Lisa Madigan
Aii)RN FY( ;FNFR,AI .
The Honorable Dorothy Gunn
Illinois Pollution Control Board
James R
. Thompson Center, Ste
. 11-500
100 West Randolph
Chicago, Illinois 60601
Dear Clerk Gunn :
Enclosed for filing please find the original and five copies of a Notice of Filing and Proposed
Discovery Schedule in regard to the above-captioned matter
. Please file the originals and return
file-stamped copies to me in the enclosed, self-addressed envelope .
Thank you for your cooperation and consideration .
Re:
People v. Isaacson Construction, Inc.
PCB No. 07-25
OFFICE OF THE ATTORNEY GENERAL
S1'A"I'E OF ILLINOIS
April 5, 2007
Kristen Laughridge Gale
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
1001 Ha
lain, Caihondale, Illinois 62901 • (618) 529-6400 • TTY : (618) 529-6403
• Fax : (618) 529-6416
RECEIVED
CLERK'S OFFICE
APR 0 9 2007
Pollution
STATE OF
Control
ILLINOISBoard
(217) 782-9031
KLG/pp
Enclosures
500 South Second ~
.
Springfield, Illinois 62706 • (217) 782-1090 • 'FFY: (217) 785-2771 •
Fax : (217) 782-7046
100 West Ram'
- .,uccy Chicago, Illinois 60601
• (312) 814-3000 • '1TY: (312) 814-3374 •
Fax: (312) 814-3806
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF
THE STATE OF
RECEIVED
)
CLERK'S
OFFICE
ILLINOIS,
)
APR 0 9 2007
Complainant,
)
Pollution
STATE OF
Control
ILLINOISBoard
vs.
)
PCB No. 07-25
(Enforcement)
ISAACSON CONSTRUCTION, INC .,
)
an
Illinois corporation,
)
Respondent .
)
NOTICE OF FILING
To:
Fred C. Prillaman
Mohan, Allewelt, Prillaman & Adami
One North Old State Capital Plaza, Ste
. 325
Springfield, IL 62701
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
Control Board of the State of Illinois, a PROPOSED DISCOVERY SCHEDULE, a copy of which is
attached hereto and herewith served upon you .
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
1
BY:
KRISTEN
C
1
LAUGHRIDGE
~~
GALE
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated : April 5, 2007
LISA MADIGAN,
Attorney General of the
State of Illinois
MATTHEW J . DUNN, Chief
Environmental Enforcement/Asbestos
Litigation Division
1
CERTIFICATE OF SERVICE
I hereby certify that I did on April 5, 2007, send by First Class Mail, with postage thereon
fully prepaid, by depositing in a United States Post Office Box a true and correct copy of the
following instruments entitled NOTICE OF FILING and PROPOSED DISCOVERY SCHEDULE
To:
Fred C . Prillaman
Mohan, Allewelt, Prillaman & Adami
One North Old State Capital Plaza, Ste . 325
Springfield, IL 62701
and the original and five copies by First Class Mail with postage thereon fully prepaid of the
same foregoing instrument(s) :
To:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
James R. Thompson Center
Suite 11-500
100 West Randolph
Chicago, Illinois 60601
A copy was also sent by First Class Mail with postage thereon fully prepaid to
:
Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
Springfield, IL 62794
KRISTEN LAUGHRI1G GALE
Assistant Attorney General
This filing is submitted on recycled paper .
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS, )
Complainant,
)
vs.
)
No . PCB 07-25
(Enforcement)
ISAACSON CONSTRUCTION, INC
., an )
Illinois corporation,
)
Respondent .
)
PROPOSED DISCOVERY SCHEDULE
NOW COMES Complainant, PEOPLE OF THE STATE OF ILLINOIS, and with the
agreement and approval of the Respondent, ISAACSON CONSTRUCTION, INC
., hereby
submits the following proposed discovery schedule
:
RECEIVED
CLERK'S OFFICE
APR 0 9 2007
STATE OF ILLINOIS
Pollution Control Board
1
DESCRIPTION OF
ACTIVITY
DUE DATE
All written discovery served
May 7, 2007
All written discovery answered
July 6, 2007
Complainant's opinion witnesses and their
opinions disclosed
September 3, 2007
Respondent's opinion witnesses and their
opinions disclosed
October 3, 2007
Depositions of complainant's witnesses
completed
December 3, 2007
Depositions of respondent's witnesses
completed
January 14, 2008
All requests to admit served
February 15, 2008
All requests to admit answered
March 15, 2008
All dispositive motions filed
April 15, 2008
500 South Second Street
Springfield, Illinois 62706
217/782-9'p~1
Dated :
y
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS,
ex rel. LISA MADIGAN,
Attorney General of the
State of Illinois
MATTHEW J . DUNN, Chief
Environmental Enforcement/Asbestos
Litigation Division
BY: KRISTEN
LAUGHRIDGE GALE
Environmental Bureau
Assistant Attorney General
2
