOVN(i
1997 . sontctthere along
there .
[IN' MR . MUELLER
•
Mrs . I oung, we have consented to allow your
husband to be here because you requested that ;
however, he cannot participate
. Some of these
questions are just general background and --
A So I should hale said in that case that I
don't know the exact date or I don't remember
hecause I don't remember
.
believe it or not .
Now, what is your highest level of
education?
A High school and I didn't finish but I
rarely use it . He always uses it .
•
If you don't know it, that's fine
.
A I don't know
.
•
If I can be indelicate for one second, what
is your age, ma'am?
A 66 .
Pages 3 to 6
PEOP-.A DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
started into college and got very sick and had to
drop out . So it's really just completed high
school .
a
Q Do you have an E-mail account?
17
A No .
11
Q So you do not have E-mail at home?
A No .
Q What is your telephone number, ma'am?
1
A 689-1512 .
Q Do you also have a cell phone?
16 A I share with my husband .
Q What is that number?
A I very seldom use it . It is 630 -- I
A Yes
. sir .
2d Q Ma'am, if you don't remember, you don't
Q
Pacer 4
Do you have any questions for me about the
I
Paaa 6
remember
. We don't grade you on your memory,
MAYVIS YOUNG
10-23-2006
hu' a new computer . I had -- all'thine that wa,
done on tm computer w ould not come up'' ith
1 5 an) thing . I couldn't get am program on or
16 athinem
and we tried and all ni\ Still l'vas on that
_~ hahard
, dri' e .
I put the address of where we took the
1 9 computer . and 'on can call them . M) husband took
the thing . and the .\ smashed it right in front of
21 him because they told him that's polio
. Here',
the receipt and here's the date of w hen that
happened .
Q
Now, you indicate hat you don't have an
:~qe d
E-mail account?
A No .
Q But you have a computer?
A
Yes . I use it fur word processing . I\ ping
letters
. stud like that .
6
Q So you do not communicate via E-mail?
A No .
P
Q Is that true for the period of
November 9th, 2005 through May 3rd, 2006?
0
A Yes .
". 1
Q All of your saved letters were on your hard
1 :. drive which crashed
. Am I understanding that none
13 of that could be retrieved?
A You couldn't get the thing to do nothing
15 but hale a solid blank come up . That's it .
1 6
Q Did you keep any hard copies of any letters
1I
that you have sent out in the past?
19
A No . And . actually . ifvou go hack into the
19 records
. things that I said were all gisen at an;
20 meeting . the paperwork and that . So -- and I had
21 alread' turned that in b> the time designated on
22 (he last day to turn i( into the Peoria County
23 clerk . So that's -- all my stuff is right in
24 there .
m new computer through his computer .
•
"His" meaning your husband's?
A Yes .
•
So he's got E-mail access?
A Yes . but I net er use it . You can check
10 with my children .
19
Q I believe you, ma'am .
2n
A Thesle ne' cr received an I(-mail from their
_ _ mother during that period because I just don't pla'
22 with the thing . I only use it tin-- I had carpal
2 3 tunnel surgeq .
So it's hard lot me to write .
24 t hat's the only reason \N
h\ I got a computer because
Paae
1 I can put it at a soft touch and I don't hat e the
problem with this hand
. It alleviates that .
•
I saw that you recently filed a public
5
4
comment with the Pollution Control Board in this
case?
6
A Yes. I did .
•
Was that done on your old computer or your
new computer?
A On ms new computer .
•
IOU
did not bring a copy of that comment
ith you here today either, did you?
11
A No .
1 3 Q So there are some documents on your new
1 computer that would have been responsive to our
1 5 request to produce?
1 6
A That would have been the onk one because
1~ that's the only thing I've done concerning this
1
issue because after I got the deposition it was
1 0 like . oh . please . w e don't want this overturned
.
2 0 Q Now, Mrs . Young, when did you first become
21 aware of the Peoria Disposal facility?
22
A Not until I heard Lois Gibbs
. I knew there
2 -1 w as a disposal because even city has to have --
24 take their garbage someplace and things . but the
Pages 7 to 10
PEOPTA DISPOSAL COMPAt7Y v
. PEORIA
COUNTY
BOARD
PCB06-184
you today that are responsive to the rider that was
attached to your subpoena?
hearing like such as a yahoo account from work or
anything like that?
A No .
Q Is there a reason why you did not bring any
1
A
0 Q
No .
I'm looking at the receipt that you gave
documents?
1 :.
me. There's a reference to yahoo mail
.
A
l'cs . I brought the receipt from hating to
1
A That's his computer . that's how he ordered
Q You're herewith your husband today, is
Q Do you have any copies of anything at home
that correct?
6
that you would have previously turned in to the
Peoria County clerk?
A No" It was all in m\ computer . I figured
I was done kith it .
Q Did you use E-mail at any time during this
A
Q
A
Q
Yes .
Where is he employed?
hggroll Express and just part-time .
Did you bring any documents or records with
MAYVIS YOUNG
10-23-2006
exact location and e'er'thing I did not kno" .
•
So when did you hear Lois Gibbs?
A
Seems like she spoke at llradle' in Ma' .
•
May of 2005?
4
A 2005 . An article "as in the newspaper and
I remember the incident and so forth . and I thought
6
1'1 e cot to go hear this -,real woman speak
. So I
wens up there to hear her talk .
•
Would it be fair to say that after that
10 point you kind of got mobilized as somebody who was 10
' 1 going to work against the application?
_ 1
1 2
A I would sa' -- I al axs have quiet lime
1
exer' morning . and ntv conscious said . You want our
14 cite health' . You want this communit' health\ .
That's what I kept hearing . and it just said .
15
1 6 You've never done anything like this bet-ore . but
there's ahkes a first time
.
17
•
By the way, how many people attended that
16
_ 9 meeting at Bradley that Lois Gibbs spoke at?
1 S+
22 A I don't know . I didn't count people. I
20
21 oral' show up to go to things that interest me . I
show up and I don't ha' e --
•
Was it, you know, a large auditorium full
of people or 20, 30 people in a small room?
24
Fa
12
A It was a small e_roup . I can tell you that .
1
There was something --
there was another function
s because I was real]\ surprised that there weren't
s
more people because I often go to public lectures
or things that pique my interest and see a large
6 quantity of people . Sometimes I don't .
F
•
Did Lois Gibbs, did she describe a strategy
3
for defeating one of these applications?
9
A No . She -- as best to my recollection, she
10 was just telling -- what stuck in my mind was the
10
11 horrendous effects of something like that . That's
12 what really just shook me to the core .
12
13
Q
Now, you attended the public hearings last 1 z
1
February?
1`I
15
A Yes, I did .
i 6
Q
I assume that you listened carefully to all
16
the evidence?
1 N
A I tried to, but this is a long time for --
1I
y
and how many hours starting at that time in the
20 morning and ending in the afternoon . That's a long
21 time. and most people's attention spans and
2' ever_ythim_--
22
7 6
Q Do von remember hearino evirlenre--
2
A That's not normal .
24
10
Q I'm sorry for talking over you . Do you
remember hearing evidence at the public hearing
that Love Canal which is where Lois Gibbs is from
isn't anything like what's happening at Peoria
Disposal Company, that they are really apples and
oranges?
A I hat's what I heard born Lois Gibbs aas
apple and oranges compared to PDC .'
•
Do you understand my question
A I'm thinking about it
.
I
hat's wh' I'm
pausing here .
•
Take your time .
A I just know the reicrences were made to
Lois Gibbs .
•
Do you have anything else to add on that
answer?
A No .
•
Before all of this project got started, had
you ever gone to any county board meetings?
A No .
• You decided you were going to start going
to county board meetings to put in your two cents
on this?
A I decided like I ha\ e "hen things aren't
right to he able to use ills right to voice m'
opinion .
• So you decided to start going to county
board members, correct, or to county board
meetings?
A Yes .
•
Did you know Tom Edwards before this
process started?
A Not'.'ou ha'e to define what do 'ou mean by
know'
•
Did you know him in any way, shape or form
before all of this got started?
A Now . I need to claritj again . Let's sa\ --
I "ill Li\e \ou an example
. I walk into this room
and I see y our two sons . I see them and let's sac
alter next week or something I go into a restaurant
or am public place and I see your two sons again .
Does that qualit\ me as knowing them?
And let's sa' I read their names in the
nc"spaper or something because I read the papers
and I know some people in that through the
newspaper.
tl Lot me ask it another wav . Vou've made
your point .
Pages 11 to 14
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
MAYVIS YOUNG
10-23-2006
Pa-I-
Did you -- had you ever spoken with Tom
3
2 Edwards before you started going to county board
meetings?
A No . Just would see him at different --
on
5 occasion at different places or at a different
h lecture or something
. That's seeing him . but to go
up and say
. I'm Mm vis Young and who are you
F because I see you at places I go, no .
1
Q Mrs . Young, have you ever been involved in
.0 any other civic causes or projects that you got
involved in before this one?
A Yes .
14
13
Q When was the last time you were involved in
something?
A High school .
1 6
Q So between high school and now, you've not
16
been involved in any kind of civic projects where
1 6 you started going to meetings and speaking your
16
1 9 mind, is that correct?
=`9
A Wait . I got to qualify that . If you call
20
21
going
to . like, when we had, I don't know how many
2 7.
22 years ago . but there was a calling to see if we
22-
2 3 could bridge more gaps in this community between
24 races . I did attend that meeting and things like
24
Facie 16
1
that .
Q
Did anyone ever explain to you either
directly or in a group what the rules were for how
5
1
the county board was going to make the decision on
this landfill expansion?
6
A
Would you repeat that question?
7
Q Did anyone ever explain to you in a group
or individually what the rules were for how the
o county board was going to make its decision on the
1 C landfill expansion?
11
A Yes . I did .
11 Q Who did you learn those rules from?
13
A
I asked about procedures. Carol I rumpe . I
14 called her to ask her about procedures .
_ _ Q When do you remember calling her?
16_
A I don't recall the exact date . but I do
17 recall and I know I called her twice on asking
1 E` about lust procedures .
19 Q Would that have been before the public
2C hearing?
21
22
23
4
1
i2
13
14
that the' gather and listen to . That's all .
•
\ ou've written a number of letters to
county board members, right?
A Not to indis ideals
. I sn,uld sas I pass
then a letter of what I stood tip and said . and
Riot's what you hate iii the records
. I hat's not
sending them to their honks or amlhing like that,
•
Were you ever told at a hoard meeting that
you attended that the right time to make your
comments was going to he at the public hearing?
A Was I told that the right time to stake in
comments should he at the public hearings
.'
•
l es.
A Now . I knoss it ssas brought out at the
count\ board nmeeting
. and I think the chairman .
Mr. Williams
. made that announcement Ihat s\e s' ,nld
hayc that time
. I think to the best of nis
recollection .
•
The reason I'm asking is because we have
transcripts of county board meetings, the regular
county board meetings from Januan, February, March
and April 29(16 where you spoke out against the
landfill at even' one of those meetings .
A Yes . We ha\c a right to .
Fa ct e 16
1
Q What makes you believe that you have that
right?
A
Because I'm a citi,en of the united States
of America .
Q All right
. Did anyone ever explain to you,
I
though, that this particular decision was supposed
to be made based only on the evidence that came in
6 at the public hearing?
9
A
I still stand on citiicn's rights in the
1C United States.
_1
Q So--
12
A l' hat takes precedence
.
13
Q So what you're saying is you understood
1 4 what the rule was, but the right of citizens takes
16 precedence over that rule?
16 A
I think
you're
try ing to put sonic words in
_
mm mouth
.
1 4
Q That's my job, ma'am .
20
4
QA
Okay.
So--
A I think you're try ing to put words in my
mouth here,
Q
You're the one that said you think rights
of citizens to speak out has precedence, not me
.
Pages 15 to 18
PEORIA
DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
A
Q
Yes .
And do you remember what she told you?
L _
22
A
She lust told me that they listen and they
2 s
sots and the' make their decision off of ss hat acts
24
MAYVIS YOUNG
10-23-2006
Ea,-
My question, Mrs
. Young, is if you
understood that the decision of the county board
was supposed to be made based on the evidence and
only the evidence, why did you go to county board
meetings and present views there when that wasn't
part of the public hearing?
A
I think that public hearing and that in the
new spapcr did not come out . A hell this first
-
started . there had not been an) public hearings set
Q
10 up . So I think there's a little fallacy here .
10
Q W ell, but you're speaking to the county
1
1 _ board as recently as March and April after the
1
'
public hearings had already come and gone, weren't 1 3
you??
14
A
I attended the meeting .
~- .
Q Did you collect any signatures on
1 C
petitions?
1
A Yes . I did .
19 Q What was the purpose of collecting
1 9
signatures on petitions if the decision was
2 U
supposed to be made based on the evidence?
21
A
This decision invokes the public . our
22
23 communit>
. our environment . our health . Our tt ater
23
24 and our soil
. and it tte don't stand IN , something.
24
Page 20
"e don't stand tbr an
This is given rights that all human beings
s hate world globally . This is "hc people need to
4 know "hat is going on because ignorance is the
number one killer . "[his is public inlbrmation, and
(
that's why "e have the right as citizens to speak
out and to stand for something .
Q So that takes precedence over the evidence
that would have come in at the public hearing, is
1 i) that correct?
2 _ A No .
23 Q Have you ever been to any of their
24 meetings?
e
4
1
7
A
No .
•
Did you donate any money to either of those
groups?
A No .
•
Did you spend any money of your own on this
project other than incidental money for postage,
paper and so forth?
A No .
•
Do you remember --
A I heard "hat you just said
. I spent mono
fix postage because I sent that letter to the IFPA
.
and I did spend nurnet on the paper
.
•
You did send a letter to the county board
members who voted no to the expansion, didn't you?
A I spoke that
. I w cut up there alter the
hearings "ere oter and I thanked them lot listening
and Ibr participating and "hat I tell w as a rcn
good eyamplc ottrue American dcmocrae) in action
.
I was yen proud that "e had this .
•
Did you send a letter to the county board
members who voted yes for the expansion
A I just got up in front ottee "hole county
hoard and said "hat I just told t oil . I don't
recall sending out letters to them but speaking out
Page
loud to them .
•
Let me show you, ma'am, a document which
purports to be a letter, it's addressed to the
honorable county board members who voted for the
expansion and it's signed sincerely Mayvis Young .
It's dated April 2006 and ask you if--
A Yeah . I spoke that . I spoke different
things . I didn't "rile personal letters to
`+ cN cry hod, and send out .
10
Q Did you send a copy of that letter to those
1 _ board members?
A I spoke out loud . Most otiny things "era
spoken out loud .
14
Q
Soyour--
13
A I would just "rite-- I would just write
1 E w hateyCr I "as going to sat because I'm not used to
1 E public speaking: so . therefore
. I would type this
1 t' out and then get up and speak it .
19 Q When did you type that out and getup and
20 speak it?
21
A
I'mn surprised I don't have a date on this .
22 Q It says 4/2006 down next to your name at
,'3 the bottom
.
24
A That's "hen I did it .
Pages 19 to 22
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
_ ,
A For inc . s es
. it w ould.
1Q And--
13 A Because lirst I am a lit ing entits . a human
1 4
being w ith rights to lite as ct cn hotly else .
1 h Q
Are you a member of the Sierra Club?
16
A No .
1
Q Have you ever been to any of their
meetings?
10 A No .
2 0 Q Are you a member of Peoria Families Against
21 Toxic Waste?
MAYVIS YOUNG
10-23-2006
Q Where would you have spoken that to the
A
Yes .
Q
Where did this meeting take place where it
was decided to show up at the landfill?
A I'm not sure because sometimes we would
have people interested in the same thing like the
first time was at the public library and another
time it would be at this restaurant or another
restaurant . So I can't remember which place . the
exact place because we moved around
.
•
Who did you meet with at the public
library ?
A There was a call given out to anybody
interested in this issue for our city to come to
the public library on such and such a date at such
and such a time
. and I answered that call .
•
Now, when you say you answered that call,
what do you mean?
A It wasn't a telephone call . It seemed like
it was in writing in the paper
. There was a little
snip or something that told me just like I go to
other events, something in the media that let me
know that if I were interested I could go to the
public library .
•
Do you remember who ran that meeting?
Page
•
Who?
A Tom 1'dwards and that would he really the
first time whew \ on use the word did I know . that's
where I actually did some exchanging of words . I am
so and so and I am interested .
Q How many people did you have at that
library meeting?
A It surprised me . Ihere wus I think six
people to mr recollection .
Q Six besides yourself.
A No . six including m' self which surprised
me .
Q Who were the other four besides you and
Edwards?
A Okav . Cindy and John McLean and Mary Moore
and Joyce l lumenshine
. I teas surprised that there
ss crc so flew of us that would answer
.
Q When did the meeting take place?
A
Seems like to me I heard Luis Gihbs, and it
was maybe a month and a haltatter that .
something
-- I'm not exactly sure because I don't
is rite a lot of things and I don't carry calendars
.
I lire such a simple life I don't need all that
extra stuff. I don't even carry a purse . I doubt
Pages 23 to 26
PEORIA DISPOSAL COMPANY
v . PEORIA COUNTY BOARD
PCB06-184
county board?
A At their meeting place where the) haye
3
their monthiy meeting .
Q If we can tell you that we can't find those
4
6 comments in the county board transcript for April,
would that refresh your recollection as to whether
or not you mailed that to the county board?
6
r
A No . It wouldn't
. no .
9
Q So you never mailed anything to the county
1 C
board?
1 11
A Not that I can remember
. All I remember is
12
13
cyervthing both there and the ciq council and that
13
14 was always given in person . Hvervthing I did was
14
'. 5 public . Nothing -- except lot- writing a comment
15
.6 and mailing it to the lournal Star and that
. Not% .
1 6
that wasn't spoken .
1
1
Q Did you carry signs with you to county
1 0
19 board meetings?
19
t . . A Yes . I did one time
. and they said that
20
21 wasn't appropriate . I didn't know it until they
21
22 told me . Then I put it down
.
22
23 Q Did you go to the Peoria Disposal landfill
23
24 after May 3rd to try to demonstrate about the
Page 24
ongoing operation of the landfill?
24
A I need some clarification on that one .
2
3 Q Let's break it down. Did you go to the
3
4 Peoria Disposal Company landfill shortly after
4
5 May 3rd, after the vote?
5
6 A After the vote? 1 o my recollection . I is ent
6
7 hetore the vote .
7
6 Q What was the purpose of your visit?
°
9 A last to see hot many trucks come in and out
9
1 0 of that place .
10
1 Q Did you go with anyone?
11
1 2 A I went by myself but others shorted tip
. but
12
1 3 I didn't go with somebody .
13
14 Q Was there a plan that you were aware of
14
15 that other people were going to show up as well?
__
16 A A plan?
1 6
17 Q Was that an organized event where you knew
1 7
1 k
other people were going to show up?
18
1 9 A I would have to anster that truthfully .
19
20
yes
. hut we did not know or take head count . W'e
20
21 said if ou want to come
. come or short up . It
21
22 wasn't like I signed something and said I
22
23 definitely will he there at such and such and so
23
24 and so . If you want to go and see --
2 4
MAYVIS YOUNG
10-23-2006
month and a half after Lois Gibbs talked?
A It was long enough that Ills conscious
--
esen time I would he in at\ quiet time, I still just
sa\ it
. I call it Ill' pra'er time before I go to
sleep and 's hen I Let up in the morning .
Q Now, you said you also had meetings at
12 restaurants?
1 .
A Yes .
12 Q What were the restaurants?
-3
A Avanti's .lnu's .Pancra's
.that oneoscr
11
in -- bs Venture or used to be venture
. that one .
I E
Q Now, was it basically the same small group
16 of people that showed up at each of these meetings?
7
A
1'es_ but I wasn't realh atlihiated'xith
am certain group
. I was also interested in
9 getting intbrmation and learning information
about
2C this issue .
2 :
Q That's my next question actually .
Why
2 % didn't you join up with the McLeans in the
Peoria
2 -,, Family Against Toxic Waste group?
A
Because I came into this -- I knots it's
St:~-7 •- 28
going to sound quirk' hot it's the truth tbr me
. I
came in this because spirituall' that's shat I'cas
led to do and that's vv by I'm here sv ithout an
4 attornc' again .
the minute that deposition \s as served me I
have sen --
and this again sounds quirk) . I have
NCI
' good coal uunleauon> "oil spoilt . .ILl It told
me right m% a\ . I looked through these papers and
9 that and I in spirit just said
. Just cool it . Go
1 C there and have fun . You hale nothing to he ashamed
1_ ol : You have nothing to ]eel guilty about
.
Your
conscious is clear.
If the Lord stood on this table . I ha'e no
14 problem knowing that I had not clone anything wrong
1, but stand up for and seas led to 'c hat is the highest
16 and best for even one and e' erything inv olved
.
Q Mayvis, other than your two phone calls to
1 ~< Carol Trumpe, did you ever talk to any other county
19 board member on the phone about this decision?
2 0
A No
. not that I can remember . I onh
21 remember knowing-- wanting to know about
21 procedures .
23 Q Did you ever go to the home of any county
24 board member?
I wrote. but \\ha tom \vole
. and I also \%cut I(,
Junior A1 alkins and Sharon Kennet' and she "asn't
ionic . That "as it
.
Oh . no. and to Riggenbuch to deli' er the
letter trout Tom . None of this seas mine. I ooh
G
chid what m' guidance told me to do
. that's "hs I
couldn't belong to art\ group because I did not
11 agree with things and titund things unneeessar' and
12 that I was incapable ot'doing some of the things
13 that I might he asked to do
.
19
So
. their-- I just didn't participate . I
5
just stricth run by what I hear Irons in' higher
guidance . Been that ssa' . (lets me into a lot of
trouble. hill I tOIIos' it because it's al'sa's
been
right fin me . The top of the line is the man
a upstairs .
_2 C
Q So you --you did help Mr
. Edwards and
22
21 delivered some things personally to board members
for him?
23
A Not things
.just one thine . onR once . I
read it and it seas right m my gut heeling .
So I
Sage s
1
did it .
2
Q Weren't you aware by that point that all of
1
the communicating was supposed to be done in
the
4 hearing and you weren't supposed to take things
directly to people's homes?
6
A Again
. freedom ol'speech . freedom .
tj Now, you said something that's very
e
interesting
. You said you didn't join the Peoria
10
9 Families group because you didn't necessarily
agree
C with all of what they were doing .
A Yes
. Some of that expenses and stuff to me
12 is not nccessan .
13 Q Can you tell me what they were doing that
1-: you didn't agree with?
1 ` A Yes .
16 Q Go ahead .
17
A 'Ibis table is not going to like what I'm
I S about to sac but li r me it rings true . I just
19 don't tee[ like at many times that you need all
20 these big wigs brought in . lawyers and expense
when
21 common sense can tell you and listening to your gut
22 feelings and trim higher power can give you the
same ans"ers that 'Nou're going to pa' horrendous
for . and common sense will tell you without having
Pages 27 to 30
PEORIA. DISPOSAL COMPANY
v . PEORIA COUNTY BOARD
PCB06-184
ifcou c\ et sacs me can, a purse to an\ III those
A Yes .
meetings
.
Q Whose home did you go to?
Q So your best recollection is it was about a
A I'cent to I)avc Williams to deliser . nothing
Pane
1
to hear it come out of a $450 per hour law fee or
"hat hacc % on
. I can, , help it . That's the "a . I
feel .
4
Q
Can you tell us where lawyers can get
5
450 an hour because we want to talk to Mr
. Coulter
c
about that?
A Well
. I can gite you an esampie real cast .
Ms mom just passed atta' and the were thinking about
asking -- in tact
. tte did . N e called a lute, er and
1
asked tt hat would it cost to look of cr the trust and
1 : all this kind of stuff
. 545(1 an hour
. "that's tthat
the lawyer gets paid . So I said hogwash with it
.
7
Q
Were there any specific examples of things
_ 4 that you recall disagreeing with from the meetings
_ S that you went to with the other opponents?
A No
. Because I real Is didn't go to their
17 meetings
. I wasn't interested . I teas onlt
18 interested in ibllott mg and doing what I teas
19 hearing that teas m
; part and that I could do and
20 could do within my capacm .
21
I don't hat e a lot of what \on call
22 educational smarts
. certificates . degrees
. but it
2 -,
seems like since 1'\e
been aloe the standing up
23
24
t is r ht has just been borne into m
.
24
Page 32
That's all
. It's gotten me into a heap of trouble
all the way -- well, not trouble
. but you might say
little challenges
.
4
MR
. MUELLER : We're going to take
about a three- or four-minute little recess here .
6 and we may be done or close to it . So we'll be
right back
.
F
(Recess 12
:10 to 12 :13)
F
9
BY MR
. MUELLER :
9
1 C Q Mayvis, do you remember going to a Peoria
10
11 City Council meeting and saying that maybe
11
12 Mr. Coulter and Mr
. Meginnes should stick their
23
heads over those PDC pipes at the facility?
13
14
A
Did I say something like that?
14
15 Q
Well
. I'm asking if you remember savinp
15
16
17
that
.
MR . ROYAL COULTERi
: I remember
6you
.
17
14
THE WITNESS
: Well, I don't remember .
18
1 `+ but if they remember, it's good enough for me
1 9
2 C because that's 1
. 2, 3 just said that .
2 0
21 BY MR . MUELLER :
21
22 Q I mean, was that the higher power that had
22
you making that suggestion? 2 7
24
A
No, I don't think so . I don't -- it never
2 4
MAYVIS YOUNG
10-23-2006
I
and they helped with you the layout .
A
No . no . no
. I went to that print shop and
individual and I still am an individual
. I was
only interested in the welfare of this community .
and that's all I still am very concerned about and
globally .
•
Did Joyce Blumenshine pay for the
billboards, to your knowledge?
A I don't know
. I didn't ask those questions
because I wasn't into the money pan
. I didn't do
any of that money part stuff . I only take care of
myself.
•
Did anyone ever help you with any of your
expenses?
A No .
•
Now, you also had some pins or buttons that
you made up to wear to county board meetings,
right?
A Yes .
Pages 31 to 34
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
1 sass am thing that does harm
.
Q
I'm going to show you what's been marked as
an exhibit here . 38
. Is that a sign that you made
4
up?
A I thought Of a portion of that
.
6Q
A
Who helped you with this sign?
From what I understand
. the lads at the
6 print shop did . but to
hate a sign and that . t eah .
9 I thought of trying to make a sign
.
10 Q
A
Whose print shop was that?
Browns
. it's on -- it's practical[ at --
12
across the street from the N algrcen's of She] dun
13 and Glen .
Q
You didn't have this made up at Converse
- Marketing, did you?
1 6
A
W hat? I don't know that place or anything
17 about --
never heard that name [store .
18 Q
Did you pay to have those signs printed?
19
A
I didn't pa' .
20 Q Do you know who paid for them?
21
Z_
A
Q
No . I don't
.
Well, you said you went to the print shop
page
1 had some copies of the petitions made one time so I
2
could take them out and get more signatures .
3
Q What about this sign?
4
A
I don't know the origin nor do I know who
S paid for that . I do not know
.
6 Q Do you know who paid for the billboards?
A No
. I do not . Like I said, I went in as an
MAYVIS YOUNG
10-23-2006
•
Did anyone help you pay for the costs of
1
those?
2
A No .
3
•
Did you make them up yourself?
4
A
Yes .
5
•
Did you try to hand them out to board
6
members?
7
A I put them in a packet .
8
•
So you did give pins to board members?
9
A I didn't tell them they had to wear them .
10
I just put them in the packet
.
11
• What else was in the packet?
12
1 3 A I don't actually remember . I tried
13
14 thinking about that before I cane here . I remember 14
1 I gave them the very first time a packet . but I
15
16 didn't -- like I said . I didn't keep anything for
16
17
m yself. s o
I don't remember .
17
1 9
I know I gave them a copy of what I was
18
1
q
going to say and I know I put the pin in theree
hilt
1 u
24
outside of that . I don't really know or recall 2 0
21 because I didn't keep things
.
21
22
Q
Would that have been like some things of
22
Tom Edwards' that might have been in the packet, 2 3
2
4
too?
2 4
one hour?
A I didn't keep those notes either
. Once I
,, of my curiosity satisfied
-- I remember I had a
little notebook, but then I threw it away . 1just
don't accumulate things .
MR . MUELLER : Mrs . Young. that's it .
I have no other questions .
MR . BROWN : You're free to go .
MR . MUELLER : Show signature reserved .
MS . NAIR : I will take care of that .
send it to me .
THE WITNESS : When will I get a copy
of it?
MR . MUELLER
: Actually, let's talk
about that very briefly . You have the right to
read the deposition before it can be used for any
purpose only to make sure that it's typed up
accurately
.
THE W'ITNFSS : Only the right to read
it?
MR . MUELLER : Well . you can purchase a
copy . but you've got a right to read it to make
sure it's transcribed accurately .
Do you want to do that or do you want to
c„ q(
trust the court reporter"
THE WITNESS : Well, I'm getting the
feeling that maybe I should just buy a copy of just
what I said so I know nothing is twisted around or
done .
MR . MUELLER : Before you can even buy
one, you've got to read it and sign it to make sure
it's accurate unless you want to give up that right
and trust that the court reporter will do it
accurately .
THE WITNESS
: So in order to get a
copy, I have to sign
-- read it first and sign it?
MR
. MUELLER : Or you can waive your
signature and just order a copy directly .
THE WITNESS : Having not read it?
MR
. MUELLER : That's correct .
THE WITNESS : I would prefer to read
it .
MR . MUELLER : Show signature reserved .
and Janaki Nair will be contacting you or Mr . Brown
when the transcript is ready for you to review .
(Further deponent saith not .)
Pages 35 to 38
PEORIA DISPOSAL COMPANY
V . PEORIA COUNTY BOARD
PCB06-184
Fag- 36
A I real lc don't remember it' I put items of
i
his in it or not. I don't remember
. My husband
can tell you that I don't keep a lot of stall : It'
ou come to m\ house . things are pretq clean .
clear
. I'm not a clutter person .
Q How many times how you been on the PDC
site?
8
A Oh, my gosh . you had us there for a
3
6
n
U
1
12
13
1 4
10
L6
i 7
9 meeting . a tour .
1C
MR . ROYAI . C'OUL I LR
: No' ember 14th of
11 2005 .
1 % BY MR . MUELLER :
13
Q So you were there for a tour once . Any
14 other times besides the time that you went to count
__ vehicles?
16 A No .
1 7
Q By the way, that counting trucks, that was
18 also kind of intended to be a little demonstration,
14
1 9 wasn't it?
19
20
A No . 1
just wanted to know for personal
20
21 knowledge .
21
Q How long were you there?
2 3
A Mac he an hour .
29
Q How many trucks did you count during your
24
MAYVIS YOUNG
10-23-2006
OF IL_.NOtS
.
SS
COUNTY Gc PEORIA
Aaca NI . Gift_os, CSR, R.7R, and Notary
Public i*: and for the County
of Peori- State c_
. : here y certify the
he-e--fore,
to-
.
on Monda_,
October 23rd, 2006,
-,e
cna'_ly appeared
before me a- 416 Main Stree-,
Suite 4CO, Peoria,
Illinois :
N.AYVIS YOLNG, a
material witness herein .
further certify that
the said witness was
by me first duly sworn to testify to the truth, the
whole truth and nothing bar -he truth in the cause
aforesaid
; that the testimony then given by said
witness was reported stenographica_ly by me in the
presence c` said witness and afterwards reduced to
typewriting, and the foregoing is a true and correct
transcr.i.pt
of the testimony so given by said witness
as aforesaid .
further certify that the signature of the
witness was not waived .
further certify that I am not counsel for
nor in any way related to any of the parties to this
suit, nor an I in any way interested 'r, the outcome
thereof .
.r
: testimony w :nereo_f, I hereunto set my
hand and affil my notarial seal on this day, Monday,
October 30, 200 -
Acne N
. C~ftos, Certified Shorthand Reporter
(State of Illinois License #GY1-003571)
commission expires 07/24/07
.
OFFICIAL SEAL
AANA M GIFTOS
NOTARY PUBLIC
-
STATE OF ILLINOIS
MY COMMISSION EXPIRES
:07124107
Page 40
PEORIA DISPOSAL COMPANY
v . PEORIA COUNTY BOARD
PCB06-184
I
A
Aana 1
:10 40:321
able 14 :1
about4 :1 13
:10
16:13
.14 .18 23 :24
27 :3 .19 28
:11 .19
28 :21 30:18 31 :6
31 :8 32:5 33:17
34 :3 .10 35 :14
37 :15
access 9 :16
accordance 5 :4
account 6:9
8:1 9:7
accumulate 37 :5
accurate 38 :8
accurately 37 :18
37 :23 38
:10
across -3 -3 : 12
action 21
: 18
actually 4 :7 8 :18
26:4 27:21 35
:13
37:14
add 11 :15
address
5 :5 7 :18
addressed 22 :3
affiliated
27 :17
affix 40:17
aforesaid
39:9.11
40 :9.11
after 10:18 11 :9
14:16
19 :12 21 :15
23 :24 24 :4.5 .6
26:20 27
:4
afternoon 12 :20
afterwards
40:10
again 14
:13,17 28 :4
28:6 30:6 39:10
against 11
:11 17 :22
20 :20 27 :23
agreement 5 : 3
ahead 30:16
alive 31 :23
alleviates 10 :2
allow 5 :17
allowed 4:3.4.4.9
4 :10
along 5
:14
already 8 :21 19 :13
always 6 :19 11 :12
11 :1723 :1429 :17
America 18 :4
American 21 :18
announcement
17:16
another 12 :2 14 :23
25 :5.6
answer 3:15 4:8
13 :1624
:1926 :17
answered 25 :14.15
answers 3 :21 30 :23
anybody 25 :11
anyone 16 :2 .7 18 :5
24:11
34:18 35:1
anything 7 :13 .15
7:16 9:1 .8 11 :16
13:4.15 17:7 20:1
23
:10 28:14 33:1
33 :16 35 :16
APPEARANCES
1 :15
appeared 40 :4
apple
13 :8
apples 13 :5
application 3
:1 1
11 :11
applications 12:8
appropriate 23 :21
April 17 :22 19 :12
asked 16 :13 29 :13
31 :10
asking 16 :17 17 :19
31 :9 32:15
assume 12
:16
attached 7 :8
attend 15
:24
attended 11 :18
12:13 17 :9 19:15
attention 12 :21
attorney 28
:4
auditorium 11 :2'
Avanti's 27 :13
aware 10
:21 24 :14
30:2
away 28:8
31 :8
37:4
a.m
1 :13
B
back 8:18 32:7
background 5 :20
based 18 :7 19 :3 .21
basically 27 :15
become 10:20
before 1 :1.10 11 :16
13 :18 14 :7.12
152,11 16
:19
24:7 27:7 33:17
35:14 37:16 38:6
39:120
40 :5
behalf 1 :20.24
being 3 :2 .18.19
20:14
beings
20:2
believe
6:2 9 :19
18 :1
belong 29 :10
besides 26 :10.13
big 30
:20
billboards 34 :6.13
Black
1 :22 .22
blank 8 :15
Blumenshine
26 :16
34 :12
board 12
.6 10 :4
13:19 22 14:4.4
15:2 16:4.9
17:3.8
17 :15.20 .21 19 :2
19:4,12 21
:13 20
21 :23 22 :4,11
23 :2.6.8.11 .19
28 :19.24 29
:21
34:22 35
:6.9 39:2
39 :6
borne
31 :24
both 23 :11
bottom 22:23
Bradley 11 :3.19
break 24 :3
BRIAN 1 :18
bridge 4 :19 15 :23
briefly
37:15
bring 7:6.10 10 :10
brought 7 :12 17 :14
30 :20
Brown
1 :22.22
37 :8 38 :20
Browns 33 :1 1
business
5 :13
buttons 34 :21
buy 7:13 38 :3.6
C
calendars
26 :22
call 7:19 15
:20
25 :11 .14.15 .17
27:7 31
:21
MAYVIS YOUNG
10-23-2006
Page 42
came 18 :7 27 :24
28:2 35 :14
Canal 13 :3
capacity 31
:20
care 34 :16 37 :10
carefully 12 :16
Carol 16 :13 28 :18
carpal 9 :22
earn 23:18 26 :22
26
:24 27 :1
case 4:18 5:21 10 :5
cause 40 :8
causes 15
:10
cell
6 :15
cents 13 :22
certain
27:18
certainly
4
:16
certificates 31
:22
Certified 40:21
certify 39
:8 40
:4.7
40 :12,14
chairman 17:15
challenges 32 :3
check 9:17 39 :12
children 9 :18
Chris 2 :2
Cindy 26 :15
citizen 18 :3
citizens 18
:14 24
20 :6
citizen's 18 :9
city 10:23 11 :14
23:13 25 :12 32 :11
civic 15 :10 .17
clarification 4 :4.10
24:2
clarify
14 :13
clean 36 :4
clear 3 :23 4
:14
.15
PEORIA DISPOSAL COMPANY v
. PEORIA COUNTY BOARD
PCB06-184
age 6:23
22 :6 23 :6
ago 15
:22
around 25 :8 38 :4
agree 29 :11 30 :9.14
article 1 1 :5
ashamed 28 :10
36:14
called 1 :9 16 :14,17
28:12 36 :5
best 12:9 17:17
31 :9
clerk 8 .23 9:3
27:3 28 :16
calling 15
:22 16 :15
close 32:6
between 15 :16 .23 calls 28
:17
Club 20:15
clutter 36 :5
collect 19 :16
collecting 19:19
college 6 :6
Columbus 1
:16
come4 :19 7 :14
8:15 19:8.13 20:9
24:9,2121 25 :12
31 :1 36:4
commencing 1 :12
comment 10 :4.10
Converse 33 :14
cool 28 :9
copies 8 :16 9 :1
34 :1
copy 4 :6 10 :10
22 :10 35 :18 37:12
37:22 38 :3 .12.14
core 12 :12
correct 72 14 :4
15 :1920:1038:16
39 :10 40 :10
16 :16 22 :2125 : 13
dated
22
:6
Dave 29
:3
DAVID
1 :22
day 8:22 39 :20
40 :17
decided 1321 24
14:3 25 :2
donate 21 :2
done 7:14 9:5 10:7
10:17 11 :16 28 :14
30:3 32 :6 38 :5
doubt 26 :24
down 3 :19 22 :22
23 : 22
24:3
drive 7 :17 8 :12
MAYVIS
YOUNG
10-23-2006
Page 42
every 10:23
11 :13
17 :23 27
:6
everybody22:9
20 :14
everyone 28:16
everything 3 :18
11 :1 122223
:13
23 :14 28
:16
PEORIA DISPOSAL COMPANY v . PEORIA
PCB06-184
COUNTY BOARD
23 :15
comments 17:10,12
23 :6
commission 39 :23
40 : 22
common 30 :21 .24
communicate 8
:6
communicating
30 :3
communications
28:7
community 11 :14
corrections 39
:15
cost 3 1 : 10
costs 35 :1
Coulter2 :2 .2.3,3
31 :5 32 :12,17
36:10
council23 :13 32 :11
counsel 40:14
count 11 :20 24:20
36:14,24
counting 36 :17
county 1 :6.11 8 :22
15 :23 19 :23 34:9
9:3
13 :19 .22 14 :3
Company 1
:3 3 :10
14:4 15:2
16:4.9
13 :5 24 :4 39 :3
17
:3 .15,20.21
compared 13 :8
19:14.1121 :13
complete 39:10
21
:20.22
22 :4
completed 6 :7
23 :2.6.8,10 .18
computer 7:13 .14
28 :18,2_3 34:22
7 :19 8 :3 9 :4 .12 .13 39 :6 40 :2.3
9 :13 24 10 :7 .8.9
couple 3 :11
10 :14
court 1 :10 3 :19
concerned 34 :10
38 :1 .9
concerning 10 :17
confine 4:20
conscious
11 : 13
27:5 28 :12
courtesy 3 :22
crashed 8 :12
cross 4 :19
CSR 1 :11 40:3
consented 5 :17
consisting 39 :9
contacting 38 :20
Control 1 :2 10 :4
curiosity
37 :3
D
D 2:6
39 :2
date 5 :22 7 :22
decision 16 :4 .9
.24 drop
6 :7
evidence 12 :17,23
18:6 19 :2,20 .22
duly 3 :2 40 :8
13 :2 18
:7 19
:3
.4
28:19
during
9:6.21
19:21
20
:8
defeating 12 :8
36 :24
exact 5 :22 11 :1
define 14:9
16 :16 25 :8
definitely
24
:23
degrees 31 :22
E
E 2 :6
exactly 26 :21
examination 1 :9
deliver 29:3 .7
each 27 :16
2 :9 3 :4
delivered
29
:21
democracy 21 :18
demonstrate
23
:24
easy 31 :7
education 6:4
educational 31 :22
examined
3
:3
example 14:14
21 :18 31 :7
demonstration
36:18
Edwards 14:7 15 :2
26 :2.14
29 :20
examples 31 :13
except 2' ) : 15
deponent 38 :23
35:23
exchanging 26 :4
deposition 1 :9 3
:9
5 :2 10:18 28:5
effects 12 :11
Eggroll 7 :5
exhibit
33 :3
EXHIBITS 2:11
37 :16 39 :8 .11
either 10:11 16:2
expansion 16:5.10
depositions 1 :10
21 :2 37 :2
21 :14.21 22 :5
describe 12 :7
designated 8 :21
dictates 4 :15
Elias 1 :19
employed 5 :9.1 1
7:4
expense 30 :20
expenses 30 :11
34 :19
different
15 :4.5 .5
ending 12 :20
expires 39:23 40
:22
22 :7
enough 27:5 32 :19
explain 16:2,7 18 :5
directly 16 :3 30 :5
38 :14
entity 20:13
environment
19:23
explanation 4 :11
Express 7:5
disagreeing 31
:14
discovery 1 :10 5 :2
errata 39 :13
ESQUIRE 1 :16,18
extra 26 :24
E-mail 6:9.11 8 :1,6
disposal 1 :3 3 :10
1 :18 .22
9 :6.W20
10:2123 13 :5
even 26 :24 38 :6
23 :23 24 :4 39
:3
event 24:17
F
document 22 :2
events 25 :20
facility 10 :21 32:13
documents 7:6.11
ever 13 :19 15 :1,9
fact 31
:9
10 :13
16 :2.7 17 :8 18
:5 facts 16 :24
doing
4:2
29 :12
20:17.23 27
:1
fair 11 :9
30:10,13 31 :18
28 :18 .23 34
:18
fairness 4 :15
fallacy 19
:10
Families 20 :20 30:9
Family 27 :23
February 12 :14
17 :21
fee 3 1 : 1
feel 4 :17 28 :11
30 :1931 :3
feeling 29 :24 38 :3
feelings 30
:22
felt 21 :17
few 26:17
figured 9:4
filed 10 :3
find 23 :5
fine 6 :20
finish 3
:21 6 :5
first 4:8 10 :20
11 :1719:820
:13
25 :5 26 :3 35 :15
38 :12 40:8
follow 29 :17
following 31 :18
follows 3 :3
foregoing 39 :8
40:10
form 14 :11
forth 11
:6 21 :7
found 29 :11
four 26 :13
four-minute 32 :5
free
37
:8
freedom 30 :6,6
from 7 :12 9 :7.20
I
40:12 .14
G
gaps 15 :23
garbage 10 :24
gather 17 :1
gave 9 :10 35 :15 .18
general 5 :20
generated
4
:22
GEORGE 1 :16
gets 29 :16 31 :12
getting 27 :19 38 :2
Gibbs 10:22 11 :2
11 :19 12 :7 13 :3,7
13 :14 26 :19 27 :4
Glen 33 :13
globally 20 :3 34 :11
go 3:11
8:18 11 :7
11 :21 12 :4 14 :16
15 :6,8 19 :4 23
:23
24
:3,1 1,1324
25 :19,21 27 :7
28
:9,23 29
:2
30 :16 31 :16 37 :8
going3 :8 11 :11
3 :21 .21 14:3
15 :2.18,21 16 :4,9
17 :10 20:4 22 :16
great 11 :7
ground 3 :12
group
12 :1 16 :3 .7
27:15 .1823 29 :10
30:9
groups 21 :3
guess 3 :8
guidance 29 :9.16
guilty 28 :11
gut 29:24 30 :21
35 :6 40 :17
30:24
38 :15
head 24:20
heads
32 :13
health
19 :23
healthy 11 :14,14
heap 32:1
hear 1 1 :2,7,8 29 :15
her 11 :8 16 :14.14
16 :15,17
heretofore 40 :4
hereunto 40:16
high 6 :5 .7 15 :15 .16
higher 29:15 30:22
32 :22
highest 6 :3 28 :15
him 7 :21 .21 14 :11
15 :4,6 29 :22
homes 17:7 30 :5
honorable 22 :4
horrendous 12 :11
30
:23
hour 1 :12 31 :1_5,11
36 :23 37
:1
hours 12 :19
house 36
:4
human 202,13
husband
5 :18 6 :16
7 :1 .19 36:2
husband's
9:14
I
MAYVIS
YOUNG
10-23-2006
Page 43
information 20:5
27:19.19
Ing's 27 :13
intended 36 :18
interest 11 :21 12
:5
interested 25 :4.12
25 :21 26:5 27 :18
31 :17.18 34:9
40:15
interesting 30
:8
involved 15 :9,11,13
15 :17 28:16
involves 19
:22
irrelevant 4 :18
issue 10:18 25 :12
2 7:20
items
36
:1
J 1 :18
Janaki 1 :18 38 :20
January 17:21
Jeff2 :3
job 18 :18
John 26 :15
join
27 :22 30
:8
Journal 23 :16
Joyce 26 :16 34:12
Junior 29 :5
just 5:20 6:7 7:5
9 :21 11 :15 12 :10
12 :12 13 :13 15 :4
16 :18 .23 21
:10,22
21
:23 22:15
.15
24 :9 25 :19 27 :6
28
:9.9
29 :14,15
29:23 30:18 31 :8
31 :24 32:20 35 :11
36:20
37:4
38 :3 .3
38 :14
K
keep 8 :16 35 :16.21
PEORTA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
13 :3,7 16
:12
24:15 .18 28:1
17 :21 29 :8,15
30:17.23 32:4.10
30 :22 31
:14 33 :7
33 :2 35 :19
33 :12
gone
13 :19 19 :13
front 7 :20 21
:22
good 4:7 21 :18 28 :7
full3
:6 11 :23
32:19
fun 28:10
gosh 36 :8
function
12 :2
further38 :23 40:7
gotten 32:1
grade 6 :1
Giftos 1 :1 1 40:3,21 happened
7:23
give 14:14 30 :22
happening 13 :4
31 :7 35 :9 38 :8
hard 7 :17 8 :11,16
given 8 :19 20:2
9:23
23 :14 25 :11 39 :8 harm 33 :1
39:11 40 :9,11
having4
:24 7 :12
hogwash 31 :12
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MAYVIS YOUNG
10-23-2006
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PLOP IA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
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PCB06-184
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PEORIA DISPOSAL COMPANY v . PEORIA COUNTY
BOARD
PCB06-184
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PCB06-184
COUNTY BOARD
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PCB06-184
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MAYVIS YOUNG
10-23-2006
Paqe 4T
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MAYVIS YOUNG
10-23-2006
Page 48
PEOP?A DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
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07/24/07 40 :22
630 6 :18
66 6 :24
1
689-15126 :14
132 :20
101 1 :23
9
11 :201
:13
9th 8 :9
12 :10 32 :8
12:1332
:8
14th 36:10
1400 1 :12.19 40:5
1512 5:6
1997 5 :14
2
2 32:20
20 11 :24
2005 8:9 11 :4.5
36:11
20061
:12 8 :9 17 :22
22:6 39 :9.20 40 :4
40 :17
204 1 :16
23 1 :12 39:9
23rd 40 :4
3
3 2:9 32:20 39:9
I
