Exhibit 17
JOYCE
BLUMENSHINE
10-23-2006
BEFORE THE ILLINOIS POLLUTION
CONTROL
BOARD
PEORIA DISPOSAL COMPANY,
Petitioner,
-vs-
;NO . PCB 06-184
PEORIA COUNT'; BOARD,
Respondent
.
One deposition of JOYCE BLUMENSHINE, a
material witness herein, called for
ewamination
pursuant to notice and the
Supreme
Court
Rules as
they pertain to _he 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, Illinois, commencing at the hour
of 8:20 a.m .
APPEARANCES :
GEORGE MUELLER, ESQUIRE
528 Columbus Street, Suite 204
Ottawa, Illinois
61350
and
JANAKI NAIR, ESQUIRE
BRIAN J . MEGINNES, ESQUIRE
Elias, Meginnes, Riffle I
Seghett ,
916 Main Street, Suite 1400
Peoria, I1'_ino_s
6160 ::
behalf o` the Petitioner ;
DAVID A . BROWN,
ESQUIRE
Black, Black & Brown
10 : South Main Street
Morton, Illinois
61550
on
behalf of the Respondent ;
P .C .
Page 1
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY
BOARD
PCB06-184
JOYCE BLUMENSHINE
10-23-2006
APPEARANCES : Cont'd
DAVID L . WENTWORTH, ESQUIRE
Hasselberg,
Williams,
Grebe, Snodgrass & Birdsall
124 Southwest Adams, Suite
*Indicates exhibits were withdrawn be Petitioner's
counsel ;
not attached :hereto .
Page 2
PEORIA DISPOSAL COMPANY
V . PEORIA COUNTY BOARD
PCB06-184
Peoria, Illinois 6160
On behalf
o` Joyce Blumenshine ;
ALSO PRESENT :
Roya_ Coulter, PDC ;
Cons
Coulter, PDC ;
Matt Coulter, PDC ;
Je-t
Coulter,
PLC ;
N D E X
WITNESS
JOYCE BLOMENSHTNE
Examination by Mr . Mueller . .
. pg .
3
*EXHIBITS
IDENTIFIED
Blumenshine Exhibit No . 36 . .
. pg .
33
Blumenshine Exnibit No . 37A-S
. . pg . 38
Blumenshine Exhibit No . 38
. .
PD
. 46
Biumer :shine Exhibit No . 39
. pg .
C5
Blume^.shine
Exhibit No . 4C
. . pg . 58
Bluaiensnine
Exhibit No . 411
Blumenshine Exhibit
No . 42
.
pq .
. pg . 92
Blumenshine Exhibit No .
43
. . pg . H4
JOYCE
BLUMENSHINE
10-23-2006
MR
. W FN TWOR Il I : Not by agreement . but
it ttas okay
.
-
13Y MR
. MUELLER :
1 6 Q Ms . Blumenshine, is Mr
. W'entworth acting as
your attorney
--
A Yes .
1 9
Q -- in this deposition today?
A Yes .
2 :
Q
Have you ever had your deposition taken
22 before in any case for any reason?
23
A No . I haN c ne' er done this before .
_ 4
Q Let me give you a couple of ground rules.
Page _4
One is that everything that we say is being taken
3
down by a court reporter . So it's important that
only one of us talk at a time, and if you would
7
5
4 wait for me to finish my questions before starting
your answers, 1 will wait for you to finish your
6 answers before starting the next question, is that
fair?
8
A Agreed .
9
Q Also, nonverbal communications such as
gestures cannot be taken down by the court
11 reporter
. So we try to keep everything verbal
12 using yes and no rather than uh-huh and huh-uh and
1 3 words like that. Is that also fair?
4
A
Yes. okay .
'_ 5 Q Yon understand that you are under oath?
16
A Absolute]\ .
17
Q What is your address, Ms . Blumenshine?
1 6
A M\ address is 2419 fast Rescnoir
.
19 R-L-S-IL-R-V-O-I-R
. Iloule\ard . Peoria. Illinois . zip
20 code 61614-8029
.
21
Q What is your personal E-mail address?
22
A My personal h-mail is joblumen'ayahoo .com .
Q
Was that your E-mail address during the
24 past 12 months?
A Yes .
•
What is your affiliation with them?
A I am a volunteer and I'm a member .
Currently . I am a local group chairperson .
•
Is the local group called the Heart of
Illinois Chapter?
A No . It is the Heart of Illinois Group
14
15
16
17
18
19
2 C which is a subset of the Illinois Chapter . In
21 Sierra Club . the chapter is the state organization .
22 Q How long have you been a member of the
23 Sierra Club?
Since 1977 or '78 I actually joined . So
Faae 6
that's getting on about 30 years .
•
Can you explain to me how the Sierra Club
is structured and governed in terms of the
relationship between local groups, state chapters
and a national organization?
A Sure . It might take me a minute . but here
I go . Local groups are authorized by the state
chapter
. and they then have autonomy because we're
all volunteers .
Now, the state chapters exist from
permission or whatever you want to say,
authorization, of the National Sierra Club . Some
chapters are regional .
We happen to have an Illinois State
Chapter: and, basically, while we're under the same
name, there is autonomy within the different
regions and local groups because we're all
volunteers
.
•
Is there a mission statement for the Sierra
Club that is adopted or has to be conformed to by
the local groups?
A
We do have a mission statement . We conform
to it . I honestly can't say if we ever adopted it,
but it's understood that our mission is to protect
1
2C
21
23
24
Pages 3 to 6
PEORIA DISPOSAL COMPANY
v . PEORIA COUNTY BOARD
PCB06-184
a 1e .,
.IOYCIl 131.1 :MLNSI TINE_
A Yes .
a material a fitness herein . being duE
snnorn
. t
v
as
Q Where are you employed, ma'am?
examined and testified as lbllm\s :
A I am employed by Peoria Heights
I'XAMINA I ION
Congregational Church .
BY MR . MUELLER :
Q In what capacity?
Q State your full name, please .
\ Musician .
A My full name is Joyce Madeleine .
Q Is that a full- or part-time job?
M-A-D-f: I
.-I'-I-N-I : . 131 umcnsh i ne .
A Part-time .
C,
Q Let the record show this is the deposition
Q How many hours a week?
10 of Joyce Blumenshine taken pursuant to subpoena,
A About 12 hours a week .
11 pursuant to applicable rules and scheduled by
11
Q Do you have any affiliation with the Sierra
1 2 agreement .
12 Club?
JOYCE BLUMENSHINE
10-23-2006
2
the environment for our families and for our
future . That is our mission .
•
Is it part of the national mission
4 statement to be opposed to landfill development or
expansion?
6
A
The national has circulars on a variety of
6
environmental topics regarding
-- now, you said
8
landfill . Could I ask you to please clarify? Are
9 you talking about municipal landfills or hazardous
waste landfills?
•
We're talking about any kind, if Sierra
Club has a position with regard to any kind of
_? landfills .
1 4
A You know
. I'm going to have to say I don't
know right now exactly where they're at in that
.
1--
16
Q Do they have a position with regard to
16
17 hazardous waste landfills?
1
1 ^
A
I believe for hazardous waste that we are
1 R
1 9 opposed to hazardous waste landfills in certain
19
29 siting areas . That's as far as I can go .
20
Q Where would the Sierra Club propose that
21
22 hazardous waste go if not in a landfill?
2`
.
21
A As I said, there are locations that would
24 be more suitable for hazardous waste, certainly not
24
Page F
1
m gr an aquitcr. [hat is not a suitable location
for landfills .
In our situation
. the Federal EPA also has
4 kind of an advisor that
.says hazardous waste
shouldn't be over an aquifer
. It's in one of their
6 memos .
•
Have you ever before the Peoria Disposal
`? Company application participated in a landfill
siting or expansion process of any kind?
10
11
W
10
A Forest Park Nature Center .
•
Are there dues charged to be a member of
the Heart of Illinois Group?
A No .
•
Are there dues charged to be a member of
the Sierra Club?
A Yes .
•
What are the amount of the annual dues
A There are ditterent le'els . I think the
basic membership noel is about $65 .
•
That money goes to the national or to the
state?
A
'I hat 'lone' goes to the national .
•
Does any of that money get filtered back
from the national to the local groups?
A Yes .
•
Is there a formula somewhere that shows how
the money gets --
or a portion of it gets filtered
hack?
A Yes .
•
What percentage goes back to the local
groups?
A We get a percentage from the funds that go
to our state chapter . I cannot tell ' Oil the exact
Page 10
1
percentage . but it's prohahls about $600 a \ear
.
somewhere in there
. Ira not sure of the exact
alllouilt .
•
Well, I'm doing this rough math in my head
.
7
If you've got 890 members and you're talking about
E $65 per year, I've got that working out as over
$50,000 in Sierra Club dues getting paid .
A Okay .
u
Q Roughly, how much of that comes back to the
Pages 7 to 10
PEORIA DISPOSAL COMPANY v
. PEORIA COUNTY BOARD
PCB06-184
group have?
1 `5 PDC?
A About 890.
16 A No .
Q Do they have regular meetings?
17 Q
Does the local group hold elections?
A Yes .
8 A Yes .
Q How often are the meetings?
19
Q
How frequently?
A
Q
We meet monthh .
Where's the -- do you have a regular
a
21
A
Q
We have elections even ycar .
Are you folks a not-for-profit corporation?
meeting
place?
22 A I here is an arm of Sierra Club . Are you
A For most o F the meetings . Cs .
23
talking about--
Q
Where is that?
2 4 Q
The local group .
A Yes .
1 9
local group?
Q
When?
11 A A miniscule amount .
A
I have a racne memos from the 1980s
12 Q
Did either the state or the national
sating
in at the count) hoard hearing on PDC .
1_ 3
organization provide any additional help to the
Q How many members does the Heart of Illinois
14 local group in connection with this opposition to
JOYCE BLUMENSHINE
10-23-2006
newsletter called Tall Grass Sierran?
A
Yes . that's right .
•
Who is the editor of this newsletter
A John Wosik . W-O-S-I-K .
•
Who pays for the cost of this publication?
A Our local group .
•
How often does the newsletter come out?
A 13imonthls . six issues a sear
.
•
Is Tom Edwards a member of the local Sierra
Club group?
A It'hcs paid his recent dues . 'es .
•
I see there's an article on the front page
of the Tall Grass Sierran that I'm looking at
called PDC Toxic Waste Landfill Endangers Our
Future, and it purports to be authored by Tom
Edwards . That's why I was wondering if he is a
member .
A
He's one of the thunders of our group . I
think he's a member . but I would have to honest I'
look at the list .
•
Who determines what goes into this
newsletter and what doesn't?
A Our editor .
•
) on would not have -- do on have any
P 9OlE
Page 14
responsibilities with regard to this newsletter?
A I write articles for the newsletter .
•
Do you have any editorial control over what
goes in?
A Not usually . If there was a question on
something that John Wosik had, he might call me,
but that is not the usual .
•
Have you ever held any offices in the state
chapter?
A Yes .
•
What offices have you held in the state
chapter?
A Currently, I am conservation chairperson .
At one time . I was secretary . and I was a general
board member without duties at one time .
•
Have you ever held any offices in the
national organization?
A No .
•
Is the Tall Grass Sierran mailed out to all
the members on a bimonthly basis?
A
Yes .
•
Is it distributed in any other way besides
being mailed out?
A Yes .
Pages
11 to 14
PEOPIA DISPOSAL COMPANY u . PEORIA COUNTY BOARD
PCB06-184
Page 11
A They have a foundation . Okay . Our local
1
4
group is not -- it's a 50130 . but to make a
donation that's not-for-profit . you have to donate
to the Sierra Club Foundation which is separate
.
p
C
Q So the actual local group is not a
G
1 :
corporation?
A
I don't understand that .
Q Joyce, it's not a trick question .
Mr . Wentworth in a letter I think indicated it was
a voluntary association . I'm just trying to see if
1 1 that's your recollection as well .
11
12 A We are volunteers .
12
1 3 Q By the way, did you participate in the city
-4 county landfill siting proceedings in the mid '90s?
14
1 6
A No . I do not recall that . I was out of
state for several years .
_6
1 7 Q What are the offices that are elected at
1 R
these local, annual elections?
lR
15 A Our local elections elect general board
19
20 members .
20
21 Q Well, you said you're the chairman?
21
22 A Right .
22
23 Q Were you elected to be chairman?
9 A The off-ices are voted by the board .
1
Face 12
Q How many people are on the hoard'!
A We have six people .
Q Can you identify the current hoard members?
A Sure . I'm chairperson . Our vice chair is
4
7
Rod) Hobben : our secretary is John Wosik.
6 W-O-S-I-K : our other officers are Joe I ,as,jo .
6
b'
5
L-A-S-/-I O : Norm F)"ing .I) W-I-N-ti : Wends Marquis .
M-A-R-Q-U-I-S : and hang on here-Dave (irehner
.
G-R-C-B-N-1 .-R
.
C Q Are those hoard members elected on an
10
12
annual basis?
A Yes.
13 Q By the way, have you ever seen Jim Thomas
14
at a monthly meeting?
14
15 A No .
15
1 6 Q Have you ever seen Allen Maser at a monthly
16
17 meeting?
19 A No .
19
MR . WF.N"IWORIII : Can )ouclarill the
19
2 J monthly meeting as a
20
21 BY MR . MUELLER
:
21
Q 1 -es, the Sierra Club .
2
2
23 A I was assuming .
2 4 Q Now, the local group puts together a
24
JOYCE BLUMENSHINE
10-23-2006
Pages 15 to 18
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
Page 15
Pd0E
a
1 C'
Q How else?
A We leave copies at the libraries .
Q Anywhere else?
A Vv'e leave copies at the Nature Center
.
Q Does the local chapter have a website?
A
No .
Q Did you have a website at any point in the
past?
A No. not what you would call a website .
Q
Ms . Blumenshine. did the local chapter of
5
e
5
9
10
Q How often did the organization have
meetings?
A
Q
Weekly .
Where did those meetings physically take
place at?
A
Q
llsualk at Panache
. P-A-N-A-C-II-I
: .
Did you ever see any county board member at
any meeting of Peoria Families Against Toxic Waste
A No.
Q Did you ever see any county employee or
11 the Sierra Club ever take a vote on whether or not 11 person that you knew to be a county employee more
12
to take a position with regard to the Peoria
precisely at any meetings of Peoria Families
1 3
Disposal expansion?
1 3 Against Toxic Waste?
_
A
I don't rcumoiucr .
No,
16
Q Did the directors ever take a vote on
15
Q Is the Peoria Families group a dues paying
whether to take a position?
16 organization?
17 A Wait . You said . are you talking--could
1"'
A
I hey don't have
dues
. no .
18 you clarify that's the directors of the state?
18
Q Was there ever an election of any kind
19 Q
The directors of the Heart of
Illinois
19 while you were going to meetings?
20
Group .
20 A
No.
21 A The directors of a local group?
21
Q Well, who's in charge of the organization?
22 Q Yes .
22
A Kim Converse is the--what I would call
1
A Oh
. yes, we did, the local group
.
Q Was it the directors or the membership that
23 the leader.
2 4
1
Q Is she a leader by reason of election or
n
decided to take a position?
just by consensus?
4
A It was the board
.
Q When did the board make that determination?
A I can't giye you the date .
2
4
A
Q
Consensus .
Do you consider yourself one of the leaders
of Peoria Families Against Toxic Waste?
6
Q Approximately?
A
I don't recall .
5
6
A No .
Q If Kim Convene is the leader of that
7 Q Your best estimate .
group, who would be, to your knowledge, the next in
H
9
A I'm trying to put a year . I don't
P
9
line behind her in leadership?
remember.
A I'm not sure hose to answer that . People do
10
Q Okay, fair enough . Are you also a member
1 U dillcrent duties . I would--t sell . I would say
11 of
the Peoria Families Against Toxic Waste??
1 ('ara Rosson did publicity . She did a task . So
1 4
A Yes .
Q What type
of organization is that?
A I would call it a grass roots s olunteer
12 that was a task that I knet~ about .
Q Can you associate any other tasks with
14 people?
1 5 local organization .
A Yard signs vere handled by'lessic . Just a
1 6 Q Does it have officers?
i 6
m i Ilute .
1 7 A No . not in the sense that you're talking
1 7
Q Tessie Bucklar?
18 about "hat? A secretary and treasure' Could % ,)it
1 P
A Thank you . Yes . that's right . Others
19 clarity the question . please'?
1 9
helped her do that .
20 Q Let's break it down . How long have you
20
Q Any other tasks?
211 been a member of Peoria Families Against Toxic
21
A So many people in that group helped with
22 Waste?
22
dillerent protects that those arc the ones that
2 s A I started going to meetings late January .
23 come to mind .
24 February of'06 .
24 Q Did Peoria Families also do billboards?
JOYCE BLUMENSHINE
10-23-2006
Page
'19
A
The billboards design was with the help of
Ted Converse
. So . y es. t o answer your question .
they were a part of that .
3
4
Q Ted Converse did billboard design?
4
A Right .
5
F
Q Were you involved in billboard design or
6
content?
A Yes .
Q
What was your involvement?
9
1-
A
Some suggested wording.
10
'_ 1
Q Was Sierra Club involved in doing
1'-
billboards or was that the Peoria Families Against 12
Toxic Waste?
14
A
Sierra Club was not involved in doing
1 L billboards
. I would say it was Peoria Families .
15
1 6
Q What was the purpose of the billboards?
1'
A
Public education . The number one largest
1
1 d task was educating the public of Peoria about the
1 8'
19 existence of PDC
.
19
2C
Q
Any other purpose?
20
21
A That was our main purpose of the billboards
21
22 because people in this town did not know there was
22
23 a hazardous waste landfill at the very edge of the
24 city . I mean, the sign out in front of PDC does
24 be made?
Paqe 20
2
1 not say hazardous waste landfill . It says
1
A In the decision 'ou
re meaning like the
Environmental Management Unit . So we had a huge
2 hearing and --
3 task in educating people of Peoria to what was
3
Q Right .
4 here .
4
A I tried to learn about the structure of the
Q What was the purpose in educating the
5 hearing and that the evidence would he based on the
people to the existence of PDC?
6 facts from the hearing and also from what was in
A
Informing them that the landfill was here
-
the record . So I guess the ansccr is yes .
and that there's a hazardous waste dump at the edge
e
Q So you did understand that the decision was
9
to be made based upon the evidence?
1 0
A Right
. It "as my understanding that the
i 1 decision was based on evidence and on facts from
12 the record and from the hearing
.
13
Q If that's the case, then what was the point
1 4 of all of the contacts of county board members made
15 outside the hearing process while it was going on?
1 6
A By contacts
. can you lust you kind of --
1 - I'm trying to understand your question a little
1'1
better .
19
Q Let's get specific . In looking at the
20 newsletter, the Sierran, I'm looking at an article
2
entitled Urgent, Tell The Peoria County Board Your
22 Views On The PDC Hazardous Waste Landfill
23 Expansion, and it purports to be authored by Joyce
24 Blumenshine .
6
6
9 of their city .
1 0
Q Why did you think it was important for the
11 public to know that?
_
A To be informed that PDC was here and to
1 ± raise their interest and concern .
1
Q Who paid for the billboards?
5
1 6
A I did .
Q You personally paid for them?
:?
A That is correct .
16 Q How much money was spent on billboards?
1 9
A
It was around $30.000 . I would have to go
20 back .
21
Q
How many billboards were there?
22
A Fifteen as 1 recall .
23
Q Was one of the purposes of the billboards
24 to increase the county board's awareness of the
I
opposition group?
A No . That o as never a purpose that I w as
as are of .
•
W' ere you involved in the-- strike that.
Let me go back
. Did anyone help you fund
the payment for billboards?
A No .
• When Mr. Wentworth was hired, was he hired
by the Peoria Families Against Toxic Waste or was
he hired by the Sierra Club or both?
A
lie "as hired by Peoria Families and I was
part of Peoria Families
: and so . thcrelbre . he Pas
rcpr,alling me I (11 Sicrru Club .
•
Well, who paid Mr. Wentworth's bill?
A
Lots of people donated money that went to
the bill .
• Ms . Blumenshine, did you early on in this
process, meaning the application and hearing
process, take the time to acquaint yourself with
the rules and procedures that governed the process?
A By "process ." could you clari1 what
exactly you're talking about?
•
Well, did you learn how the decision was to
Page 22
Pages 19 to 22
PEORIA DISPOSAL COMPANY
V . PEORIA COUNTY BOARD
PCB06-184
Face
Let me show you that and ask you if you
wrote that article .
A Yes. I did .
•
Did you write that headline?
4
A Probably . yes .
5
6
Q Underneath it, it actually lists the board
6
7 members and their contact information?
A Yes, it does .
8
• Now, what was the point of urging people to 9
have direct contact with Peoria County Board
10
members if the decision was to be made based on
11
evidence developed at the hearing?
12
A the reason for that was that the PD(
- _
hazardous waste landfill is located over our
14
15 aquifer . In the articles by PDC and the news . the
15
1 6 spin from PDC was that that wasn't the case
. and we 1 6
17 were concerned --
I was concerned that the public
17
1
presence of PDC did not tell the full story, that
18
9 the public didn't know the full story . and so to
1 9
get what we to our best ability knew as the correct
20
state of knowledge and the concerns for our
21
22 community wanted people to know that and to tell
23 the county board because we were concerned the
2a
2 4 county board did not hear the full story . We know
2 4
Page 24
1 that I' DC had maintained numerous things that
1
2 weren't hots we saw the case .
2
So my eflbrt was to educate the public to
what we saw were the facts . Those facts were all
4
in our et idence turned in in the record .
6
Q The Sierra Club was an official participant
6
in the siting hearing?
A Yes .
8
9
Q The Peoria Families Against Toxic Waste
9
1 ` were an official participant in the siting hearing?
10
1
A Yes .
11
•
Both organizations were represented by an
12
attorney in the
hearing?
'
14
A Yes .
14
1 a Q Were you denied the opportunity in the
15
16 siting hearing to get a portion of your story as
1 6
17 you saw it into the record?
17
16
A No . I thought it tras ten fair .
18
'
q
Q That being the case, why did you think it
_ 9
2
was appropriate to hate people gice counts board 2
1
members their views outside the siting hearing if
21
22 county board members were supposed to make their 22
2 3 decision based on a record which you say was fairly 2 3
24 developed?
24
JOYCE
BLUMENSHINE
10-23-2006
A The record was voluminous
. many volumes
.
and as we sit at this table . you see business
people with suits . Mr . Coulter and his family . and
their side had presented huge volumes of
information which parts of it I did not agree with,
and we did not know that the county board might
read every page and every word
.
I felt it was essential as did much of the
Peoria Families that we highlighted concerns in
that record because PDC had been in the Chamber,
they had been in the civic federation, the news
articles, seemed to always have what I will call
toe same spin . eyervthing's sate. everything's
fne, and that to us was not the full story .
While everything was in the record, onls
certain parts of that were being highlighted
. you
know, what people really seemed to attend to . So
we were speaking out to our community to he sure
that the full picture was presented .
•
So you wanted to pressure county board
members outside the hearing process, right?
A No . That was not the direct purpose .
•
That was an indirect purpose of it, though,
wasn't it?
Page : 26
A I would say education . I do not agree with
our word pressure . Education was our purpose .
•
You wanted to educate county board members
outside the hearing process?
A No . At no time did -- well . I should sat .
the factual record and the hearing process rust
what we all knew was to he (tic basis for the vote .
and our el$xts were at educating to bring the hill
picture of the condition of the landfill and our
concerns .
•
But you wanted to educate the county board
members outside the hearing process?
^. No . Far, thing that tm uacl in oar
publications were parts of our c\ idence that was
tinned in or part of the record or was facts from
the PDC application . It was already part of what
was in the hearing process . That was --
•
Ms. Blumenshine, you urged people to
contact county board members outside the hearing
process. didn't you??
A When you're saying "outside the hearing
process
." I want to he sure that I understand that
because we were referring to things in the record
or we were using things that were in the hearing
Pages 23 to 26
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
JOYCE BLUMENSHINE
10-23-2006
4
Paoe 27
itself. So when you say outside the hearing
process, I need to know if you're talking about
what kind of part of that .
•
Well, you understand what a hearing is,
right?
A Right .
•
It convenes, things are said, it adjourns?
A Right .
•
Y'ou urged people to contact board members
outside of what happened while the hearing was
going on, didn't you?
A Yes
. because we knew PDC was taking board
members out on landfill tours and talking to board
members
. W e knew that PDC was speaking at the
Chamber of Commerce and that they had had other
contacts with board members .
So we did -- what I'm talking specifically
about is what you have in your hand there, the
newsletter .
•
I need to follow up on this . Y'ou said that
Ihr as the conersat ion that we're hat ing . So what
I relerred to about the tours . I can tell ) ou that
_' soe scent in November with Sierra Club .
4
Q Would that hate been No, ember 4th?
A It could ha'e been . I don't remember the
6 exact date .
7
Q Were 'on ever auare that once the
P application was on file the participants were not
9 to have ex park communications with board members :'
~~
4 No . The es pane ter nimolog' ne\er came
into our earl, awareness as lot a, -- I mean, the\
tscrc board members . So --
Q \\ ell, did it ever come into 'our late
awareness?
15
A When we-- could )oujust-- let me just
1 C back up a minute here .
1?
We felt count' board members are elected
1 b and representatites of the public and that people
15 could call them tsith their opinions .
2 C
Q V% hat was the point of that if you
18
20
21 PDC was taking board members on landfill tours?
21 understood the decision gas to he made based on the
22
A Yes . They took Sierra Club members on
22 esidence?
2 3 landfill tours, too .
23
A The evidence tile was huge : and . as I said.
24
Q
That was not after the application was
24 "c were concerned that the spin that PDC had on
Page 28
Page 30
1
filed, was it?
things was onk part of the picture . not the whole
A
I don't know the full timeframe of
picture .
3 e'crything . I know o'e went in No' ember .
3
Q Well, you had a fair hearing to present the
•
PDC before they fled their application
whole picture, didn't you?
offered landfill tours to everybody, didn't they??
A W e had a fair hearing . but PDC' had numerous
F,
A They made an open statement. I'm
6 professional expert witnesses in suits and gi'ing
7
assuming -- I don't reall' knots if they otlercd it
7 their paid comments . We had one professional N\ ho
9 to ever' one . I'm assuming they did .
8 assisted us because we didn't hace mono) for more .
G
Q
You knew PDC was talking to board members 9 So I see that we were onk doing what \olunteei's
1 0 while the application was pending? 1 0 and any concerned local citizens would do and that
1 _ A I better he sure I'm relating to the right
11 is to speak about the issues that concerned then .
12 timeframe here . So let's spccift the dates . What
12
Q
So you wanted it to become a popularity
dates are you talking about?
' 3 contest?
14
Q I'm interested in November 9th through
-
A
No .
_ 5 May 3rd . That's the time period .
1 5
Q
You certainly wanted the county board
1 6
Tell me what board members PDC
1 6 members to take your views expressed to them in
1
1
representatives talked to during that time that you
1 7
home visits and E-mails, in letters, in personal
1 E were aware of.
18 conversations, in telephone conversations? You
19 A I don't know
.
19 wanted them to take those views into consideration
20
Q Well, you made the statement,
20 making their decision, didn't you?
21 Ms. Blumenshine, that you knew that they were
21
MR . WEN'I'WORTIi : I hace to object .
22 talking to board members
. So I'm going to inquire, 22 You're mentioning an awful lot of a laundry list of
23 what did you know?
2s stuffthatisn't --
29
A I'm trying to get dates straight here as
24
MR . MUELLER : I will break it down .
Pages 27 to 30
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
JOYCE
BLUMENSHINE
10-23-2006
Q All right . The January-February issue of
the Sierran -- let's mark this as an exhibit now
.
We're going to give you a copy .
(Blumenshine Exhibit No . 36 marked)
MR . MI 'LLLLR : This kill he Deposition
Exhibit No . 36 . Mr . Wentworthk
the reason for the
odd numbering is we've just kept one
continuous
sequence of numbers for all these deps
. So we to
not have 35 other exhibits to ask Ms . Blunmenshine
about .
11111 WITNESS
: Thank y ou .
B Y MR
. MUEI .I.IR :
Q
If I can direct you to the third page of
this particular Sierran, that has a full page
article which you indicate was written by you, and
I take it that the county board contact information
including phone numbers, addresses and E-mails was
initiated -- was also provided by you, right?
A Yes . I "rote this
Q You did write, Please contact as many board
members as you can, right?
A I'm looking for--
Q That's the last sentence in your article .
A Okas
. Yes . I did .
Page 34
Q The purpose of that was to help counteract
what you have referred to as several times as PDC's
spin, correct?
A We wanted people to intornl the board
members of the fact that it mentions about
important environmental issue ibr Peoria .
Q It wasn't good enough to mention that at
the hearing . You wanted it mentioned to board
members by telephone, by letter and by E-mail,
right?
A That is what I'm asking here to do
. yCs .
that's right
.
Q Did anyone ever tell you that was wrong,
that that was not part of the approved process?
A No .
Q You never got an understanding that the
decision was to be made exclusively based on what
county board members heard at the hearing?
A We knew that the decision would he based on
the facts in the hearing and in the evidence
record .
Q But that those facts could be emphasized
and communicated to board members outside the
hearing?
Pages 31 to 34
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
Paso 31
but I don't know how much time we ham e .
MR . WFNTWORI11 : Fair enough
. You're
kind of testifying
.
3
1
BY MR
. Mt1Ill.! ER :
4
r,
Q Mr
. W'entworth's objection is fair. Let's
7
go back for a second .
You made the statement that you knew Peoria
6 Disposal Company was having contact with board
Y
members .
9
My question is, can you give me a single
1C
1 1 contact with a board member on behalf of Peoria
1_
1 2 Disposal that you're aware of between November 9th
12
and May 3rd?
1 3
14 A No .
14y
1~ Q So when you said you knew that Peoria
15
16 Disposal Company was having contact with board
i6
1 1 members, you misspoke, is that correct?
17
18 A The timetrame was probably not clear to me .
19
1 9 Q You certainly had contact with board
i9
27 members outside the hearing process between
20
21 November 9th and May 3rd, didn't you?
21
22 A Yes
.
22
2 5 Q Hundreds of such contacts, right?
23
24 A I don't know the number .
24
Q
Page 32
Well, would it be fair to say that it's in
1
2
the hundreds that you had?
3 A I don't know .
3
Q In the thousands then?
4
A I don't know .
Q You had so many contacts with board members
c
6
8
you can't remember the amount, isn't that fair?
A Are you talking about me personally because
A
you have the Ilearl of Illinois Group Sierra Club
9
17 newsletter in your hand?
ib
11
Could you specilS if you're talking about
12 me personalh^
12
13 Q I'm talking about you personally right now .
1 3
1 4 A It certainly was not in the thousands . not
1 4
15 in the hundreds . I did call board members and
15
16 leave messages mostly on answering machines
. I did
16
1 7 write some letters and I sent them thank s on cards
.
17
18 Q Did you go to any of their houses?
18
19
A No .
19
20 Q That was Mr. Edwards that did that, right?
20
21 A I don't know
.
21
22
Q And others also went to homes, correct?
22
23 A I never asked someone to go to a home
. I'm
2 3
24 not sure what you're referring to there
.
24
JOYCE
BLUMENSHINE
10-23-2006
A
Not logo to their house and talk to them,
110 .
•
Who's Lois Gibbs?
A Lois Gibbs is the what they call the mother
of the super fund bill . She was an organizer at
the Love Canal . Now she's the head of an
organization center for the environmental health
and justice .
•
Did she ever give you any advice on how to
fight these landfills?
A Yes .
• Did she tell you that encouraging direct
contact with the decision-makers outside of the
hearing process was a very effective method?
A I
don't remember the wording that she used .
I don't remember if she did that
.
•
Here's an E-mail that you produced dated
12th of March -- 22nd of March, excuse me, and
this is apparently a document presented by --
produced by your attorney today .
Did you write that E-mail?
A Yes . I did .
•
Who was that written to?
A It is to Julia Stone, and there's some
.
Page 36
other people copied in the heading . Jean Roach .
C'ara Rosson and Iessic Rucklar
.
•
What was the purpose of that E-mail?
A To talk about
--
MR . WEN I WORTI I : Why don't you read the
whole thing before you start answering in pieces .
111E WIINESS : Thank you . lhel .-nail
reads
. Julia
--
MR . WEN I WOR 111 : No, no . You read it
m er.
I I I 1 WITNFSS :
(Witness perusing
document.)
(Discussion oil the record .)
(I3lumcnshine F\hihit No . 37A-S
marked)
BY MR
. Ml iI'LI.LR :
•
While Janaki is marking documents, I think
, e can spend some time asking questions.
You did review the one E-mail that is going
to be identified as Exhibit 37B, didn't you?
A The one ' on just handed me. yes. I did .
•
What was your purpose in writing that?
A We-- I "as informing other volunteers
about lealletting that we had done, and in that
Pages 35 to 38
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
A Well . it was m' decision to write this
1
article and that's "hut I asked people to do
.
Q You never cleared that with Mr. Wentworth
3
4 before you did it?
4
A No .
Q Did you clear it with anybody at the
6
Illinois Chapter of the Sierra Club?
A No.
3
Q Did you clear it with anybody at the
9
national?
A No .
Q
Now, the Sierra Club has a long history of
opposing landfills .
13
Did you ever talk to anyone at the local or
1 4
1 at the state or national organization about the
1
r,
procedures for doing that?
16
1? A No .
11 -
10
Q The presentation to the Chamber of Commerce
1 ?
1-'
that you've referred to on behalf of PDC, when did
1 9
that occur?
20
_1 A
I think it "as in .lanuar' . I don't
21
22 remember the exact date . We were out at Apple's
2
23 Restaurant.
23
24 Q Do you know if counts board members were at
24
1
-age 36
that presentation?
1
A I do not think anc eountc board members
2
2 x% ere there .
3
4 Q So that was not an ex parte contact by PDC
4
5 with county board members, was it?
,.
A No .
6
7 Q
You understand the term ex parse contact,
8
don't you?
9
A I think it means that cou're talking to a
v
1 C person Outside of the record . "hate'er
10
1 : Q
Right
. You acknowledge that that's what
11
12 you encouraged people in the January-February issue
12
1 ? of the Tall Grass Sierran to do?
14 A W'e were referring to information in the
14
15 record . I have this article
. I did ask people to
15
16 call and contact .
1 6
1 % Q Did you also encourage people to visit
1-
1P board members door to door?
19
A
Not to visit hoard members door to door .
1 9
20 no
. Now when you're talking about visiting . can I
20
21
ask you to clarif\ . George°
21
22 Q To talk to them .
22
2
3
A
To go to their house?
23
24 Q Yes .
24
JOYCE
BLUMENSHINE
10-23-2006
P qe 39
I :-mail it says . sve were concerned about the public
thinking that it was a ballot issue to vote on the
I'D( landfill . So we were--we had livers that we
4
were taking around the neighborhoods
.
•
Isn't it true that the--one of the
purposes of the very organized and comprehensive
campaign to have county board members receive ex
parte communications from landfill opponents was to
try to overpower the perception of what you called
the suits that appeared on behalf of PDC at the
1
hearing?
A I wouldn't sa' overpower
. We wanted our
side of the stun . that is . the information as we
14 understood it to he relined and highlighted as I
- , told _you .
Q Well, let's talk about you personally . You
1 ' spoke at the public hearing?
A Yes .
•
You got a chance to relay your personal
2 0 feeling and your perception of your side of the
2'2
story?
A Yes .
24
23
Q
But you also wrote numerous E-mails
directly to county board members?
Page 40
A I did
.
•
Why would you feel
the need to contact them
directly outside the hearing when you had a chance
to say everything you wanted to say during the
hearing?
A 'There was -- nw concern that there's so
much information in the evidence and the hearing
file and so much presented Irom PDC' that I had a
concern that the issues about the aquifer wouldn't
he highlighted .
• So the point of the ex parte communications
was to highlight what you thought was important,
right?
A Yes .
MR . WI:NTWURI
IT
: I'd just like to make
an objection to the term you had the witness
disclose . ex partc . but I don't belies c she's a
lawyer : and to the extent that it calls for a legal
opinion under the definition of ex parte as it's
used in pollution Control Board hearings . I don't
think she's given her opinion as to that as a
nonlawver .
MR . MUEI-LIIR : Actuall' . Mr . Wentworth .
I asked her if she understood what ex paste was .
and she ga%c a pretty good definition Ior a
2
lay person,
13) MR . MIII.I
.I
.F.R :
5
4
Q
You understand once again that you were
communicating with decision-makers outside the
E presence of your opponent and outside the confines
of the hearing room?
A I can't sac it
wasn't
outside the presence
of the opponent . I'm not sure what all is
10 happening with them . I know that the Chamber of
11 Commerce and other places had been considering the
12 issue There are articles in the newspapers and on
the news that promoted what I would sa' as TUC's
7 4 interpretation of the situation .
1~
Q We've already talked about the Chamber of
17
1 r
Commerce which had no county board members at it,
right?
1 b'
A
Thai's right .
19
Q When you communicated with county board
23
2 0
members outside the context of the hearing, meaning
2 1
11
directly communicated with them, you did not copy
22
PDC in on those communications, did you?
A Not directly . Some throes would he at
2 4
counts hoard members
--
meetings or whatever . were
Page 42
given
c opies. but . n o. the answer is no.
•
Let me show you what's been marked as 37:\
which is another one of your F :-mails .
Again, I think when we're all done here,
Mr . Wentworth, we'll have you authenticate the
entire 37 group .
And this appears to be entitled -- it's a
yahoo mail from you and it sacs, I rgent, tell the
Peoria County Board your views on the PDC hazardous
waste landfill application . Calls and letters
needed
. Again, it provides the contact information
for Peoria Count% Board members .
What was the date of that communication :'
A the date on here is I ridaN . 1anuan 6th .
2006 .
•
\Y ho was that E-mail distributed to?
A That was sent to Diane Surrey .
•
Am one else?
A No . I don't see any other copies on this .
this specific E-mail went to Diane Storey .
•
Going hack to 3711, in this particular
h: mail there's also --and that's the first one
that I had you look a, there's discussion about
going to the neighbors of board members to
2 .
21
24
Pages 39 to 42
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY
BOARD
PCB06-184
JOYCE BLUMENSHINE
10-23-2006
race
inform their board member representatives?
A You use the word hope . I think that that's
accurate. You can't tell people what to realh do .
11
Q Who's Cindy Herman?
12
A Cindy I lerman was a member of Peoria
13 Families Against Toxic Waste .
11
Q If 1 can direct you to page 3 of 4 of
1 .5 Exhibit 378 starting with talked with Cindy Herman,
16 if you could read that and just read that portion
1 7 in the record?
1E
A 'I he date on this is March 21st-2006_ and
15 it sacs. I talked to Cindy I lerman and she is going
20 door to door
. Did that answer your question?
21
Q No. If you could read the actual portion
22 of that E-mail into the record there starting with
23 talked to Cindy Herman .
A
I said --
here it sacs. l alked with ('ind\
Page 44
1 Herman and she's all o\ cr Barton ille . Hanna City
2 and the Knolls tomorrow . She said that the address
3 that Eldon Polhemus gites is not a residence but
4
talked with O'Neill herself. She wants to do
S Dehceiller . too . but I couldn't remember if someone
6
had already been there
. I will send her out on
7
Thursday unless someone lets me know if the' has c
R done Dehceiller Drive . that's from Julia .
9
Q Now, who's the person that's sending her
1 C:''
out where it says, I will send her out on Thursday?
11
A Well, it's signed here --you know
. this is
12 one of those 1 mails that's kind of got several
13 I .-mails in it . so it's signed h, Julia Stone .
4
Q
And that's Peoria Family membership,
15 correct? Who's Julia Stone?
1 6
A Julia Stone is Brad Stone's wife. and the,
17 live in Wisconsin . I think she-- I know she
18 attended the hearings on a couple of times . I do
19 not know if she's an oihcial whateer you call
20 attender of Peoria Families . I saw her at a couple
21 of Peoria Families meetings .
22
Q She lives in Wisconsin but was coming down
23
here for the--
24
A No . They ware going to mote to Peoria . but
23
24
-aqe 5
A No .
•
The references in there to O'Neill and
Polhemus are to board members?
A those are hoard members . , es, the, are .
•
And the purpose was to go visit them in the
1 3 door-to-door walks, correct?
7 4
A No. The purpose of door to door „as to
15 lea,e leaticts for the public .
16, Q Then what does it matter where
17 Mr. Polhemus's residence was?
19
A People were sharing results of ,walking . and
19 what I read here is that she was reporting on ,chat
had happened during her walking ofthe
2 1 neighborhoods .
•
Did you do any walking of neighborhoods?
A Yes .
•
Did you hit any county board members' homes
Page
I
in your walking?
A Not that I am aware ol .
•
And the purpose of walking the
neighborhoods was to make the public aware of this
so they would contact their county board members,
right?
A As I said . the primary purpose was w make
the public aware of inlbrmation about the I'DC'
hazardous waste landfill . We had the hope t hat . i t
l p was your word . that the.\ might . but there's no
guarantee .
(l4lumenshine Lxhihit No . 38 marked)
13 13Y MR . MUEI .I .ISR :
Pages 43 to 46
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
communicate with them, correct?
1 the, ended up moving to Wisconsin . So she was in
A
Q
It sots neighborhoods in here .
Neighborhoods?
3
Peoria I heliet c at this time .
Q She was organizing people going door to
t
A
Q
A
Q
Yes .
What was the purpose of that?
lb inlorm the public about the PI )C issues .
With the hope that the public would then
door?
A
Q
that's how this reads
. ,
es
.
You never told the Peoria Families to stop
that conduct, did van?
Q Let me show you what we're going to mark as
' S Exhibit 38 which is apparently a folded document .
1 8
F
Have you ever seen that before?
A Yes .
Q Stop Hazardous Toxic Waste?
I
A Yes .
2
Q
Who paid for that to be printed?
21
A
I did .
22
Q Who wrote its content?
23 A Content came from a design by Mayvis Young.
24
Q Where was that particular document
JOYCE
BLUMENSHINE
10-23-2006
2 1 activities?
22 A You know, I am a citizen, a volunteer
. I
2 3 work from my home . I use a phone or I use a
2
computer
. I mean, like those things are-- I don't
Page 48
Page
significant personal sums?
A When you say "significant personal sums."
could you be more specific?
4
Q Well, are you aware of anyone else who
E
spent more than a thousand dollars of their own
6
money in this campaign?
A No
. I am not .
3
Q
Peoria Families Against Toxic Waste had a
9
website?
10
A Yes .
11
Q That website also openly encouraged its
12 visitors to make direct contacts with county board
members by phone, letter or E-mail, right?
A
Well, the website was an information tool .
15 I'm not aware at any time that you or Brian
18
16 Meginnes or anyone else had called and said that
17 that was inaccurate except for -- there was one I
c think label on a photo . but we all used the website
19 for information purposes .
2 0 Q The question is, did the website openly
21 encourage its visitors to contact county board
22 members by letter, telephone or E-mail?
23
A It had information to encourage people to
24 contact the board members .
Page 50
Q
Including the contact information of board
members?
3
A
Yes .
4
Q Did you provide that information for the
1
know what you're wanting to kind of get at there
.
but I would have no way to separate out other
3
costs .
4
Q How much was Mr. Norris paid?
5
A About $8,000 .
3 website?
6
Q And how much was G . Fred Lee paid?
6
A No . not that I'm aware of.
A Nothing . Wait . I believe that was $5,000 .
Q
Did you have any editorial input into the
8
Q So my understanding then is that between
" maintenance of that website?
9
the two experts which were retained by the group
9
A No
.
1 0 you spent $13,000?
10
Q
Do you know who did maintain the website?
1 1
A I think that's pretty close to the right
11
A I believe it was led Converse
.
12 amount.
12
Q
So as you sit here now, you don't think it
13
Q
But you spent
-- you personally spent more
13 would have been better to take that 30,000 you
14 than double that just on billboards?
14 spent on billboards and maybe get some other expert
15
A That's what billboards cost . They're very
1
witnesses for that money?
16 expensive .
16
A At the time . we were wanting to inform the
17
Q So would it be fair to say that you thought
1 - public and we had tried to get other experts . but
1 8 billboards were a higher priority than experts?
18 by the date we were working with, you know
. that
19
A No . That is not true . Both Chuck Norris
19 thought never came into my head .
2 0 and G . Fred Lee were gracious to us as citizens and
2 0
Q
I want to show you another E-mail that you
21 volunteers and gave us a greatly -- at least for
2'1 wrote . This is part of the 37 Group, and this one
22 Chuck Norris specifically, he in no way charged us
22 I think we have marked as--this is the one that's
23 what his true accumulation of costs would be .
21 marked as 37J and K as a second copy .
24
Q
I assume
other people also donated
24
Let
me
show you those and ask you if you've
Pages
47 to 50
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
_dge
1
circulated?
2 A Well . this document is dated
3 November 2nd, 2005 . and this was circulated as
4 yard signs .
5 Q Now, you indicated that you spent $30,000
6 on yard signs of your own money, right?
7 A No .
B Q Or billboards?
9
A
Yes .
10 Q You spent 30,000 of your own money on
11
billboards?
12 A Right .
13 Q How much did you spend on yard signs?
14
A
Probably about $2 .000 .
15 Q That's your personal spending, correct?
16 A Yes .
17 Q Any other personal spending besides that
18
32,000?
19 A On a specific --
20 Q On landfill opposition related materials or
JOYCE BLUMENSHINE
10-23-2006
A Yes.
Q --
right?
N1 ho was that E-mail addressed to?
17
A It saes . Dear Chairman Williams and Members
1 0
11 ofthe Peoria --
l'nt sorr\ . I see . The li-mail
_
12 here is addressed to I out O'Neill .
MR . WI'.N I \k OR II I : I hat's 37K . 37.1
14 (indicating)
.
2
7
1
15
TI IF Wl IN1SS : 37.1 . the other one which
1 _`
16 is a copy of the exact same wording is directed to
16
7 looks like a whole string of county board members .
1 7
16 BY MR . MUELLER:
18
'_ 9 Q That would he actually all of them, right?
1 9
20 A I'm not counting them all here . but it
2 C
21 looks like a lot .
21
22 Q hes . Did you also send a copy of this to
22
3 anyone at PDC such as Mr
. Meginnes or myself or any 2 3
24 of the members of the (oulter family?
24
Fage 32
3
2
A No . but I did send a copy to the Journal
1
Star. I believe this was originated as a letter to
the editor.
4
Q
This E-mail purports to contain facts,
4
5
doesn't it?
5
6
A Yes .
Q So you were introducing outside the hearing
I
8 process material that you believed to be fact?
9
A No, not outside the hearing process . I
9
'
C believe that all these topics in here were covered
10
11 in the hearing or the evidence, I mean . I don't
11
12 think there's anything new here at all .
12
13 Q Go to the second fact . Fact, the geology
13
144 of the site will not protect the aquifer .
14
15
That wasn't a fact at the hearing, was it?
1
6
A Yes .
16
i 7 Q
Wasn't that just an opinion offered by some
1
18 people and there are contrary opinions offered by
16
19 others?
19
20 A Well, I understood it to be a fact because
20
21 there were soil borings entered into the record
2 i
22 that showed that the PDC site was sand lenses and
22
23 it was testimony of our professional witness, Chuck 2~4
24 Norris . that the geology of the site will not
2 4
protect the aquifer .
•
You attended even' day of the hearing,
didn't you?
A Yes .
•
Wasn't it your recollection that whether or
not the aquifer would be protected was a contested
issue between the parties at the hearing
A Yes .
•
So for you to contact county board members
directly outside the hearing and refer to that
statement as a fact is really a misrepresentation
of what occurred at the hearing, isn't it ?
A I don't understand it that was .
•
Well, it would have been a fact to say our
witness testified that the aquifer will not be
protected, but PDC's testimony was that it would be
protected, that would have been an accurate
statement, right?
A I hear what
Not'
re saving that this didn't
represent the other . like
. point of view .
•
This purports to present something that was
disputed and contested as a fact, doesn't it?
A Well . I know there was agreement in the
hearing that Ken Liss . PDC's ow n witness . agreed
Page 54
with Chuck Norris
. our w itness. that trace elements
of pollution were entering the aquifer . I c m e . it
was fact that the geology of the site would not
protect the aquifer .
•
To you it was a fact?
A Yes .
•
But any county board member that would read
this E-mail who hadn't been at that particular
hearing would have been misled?
A No . They would have the full transcript of
the record and whatever discussion you're alluding
to,
•
Ms . Blumenshine, you didn't want them to
read the transcript. You wanted them to read your
E-mail and base their decision on April 6th on
the facts as you represented them in your E-mail,
didn't you?
A No
. I thought I was representing what I
understood to he the facts . My honest answer . I
thought that this is ss hat I understood to he the
facts.
•
Why didn't you send all the board members
an E-mail saying the Sierra Club and the Peoria
Families Against Toxic Waste encourage you to read
Pages 51 to 54
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
Pane
ever seen them .
1
A (Witness perusingdocuntent .) Yes. I ha e .
Q What's the date of that E-mail?
q A That is dated Thursday . April 6th . 2006 .
e
Q That would he the day that the committee
met to vote on recommendations -
F
mark as Exhibit 39
.
9
Q Is there a reason why this document would
A (Witness perusing exhibit .)
10 have been sent to county board members and not
•
Ask you if you've ever seen that document
. _ _ filed with the county clerk?
A Yes,
12
A
I don't know that it was sent to county
•
What is this document?
13 board members . We had a talk at -- I'm trying to
A This is kind of a summary . It says, Issues
--4 r emember . a t Channel 47 that Coulters were at . and
regarding the PDC . Peoria Disposal Company .
-5 there was another event -- I'm trying to remember
Hazardous Waste Landfill and has a US code
-o where the Chamber of Commerce interview was . I
definition of hazardous waste and a CFR definition
don't know .
of hazardou, waste . and then it has an excerpt from
Q On the last page of this document is a
the TRI
. the toxic release inventory, showing
reference to a website, looks like
examples of PDC . Then there's some current
2 0 www .npaction .org, et cetera .
concerns at the end .
21
Is that the Sierra Club's website?
•
When was this prepared?
22
A No .
A It is not dated . I'm trying to remember .
23
Q
Do you know whose website that is?
This was sent out February 9th -- no.
2 4
A I don't know . That's not my writing.
MR . WFN"I WORll I : Read the whole
2 document.
lHl[ : WITNESS : Thank you . let me take
5
a look
. Well . I can't tell you exactl% when it was
prepared .
6 BY MR . MUELLER :
Q Would it have been sent out somewhere near
to
February 9th, to your recollection?
JOYCE
BLUMENSHINE
0
Are volt aware of any site that then had a
2 page that would have been called PDC facts?
3
MR . WENTWORIII : Any wehsite or the
4
website that
.\ou just gave?
7
5
13Y MR . MUELLER:
6
Q If you can't recognize the domain, then you
Q It appears that Peoria Disposal Company got
/ can't.
a copy of this on February 9th?
-
A I don't know what this w,ew .npacuon wehsttc
9
A "I hat's the date at the top of this . right .
9
is .
(Blumenshine Exhibit No . 40 marked)
BY MR . :
MUELLER
Pages 55 to 58
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
10-23-2006
the transcripts carefully so you will know the
1
A
I don't remember . I had a lot of
facts?
A
That was understood that they were to do
3
documents .
Q The TRI numbers, toxic release inventory
that . I mean . they heard the information from the
hearing
.
5
numbers on the second page, those were not ever
made part of the record in this case, were they?
(Blumenshine Exhibit No . 39 marked)
BY MR . MUELLER :
7
A Yes . They are in the record . I believe
there was a file folder in the Sierra Club evidence
Q Let me show you next what we are going to
b
file that contains several years of TRI data .
A It could hays been
.
12
Q Let me show you then what's going to be
Q
A
Q
Heart
Now, did you prepare this document?
Yes. I did .
Did you have authority from the Sierra Club
of Illinois Group to use their letterhead?
1 3
14
1
16
marked as Exhibit 40 which purports to be a letter
from you to members of the Peoria County Board and
Chairman Williams dated February 14th, 2006 .
Did you write that document?
A Well . as group chair. I don't normal I'
17 A Yes . I did .
check
communications .
with the entire hoard on doing
So I took that authority upon
R
i 9
Q What was your purpose in writing that
letter directly to county board members rather than
myself.
70 just filing it with the clerk or reading it into
Q Who's this document sent to?
21
the record at the public hearing?
A I'm not sure at this point .
22 A This was in the record . the evidence file
Q Well, you did not file it with the county
23 from -- I mean . the information that was in the
clerk, did you?
24
evidence file from Sierra Club
. Again. my goal was
uvica oLuI°1r~1vonkpJm
10-23-2006
1 to highlight things that were in the cviden cc .
Q The public hearing hadn't even started yet,
had it?
A No . but we were sending things into the
county record .
F
Q W as Mr . Wentworth a member of the Peoria
Families Against Toxic Waste?
6
A
No .
0
Q Do you know how much Mr
. Wentworth was
paid? We've talked about Mr . Norris and -
1
MR . W [IN'I - W OR I'll : Don't answer that . I
1 2 object on the grounds of attorney-client pri' ilege
13 to the extent of hots much or how little I was
14 compensated is not
:
relevant
plus. it's subject to
'_5 privilege.
16
MR
. MIJELLI :R : I disagree with both of
16
-''
those objections for the reason that the
17
1
19
20
MR . WENTWOR] II : And a privilege is a
20
21 privilege is a privilege no matter what the purpose
2
ol 'our question .
22
22
23 BY MR . MIIELI .I1K :
2 4
Q
Ms . Blumenshine, did you ever meet with any
2 4
18 prioritizing of spending certainly is probative as
9 to what the intent of these organizations was .
Page 60
county board --with Allen Mover specifically
between November 9th, 2005 and May 3rd, 2006?
A No .
Q
Did you ever have any telephone
conversations with him during that period of time?
A I don't recall . I night have let a voice
7
mail . I don't recall .
. .
Q Did you ever participate in discussions
G
with anyone else about targeting board members who
1 . C voted for the expansion or who might vote for the
1 _ expansion with opposition in this November
12 election?
13
A You use the word targeting . We as
14 concerned citizens talked among ourselves about
15 different hoard members votes -- votes from the
1E April vote .
17
Q Well, this talks specifically about Board
18 Member O'Neill .
Was there ever a discussion in your
23 presence after April 6th and before
2
i May 3rd about finding an opponent to run against
22 Mr . O'Neill in the November election?
23
A No . not that I'm aware oil
24
Q Was there ever any discussion that you were
1
aware of of
communicating to Mr . O'Neill that if he
did not change his vote he would face opposition in
the November election?
ever threatened with opposition?
A I have no idea
.
Q What hoard members did you talk to
personally while this application was pending,
meaning between November 9th and May 3rd?
A
I had a phone con'ersation with Merle
Widmer to ask hint because he had said I did not --
I had erroneous information . and I called him and
said what
\
\as
erroneous that I had said : \\hereupo n .
Pag0
he told me that there's no toxins in the PDC'
hazardous
write
landfill .
3
I tried to give him a definition oftoxic
4
substances and our concerns
. and he hung up on me .
5 SO that was that call
.
Q Now, do you remember ever giving some
population figures to Mr
. Mayer showing how many
people lived within a certain proximity of the
facility?
A I don't remember giving something to
Mr. Mavcr like that
. I had population figures in a
12 couple of our handouts. and the' also were in the
1 3
evidence records that woe turned in
.
14
Q If I could take you back to I believe this
15 was going to be Exhibit 39 which is the Sierra Club
16 issues regarding PDC landfill where you had the TRI
i' numbers and you go to the third page of that, does
18 that provide some population numbers about
19 proximity to the landfill?
20
A Yes . it does.
21
Q You indicated that you believe this
22 information was in the materials actually_ filed
23 with the clerk?
24
A Yes
. I believe it was . This was from the
Pages 59 to 62
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
4
E
A
Q
I never said amlhing to that nature .
Well, maybe you didn't, but do you know if
anyone else did :'
A I
am not avv are of any one that I know of
that said that .
9
Q Was there ever am conversation about
10
targeting Board Member Phelan for opposition in the
11 election?
~ 2
A
I'm not aware of anc conversation .
1 3 Q You never heard on y such conversation
:'
14 A I I 'l did . I do not recall it as
--
15
Q
Was Board Member Phelan, to %our knowledge,
JOYCE
BLUMENSHINE
10-23-2006
you say that again, please?.
9
1
Q Do you remember Mr . Slayer on
10
1 1 May 3rd indicating that the population numbers
11
12 about the total people in proximity to the landfill
12
5 were being taken out
of the proposed findings
1.3
because the, did not appear in the record?
14
landfills precious to this time .
•
What was your point in reading articles on
landfills before this application became public?
A Well
. it's an issue of concern for the
health and well-being of the public . and I was
sitting in the audience at the hearing in Last
Peoria hack in the late '90s that you were the
attorney for and those people were'en concerned
about their aquifer . So I read things at that time
and other times .
•
Do you think it would have been appropriate
for Peoria Disposal Company to call, write and
E-mail county board members directly during the
hearing process to offset the spin that the Sierra
Club and the Peoria Families were putting on the
evidence?
A I don't know how to answer that .
•
I'm just asking if you think it would have
been proper.
A Well . I think any citizen has the right to
contact their duly elected officials . and etery
citizen has the right to live their life and take
action lhr what the% belice is a correct and
proper . and in my cicw%
that's protection of our
Pace 66
environment for the future .
Q But even if the law says you're not
supposed to have direct contact, you believe that
the right of people to petition their elected
officials trumps that law?
A
You'v c referred to the law . I must sa\ I
was acting as the best I could as a volunteer
citizen . and I must soy that definitions of the law
exactly how things are done probably wasn't . you
know . the complete understanding that I had in
effect at the time . We were doing the best we
Could as citizens . toluntecrs .
Q Well, if you had a loved one who had a
court case, you know that you're not supposed to
contact the judge outside of that court case to
tell him or her your opinion, don't you?
A Right .
Q
So you wouldn't think of contacting a judge
to intervene and provide your viewpoint as to what
the outcome should be on a loved one's court case,
right?
A Yes
. But a judge is in a court and they
wear robes and they are not as I see like county
hoard members that are public
-- you know . directly
Pages 63 to 66
PEORIA DISPOSAL COMPANY
V . PEORIA COUNTY BOARD
PCB06-184
16
A I hasc
forgotten
that . I'm sorry .
Q flow would he have known about those
1 6
1 population numbers
if you hadn't communicated them I
1$ directly to him at some point?
1
1
a
A hhese are accessible numbers to am body on
19
_ : the internet
. I have no idea ifthis went -- I
22
2'_ can't remember if this went to the hoard members or
2 -
not .
2 2
Q So it's your testimony you never
2 3
24 communicated population numbers to Mr
. Maver?
24
1
Page
A
I don't recall that .
2 Q But you may have given him a copy of that
2
3 document . Exhibit 39
. right, or mailed it to him?
3
4 A This particular handout could have been
4
5
handed out at numerous places.
-
6 Q Other than the public hearing, right?
6
A Right .
Q Ms . Blumenshine, what's your educational
8
10
background?
A I have a master's degree in library science
10
1 1 from the university of Michigan
. I low tar hack do
11
you want me to go
,
12
1 3 Q That answers that
. What's your work
1 3
14 background prior to your becoming employed as you
14
1
said musician?
15
A That's correct . I have been a librarian
16
17 Ibr about 32 years at various libraries .
17
18 Q Do you have any particular knowledge
18
1 +
regarding landfills and waste disposal other than
1 9
20 what you learned during this hearing process?
2 0
21 A Yes .
21
22 Q What other knowledge did you have?
22
23 A I have read other articles in magazines-
2 3
2
4 other publications that might have been on
24
Pca :'
b_`
1 echo data which I got online
. and I thought I had
L an evidence Bolder_ whatever
. the sheets with that
t
report was in the Sierra C'luh evidence tilt
_,
Q Do you remember on May 3rd Mr. Mayer
4
indicating that he was taking the population
6 figures out of
the proposed findings because they
b
7 were not located anywhere in the record?
'~
A
I don't remember that . I'm corn . Could
b'
JOYCE
BLUMENSHINE
10-23-2006
Page 67
representing the public .
•
Didn't you understand that the county board
members in this case were to act like judges and
make their decision based not on popularity or
public input but on what the evidence at the
hearing was?
A
I knew that the' "ere to base the decisions
on the eN idencc in the record
. and that's "hat "c
were referring to and that they would be Noting on
10 it
. I don't know that I could sec them . like . as
~_ official judges : hut . vesN
the' would be Noting on
:1
12
Q Well, you thought it was appropriate to
13
1 4 contact them to emphasize certain parts of what you -4
1 ° believed were in the record?
A Yes . I did.
16
_
Q And to provide your own spin on what you
17
I thought certain evidence meant?
16
1 9 A
I thought it "as appropriate under the 1 9
22 circumstances that PDC had spent over a million
22
21 dollars on the application and 'vas a large
2
corporation to make an effort to highlight the
22
Iacts as "c saw it .
23
•
Now, you're not aware of any single
2 4
E.
1 "ant to know "hat she knew or thought the rules to
.. he . As such . I believe it's a proper question .
MR . WF.NTWORTII
: Which b> definition is
"hat ad' ice ma' he : and
. therefore . it's still
subject to the privilege
. I understand "h% you're
asking it . I don't think you're entitled to ask
it .
BY MR
. MUELLER :
•
Let me do it another way
. Were you told by
anyone, Ms. Blumenshine, at or around the time of
the public hearings that direct contacts with
county board members were not appropriate in the
A I don't know . No one e'er talked to me or
13 process?
A
Not appropriate in the process . Okay .
Nov' . I am trying to recall because there's so much
that was going on at that time . I mean . I knc'N
clearly that it was to he based on the (acts and
evidence in the case that Noe were working so hard
just trying to collect our evidence that I'm reall>
u, ing to recall .
Q Go ahead .
A
I'm trying to find a specific time that I
could recall that that was exact- and I suppose
that that happened
.
improper ex parte contact by PDC while the
application was pending, are you?
A
You're talking from No' ember to May'!
That's correct .
No .
No meaning you're not aware of such contact
or no meaning I'm wrong?
A I'm not a" are of it .
•
If PDC had, in fact, been out lobbying
board members let's say in March and April, you
would have complained that that was unfair,
wouldn't you?
Q
A
Q
Page 68
Page 70
with count_' -- with contacting countv hoard
members .
•
He reviewed
. When did this review occur?
A I'm to ing to think "hen "c started that
process . It "as 'en close to the --'cr> close to
the hearing
.
•
Close to the hearings in February, correct?
A Well . I must sa' there "as so much going oil
and I "as working vcq long nights. I would havc to
be for sure here . I'm tr-\ ing to recall .
•
So you were told somewhere around the time
of the public hearings that these direct contacts
with county board members were improper?
MR . Wl'N I WOR I H : Objection to the
extent that it's subject to the attorney-client
privilege . N e're getting into the area no" of "hat
legal advice and "hat work product and "hat
communications she had with her legal counsel .
MR . Ml16LLLR : Well . she's the one that
brought it up b> sa> ing she "as told . I think I'm
entitled to inquire because it goes to motive and
mindset here .
I'm not asking fix the specilies of
an' one's ad' ice or "ho gave it necessariI> . I just
Pages 67 to 70
PEOPIA
DISPOSAL COMPANY v . PEORIA COUPITY BOARD
PCB06-184
pointed out to the Sierra Club fix our information
1 4
that that was unfair or inappropriate .
1 `
Q No one ever indicated that you were not to
1 6
engage in ex parte communications with the county?
1
A Here "e go back to that term
.
]9
Q Now, as a member of Peoria Families Against
19
Toxic Waste, did anyone ever communicate to you
20
that you were not to engage in ex parte
21
communications with county board members?
22
A When Noe had our atterne) which was ver'
23
close to the hearing . he reviewed the situation
24
JOYCE BLUMENSHINE
10-23-2006
Page 71
•
Were you ever told by anyone that you
1
should not be contacting county board members
directly? You're nodding your head as in the
4 answer is yes .
A W ell, that is something that obviously we
>
6 wanted to contact board members to state our case .
6
I am trying to recall if somebody told me directly .
8
We had heard the information about how the
y
decision would be made . We were concerned that
5
10 other entities were calling county board members .
1 C
_ 1 state representatives . other people that we heard
11
12 that were calling county board members .
:2
_
So I -- I'm trying to answer this as best I
-3
1 4 can
. As far as someone telling me I should never
talk to county board members . I don't think it sunk
1-5
1 6 in if that had been told to me .
1 6
1"
Q What I'm hearing you're saving is that you
17
technically knew that you shouldn't do it, but you
10
2
9 felt that you had to in order to stay in the game,
1
20 is that a fair statement?
20
A I'm trying to think about that . Somehow it 21
22 wasn'tL you know . the primary thing in my mind as
22
23 far as not contacting county board members . The
23
24 main thing was that everything that we referred to
24
Page 72
as in the record or in the hearing . that was the
main thing that I was attending to
.
•
Let me ask the question again
. Thank you
for that information .
Is it a fair statement that you knew that
technically you weren't supposed to be contacting
county board members directly, but you felt you
needed to do it anyway in order to be successful?
A "I he vcag you No e phrased that to he
successful . I think our goal \c as education from
\chat was in the record and information from that .
If something seas told to me directh at that time .
you know . whatever I had in my head it seas that \ce
had to refer to things in the record and in the
hearing testimom .
•
Ms. Blumenshine, I take issue with your
2
4
6
c
a
10
1
to vote no, isn't that true?
A I did hase things I "rote that said to urge
people to \ote no .
•
So let me then ask you once again, yes or
no, is it a fair statement that you knew that
technically you were not supposed to be contacting
county hoard members directly but you felt you
needed to do it anyway in order to he successful in
the opposition'!
A Well . my mindset at the time seas--
•
Well, is it a fair statement or not that I
just made?
A I'm not sure that I can sa) that I fulI\
realized the extent of hat
.sonre
sax ing . I mean .
as far as hos\ much
. \ ou knoss . see had to adhere to a
certain specific action on that because see were
members of the public .
•
You were also members of a registered
opposition group, weren't you?
A I'm a member of the Sierra Club . \ es .
I hat's right .
•
Y'ou were a member of Peoria Families
Against Toxic Waste?
A That's correct .
Page 74
MR . Mt 11 I .EIIR : We're going to take a
live-minute break .
going
IRecess horn 10 :15 to 10 :30)
MR . WEN I WORTH
: We hate been handed
Group Exhibit 37 vehich are documents within the
loser right-hand corner all hay e the date
10'22/2006- and it's a group exhibit labeled
Exhibits A through S . So there are that nwm
individual F-mails
.
.toy cc . did those come off of 'our Yahoo
ser\ er account or E-mail account that you printed
12 out _yesterday^
13
TI If
: WITNESS
: Yes, these are-- the
14 ire all from ms
-- yes .
15
MR
. WEN I WOR Ell : So you either sent
16 them or reeeiyed all of these documents that are
saying your main goal was education because I can
1
7
about the time as indicated on the E-mail?
probably show you a dozen communications by you
10
1111
: WI INESS : Yes .
where you urged people to contact their county
1 ,
BY MR . Ml!IFI.I .ER :
board members to vote no .
20
Q
Ms
. Blumenshine, what's your relationship
A that is true .
2
: with Elaine Hopkins?
•
You weren't urging people to contact their 22 A
I know Elaine I lopkins is a writer fix the
county board members to get educated . l'ou were
2
Journal Star.
urging
people to contact their county board members 24
Q
Have you in the past or do you
now have any
Pages 71 to 74
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
JOYCE
BLUMENSHINE
9
10
. .
12)
13
14
A
No .
17
1 5 Q Do you remember being interviewed by heron I
16 or about September 9th of this year when the i 6
process for the Pollution Control Board appeal was
1
_r being discussed and stating this deja vu
1 9
19 McCarthyism?
19
A She called me on the phone and asked me
2 0
2 1 some questions about the coming situation here .
2 2
Q Do you recall saying this is deja vu
22
23 McCarthyism?
23
24
A I recall I said -- we were talking about
2 4
•
Absolutely .
A (Witness perusing document .) % ell . and the
board members are facing serutim . I think the
extrapolation that we volunteers had made it \undd
he likely that other people Mould also do that .
•
Scrutiny was going to be about the
decision-making process, you understood that
.
right?
A Well . about the process . right . About the
process . right .
•
About the process . So you knew you had
done something wrong?
A No .
•
At least by this point?
A No .
•
Well, as you sit here now, do you
understand that contacts of county board members
outside the hearing process to give them your
Page 76
emphasis in your opinion of what the facts showed
was improper?
A No . I s till . a s eou said
. I have trouble
v, ith the improper because we were told that the
county board members would be answering us or
something . but they worn still our elected
•
officials
. As members Little community . you know_
we could --
•
• Who told you that
A
Well , that as m' --
•
You said "we were told." Who told you
that?
A I'm sore
. I should sac that in im mindset
14 the County hoard members \sere still our elected
1
officials
and that we had a right to contact them
.
16
Q And urge them to vote no?
_
A And as I said . not urge them
-- well . vote
i 6 no but to . you know
. highlight the information and
19 that we as citizens would he part of this process .
20
Q But, once again, you specifically on a
21 dozen of occasions encouraged everybody who would
22 subpoena . but I think we knew that that was
22 listen to you to contact county board members to
23 probably -- I knew that that probably was going to
23 urge them to vote no, and you even facilitated that
24
happen
or something like that .
24
by providing a ddr e sses, phone numbers and E-mail
Page 76
the situation that a whole bunch of citizens were
-
called in to be subpoenaed, and I had said, you
2
know, there's a long list of things that I have to
3
get ready and the hours and hours it would take me
4
because it would take me a huge amount of time to
6
collect this information, I assume for other
7
people
. too . That came to mind, yes .
8
Q Thank you for that answer . Now, let's
9 answer the question again .
10
Did you say as you were quoted in the
10
11 newspaper article, this is deja vu McCarthyism?
12
A
Well . I said numerous things, and I thought
~2
13 I had said that
. We were talking on the phone for
14 a while, and I said a variety of things that aren't
15 in there
. To the best of my ability, I'm trying to
16 recall
. I think I had commented that way .
17 Q So you were not misquoted?
18 A No .
19
Q This is actually before any citizens were
2 0 subpoenaed to give depositions?
21
A Well, I think I had not received a
Pages 75 to 78
FEORIA DISPOSAL COMPANY
v . PEORIA COUNTY BOARD
PCB06-184
10-23-2006
Page
social relationship with her?
Q How did you know that was going to happen?
A I have attended some things that she was
A I suspected it because just the way -- I
at . but I wouldn't call it a social relationship
.
mean, the appeal is in the process
.
Q Do you consider her a friend?
A SheIs
a nice person . I can talk to her.
Q
How frequently did you talk to her during
4
E
MR . WENTWOR Ili
: Could the deponent
look at the article?
BY MR . Ml TLLER :
these hearings?
A I probably said hello when she was coming
8
into the hearing room
-- I'm sorry . the 1100 I fall
-
and I copied her on some t: mails .
10
Q
Did you ever call her to give her your
_
private spin on what you thought the facts were
12
while the hearing was going on?
13
JOYCE
BLUMENSHINE
10-23-2006
Page
addresses for county hoard members?
A
I did make listings and I supplied
information that was in the record or front the
4 testimony, but also part of that was encouraging
members of the community and citizens to be part of
the process .
•
By contacting county board members to
encourage them to vote no, right?
C
A As I said . I think the main goal was
1 0 information and getting people aware that the
landfill was here . and we also -- I also wrote
things asking people to contact county board
1 _3 members .
14
Q We're going to get to some more of your
1 5 main goal in a second .
16
What was McCarthyistic, by the way, about
7 7 the process of an appeal in this case? What did
-!` you mean by that statement?
1 9
A It was not process of an appeal, but it was
2 C the process that people are being called in for
21 depositions and the whole burden it places on the
2
public or me, in my case talking for m yself. t o
2 3 collect papers or, you know, pull together things
2 4 over a long period of time
.
rage 80
•
So having to answer questions about your
role in the process you think is McCarthyistic?
A No. not to answer in the process. but the
4
fact that . you know
. a large number of tolunteers-
e'enday citizens were being called up ix subpoena
~: to me it sounded -- you know
. it's not something
that I hat c e% er done hclbre .
•
But what was McCarthyistic about it
9 particularly since no citizens had been subpoenaed
1 as of when you made the statement?
1 '.
A Board members w ere being subpoenaed .
12
Q Is that McCarthyistic to subpoena a board
i3 member?
1 4
A No . But it means that you have more
15 questions . and as yoti re doing now
. you're
16 searching for some kind of information that I don't
17 know ecactly what it is that you're --
1
19 Q
What's your understanding of McCarthyistic? 1 8
19 A
McCarthyistic . I would describe it as kind
1 9
2 0 of a comment as that regular citizens are called up
2 C
2i to do something that might make them the second
2 1
22 time around he less likely to either participate .
2 3 speak out
. \trite or do anything else because people
24 tend to he kind of concerned when they are in\ohed
2
23
4
_aae
in legal matters .
I see the process here, although . I have
every right to get information, as something that
puts general citizens in -- feeling uncomfortable .
•
You don't believe that citizens should be
accountable for their conduct?
A I believe citizens should be accountable
for their conduct
.
•
Is it McCarthyistic to ask people to
account for their conduct?
A No .
•
You believe that the process of this appeal
whereby Peoria Disposal is trying to protect its
rights is going to have a chilling effect on the
public in participating when we do this again?
A Well, I wonder about that because the
information from the hearing or the testimony . all
the things that we had entered into the record was
easily available to you . You had that .
So the fact that people were called in for
questioning just
-- I mean . I do wonder if it's
being used as a tool to discourage future public
participation .
Q Well, if I were to tell you that we're
Page 92
interested in discouraging future violations of the
law regarding ex parte contacts but welcome public
's
participation, would that give you comfort?
4
A W ell . you know
. if this case comes hack
again . I don't knots that that will
-- I mean . we
all need to learn about this process
. I hear what
oti re say ing . N e need to learn about the process
.
So . r ight. i t would 11CIp people to understand
what's the process .
•
Now, isn't it true, though, that if this
case comes back again for another hearing you'll
encourage people to contact their county board
members directly again just like you did before?
MR . WI
:NTWCIRI'll : That calls Ibr
speculation .
11) MR . MUELLER :
•
If she can answer.
A
I don't want to predict the future . Maybe
pDC will decide to close their landfill because
it's polluting the aquifer .
•
That's a fact that it's polluting the
aquifer?
A No . That yeas agreed to by hen Liss. 1 he
word polluting --
I should say . the truce elements
Pages 79 to 82
PEORIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
JOYCE BLUMENSHINE
10-23-2006
was part of the public education agenda that the
Peoria Families and the Sierra Club developed?
A You know . I don't think Peoria I amilies and
Sierra Club des eloped an agenda as you speak . We
had some topics that we thought were important . but
I don't think there was am intent on businesses .
Our petitions and the petitions I circulated we
went to individuals or had them in places where
there were individuals .
•
So it was not -- going to businesses and
soliciting their support or participation was never
something that was discussed in your presence?
A
I don't recall that.
Q
Do you know someone from the Journal Star
named Tory--Terry, Terry Bibo?
A Tern 13ibo is a writer at the Journal Star .
Q
Do you know him?
A 11er.
Q Her?
A I have read her articles and met her a time
or taco .
Q
Have you ever talked to her outside of the
public hearing process?
A
ISver?
Page So
MR
. \k EN IWORTI I : About this'?
13Y MR . Mill-I .LfR :
•
About the PDC expansion .
A I don't recall that I talked to her about
the PDC expansion .
Q
Have you talked to any county board members
since their depositions about what you could expect
at your deposition?
A I have not talked to count\ hoard members
about their depositions
.
•
When's the last time you talked to Allen
Mayer for any reason?
A Oh . Hem ens . that's been a long time ago .
I couldn't tell con the date . Nothing comes to
mind particularly .
Q When's the last time you talked to Lynn
Pearson for any reason?
A It's been some time ago . As I recall .
prohabh have phoned her and l eft her a voice mail
or left her a message earlier in the process .
•
Well, let's break it down
. Have you talked
to any county board members about anything since
your September 9th, 2006, quote about the
deposition process being deja vu McCarthyism?
Pages 83 to 86
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
Pane 83
E
of pollutants are in the aquifer . That was agreed
to by PDC's own expert witness, Ken Liss .
'-
4
t
P
Q So in your mind, that equates to PDC as
polluting the aquifer as a fact?
A Well, that was agreed to at the hearing,
and I would say that it is a fact that there are
trace elements of pollution at the aquifer level
sands .
4
Q Did you appear at the PDC website or PDC
9
11 facility shortly after May 3rd in an attempt to
11 block people from coming into or leaving the
12
facility?
2
13
A No
. I was there not blocking people coining 13
14
in or out
. I was there for a day or so counting
4
1 trucks going in . W'e wanted to get an idea of how 23
16 many trucks and the size of the trucks that go in .
1 6
_I
We were on the side of the road .
1
Q There was no attempt to block traffic?
18
'.
A Absolutely not .
1 9
Q You just were doing an informal traffic
2
2 count is what you're saying?
21
22 A
Q
That's what I was dome .
To your knowledge, was Mr . Edwards also
2 :
24
doing an informal traffic count?
Page 84
A I know he was there lot a whiles yes .
Q Was the Native American war dance that was
1
3 being done part of the counting process?
4 A I'm not sure w hat Native American war dance
you're referring to .
5
Q Were there dances and exhibitions while you
6
7 were at the PDC site?
?
8 A I know people were cold and I know people
-.
9
were jumping up and down because it was real 1
.
c cold
10 and windy out .
1 C
Q How many people were there counting trucks,
12
by the way?
A It was myself and 1 om was there fnr a
4 while . then he left . and Diane Store,\ cane for a
while .
_5
16 Q Was Mayvis young there?
1 6
i- A She was there also lose a while .
1 3
14 Q In fact, it was demonstration, wasn't it?
18
19
A No.
1 5
20
Q Did you ever go to any businesses and urge
20
21
business owners or operators to sign petitions?
22 A l do not recall that I cvcr went into
23
businesses and asked people to sign petitions .
23
24 Q Do you know whether pressuring businesses
JOYCE BLUMENSHINE
10-23-2006
•
Well, was there ever discussion, though,
1 1 about trying to find locations close to board
12 members' homes?
-2
A
Sierra Club focused on neighborhoods when
1 4 we were walking, and it is -- the general areas
~ 4
1 ` could have been around, but I must say we covered a
1-,
16 large area . We wanted the public to be aware of
16
1 - what was happening and get the public involved in
15 the process .
15
•
We've done this before . The purpose of
19
getting the public involved was so they would
2t!
2'_ provide more pressure on county board members,
21
22 right?
2-
A Well, the main purpose was so that the
23
people of Peoria would wake up to the fact that
24
Page 55
there is a hazardous waste landfill at the
immediate edge of the city and to get invoked in
the process that was ongoing . and that was
e' crsthing that it could beer en that the' would
know the hearing ssas coming up .
• So the secondary purpose then was to get
those members of the public to pressure county
board members to vote no, right?
A I do not agree with'our cording there on
Peoria . Enough is enough . No more hazardou, waste
us er our aquifer . It say s. Sa) no to 15 more
'ears . 2 .2 million tons more of hazardous No aste
coming into Peoria Count'
. t'rge the Peoria Count'
Board to Note noon Ma' 3rd .
We need 'Oil .
"ednesdus . Ma) 3rd .
2 : 0O p.m . or after at the 1100 I lull . 4909 West
Parntinglon Road . Peoria .
fib'
the Peoria Count'
Board sole on the PDC Hazardous Paste Landfill
Ilcpansion Permit Application .
Do
roil
want me to read the addresses and
other things?
•
No . You skipped a line actually .
A I'm sorr'
. I didn't mean to .
•
That would be the line that says, Please
phone and write to the following Peoria County
Board Members .
A Let me read that into the record .
•
Do you agree that I read it correctly,
Please phone and write to the Peoria County Board
members?
A Yes .
•
And who were the four board members
identified there?
Page 90
1
A 'That's Robert Baietto . Patricia I liddcn .
Thomas O'Neill and Timothy Riggenbach .
-
Q What was the purpose of identifying those
4 four?
A Well . I know in the case of Pat I lidden she
h said thems no toxic at the PDC landfill . and
7
these other individuals were part of the group that
we were tr' ing to he sure that the ; heard tom --
r' about the landfill being over the aquifer .
Q No . This doesn't say to be sure to talk to
these people about the landfill being over the
aquifer.
It encourages people to contact these board
members to urge them to vote no, doesn't it?
A That is what it sacs
.
Q
Are you saying that you miswrote this
document? What you really meant to write was
contact these board members and explain the facts
to them?
A No . It doesn't say that . I wrote people
on there
. It also saes to please come to the
hearing . I think there's an element there that
encourages people to attend the meeting
. but it
does ask then to vote no .
Pages 87 to 90
PEOPIA DISPOSAL
COMPANY v . PEORIA COUNTY BOARD
PCB06-184
Page 5
.
3 Peoria
A
Q
No .
1
Was it ever part of the Sierra Club or
Families plan in doing the opposition to try
to find yard sign locations in close proximity to
board members' homes?
6
A
We had talked about yard sign locations,
6
and I know in Chillicothe it was very cold . we had
a few walkers, and so we tried to have some on the
P
main highway . I know that I did .
pressure . Could get people in' ohed and to
1 2
participate in the process
.
1 :
(lilumenshine Inhibit No . 41 marked)
12
BY MR .
MUELLER :
13
Q
Well, let's see what kind of participation
_ 4
you wanted . This would be Exhibit 41, purports to 15
be some
type of flier with the caption Hazardous
1 P
Waste Does Not Play In Peoria .
1
Have you ever seen that before?
1
r
A Yes .
1 9
Q Who was that document prepared by?
2U
A I wrote this .
21
Q
Why don't you read what it says and we'll
22
see how
much public education is in there.
A It sacs . Hazardous Waste Does Not Plas In
2 4
JOYCE BLUMENSHINE
10-23-2006
i
Q
Isn't it true that these four board members
-
these four people because you thought you could
change their votes?
A Is there a date on there?
Q Well, my guess is it's in close proximity
to May 3rd and it would be after April 6th .
A Okay . I don't remember the exact date of
1 _' this . but it does, right . ask them to vote no on
1-=_ the landfill .
1 5
Q
But why those particular four people? Can
16 you tell me that?
1 7
A Well, because we wanted these people
1 N contacted regarding whatever the timeframe was on
1 9 this . I guess that's it . and --
20
Q How was that--was this in the form of a
21 leaflet?
A That would be my likelihood, yes .
Q Did you have this handed out on a
door-to-door basis?
23
2 4
Pace 92
A This particular page -- I mean . the
leaflets usually had a general article from the
.s Journal Star or something else on the hack from the
4 hearing if it was from that t imeframe . hut . ces
. i
t
was likeh that this \au handed out or put in
6 people's doors
. I should saw .
tl3lumenshine I .shihtt No . 42 marked)
P BY MR . Mt1FI .1FR
Q Then let me show you the nest exhibit which
1
is going to he 42 . this one is captioned, Thank
11 I ou . Thank You, Thank \ on, Thank \ ou . \y ho was that
prepared by?
A I wrote this .
14
Q Okay . Was that also a public education
I .5 document?
16
A Well, no . I don't think it's public
17 education --
\ cell
. at
the bottom it does sac the
1 P geology (it the ground under the PIJC hazardous \waste
5 landfill does not protect the aquifer . )'here's
2 0
some other information here about the current
status. the lacers of plastic liners will
22 eventually break don n
.
23
Q What was the point of your doing that
24 particular leaflet",
A Well. it sacs . Ihank cou
. Please phone
your thanks to the following Peoria C'0unty hoard
members who Noted no to PDC at the counts
count \- hoard
finding of fact hearing .
•
N by did those people need a thank you call
when the hearing was not over et?
A Well . I think Nou in icht sa\ that a good
sense of the Note \\as taken at the findin , of ],let
hearing . That is \ \ he n the hoard nremhers based on
1 ,
their reading of the record and the lestimom and
11 the hearing Noted on the finding of fact
. So that
12 became public known (edge at that tune
.
•
Did you think it was appropriate while the
1 4 hearing was going on to contact counts board
7 members and to urge others to contact hoard members
1 6 to sac thanks for your first cots?
A
I did that.
•
Did you think it was appropriate?
A I don't know it 'l weighed sNhether it was
20 appropriate : hut . yes . I thought it was
appropriate . I did encourage people to do that.
22
Q %\hat facts were you trying to come\ to
23 those county board members to offset PDC's spin?
24
A Well, at the honour it has
Pace 94
2
1
Q Those are the facts you're trying to convey
or it encourages people to say thank you, doesn't
it?
A Yes, it does .
5
Q So they weren't being encouraged to convey
6
facts? Thev were encouraged to say thank you,
right?
P
A
That's the whole top part of it, and the
10
9 lower part of this talks about the information on
10 the landfill that we typed in there .
_ _
(Blunienshine Exhibit No . 43 marked)
BY MR . MUELLER :
Q Let me show you the next exhibit . What is
1 4 that document?
A
Well, this is a flier .
1 6
Q How was it distributed?
1
A I believe it was door to door
.
I
Q
Who wrote that flier?
19
A This flier is written by Abby Grawey
.
20 Q
Who's she?
21
A Abby Grawey is a young lady who had
22 volunteered to help the Sierra Club . She has come
23 to Sierra Club functions .
24
Q How old is she?
Pages 91 to 94
PEORIA DISPOSAL
COMPANY v . PEORIA COUNTY BOARD
PCB06-184
were all perceived to be people likely to vote yes
on the application?
4 A No . Oh, wait . I'm sorry . To say yes on
4
6
the application?
Q Yes . So you targeted the public to hit
e
JOYCE
BLUMENSHINE
10-23-2006
1 9 Mr . Riggenbach's district?
20
A It looks like that . Yes, it does .
2'1
Q What was the purpose of targeting
22 Mr. Riggenbach's district for distribution of this
2 leaflet?
24
A
Well, there's a lot of information on this
Page 96
1 leaflet and it says . Why is the dump so bad? The
2 geology of the land under the landfill does not
3 protect the Sandkoty aquifer, our major water
4 resource located under the dump .
5
Q I think my question was why was
6
Mr . Riggenbach targeted specifically for this
7 leaflet?
B
A
Probably -- well . because he was on the
9 county hoard .
10
Q
You didn't target 18--all 18 county board
1 0 it .
Stone and Tracy Fox .
Q
What was the purpose of that visit to the
IEPA?
A
W e wished to find out the process for the
renewal application for the PDC hazardous waste
landfill permit which was our understanding that
PDC' had applied to IEPA for renewal of then-
permit . their current existing operating permit .
Q
Any other purpose there?
A We wanted to convey our information from
Can you be specific as to who its authors
were?
A The part on the hazardous -- the liners,
our concern about the liner at PDC particularly in
cell C I was written by Tracy Fox . I wrote the
section that was concerned about trace elements of
pollution in the aquifer .
There was a part aboutjust our community
of Peoria, the location of PDC as far as its close
proximity to the city and that was written by Lisa
Offutt, and the part that was about the findings of
fact from the county board I think Tessie worked on
that and Brad Stone .
Q The document contained only facts, correct?
Pages 95 to 98
PEOPIA DISPOSAL COMPANY V . PEORIA COUNTY BOARD
PCB06-184
Pane
A
Q
A
Q
She's a high school student .
She's a high school student?
I believe, yes
.
So you enlisted the aid of high school
4
Q Now, did you go visit the IEPA director in
July of this year?
A
Q
Yes .
Be Director Scott, you visited him on
students in this case?
6
July 26th?
A No . As I said, she came to me and said she
A Correct .
would like to help .
F
Q
A
Who went with you?
Q Now, the bottom of that document identifies
We had Tessie Bucklar . Lisa Offutt. Brad
.9 the county board findings of fact or the count_)
20 board findings of fact .
2- Q Was there any written presentation made to
2 2 the IEPA director?
23 A Written presentation . what do you mean?
24 Q Anything presented to him in the form of
Page 99
written information?
A
Yes .
Q
What was presented to him?
4 A We had a power point .
Q Who developed that power point?
6
A Volunteers wrote parts of it and different
7
ones of us wrote the parts that were in the power
point
.
9
Q Well, you said different ones of you wrote
the source of it being the Heart of Illinois Sierra
9
1 J
Club?
10
11 A That's right .
11
Q So did you approve that document before it
12
was distributed?
1 3
A No, I did not .
1 4
1 5 Q I notice that it says on there, also, your
1 5
16
board member is?
16
1
I P
A
Q
Yes, it does . I see that in the corner .
So this was targeted just at
' F
districts, did you?
I'.
A No .
12
Q Just Mr . Riggenbach with this leaner?
13
A This leaflet is directed to Mr
. Riggenbach .
14
Q Is there a reason why his district and no
1
others were targeted with this leaflet?
6
A
Well, it doesn't have a date on it, but it
1
could
be because of his vote at the finding of fact
10
or it could
be also because this is the area that
1 9
was
-- this group was walking .
20
Q
Do you know a Meg Whitmer?
21
A I'm sorry . What?
22
Q Meg Whitmer.
23
A
I can't put a connection to that name.
24
JOYCE BLUMENSHINE
10-23-2006
Paso 99
Pa o
county board members?
A I do not recall that I attempted to gi' c
buttons to count' hoard members .
•
Do you know if somebody else attempted to?
A I know that Mac' is Young made those pins
.
I know that she distributed them prett' w idol'
. I
don't know if she gacc them to countv hoard
members
. She might hate left them out .
•
Did you ever attempt to present petitions
regarding the landfill at any county board
meetings?
A Present . Could 'on define what 'on mean b
.
\
"present"?
.
•
I would say that's to turn it over, to hand
it in, to give it to a county representative?
A To hand a person a petition
. not to displa'
Page 102
them up front because I think Jinn I Awards at one
time during public comments displayed sonic
petitions up front and it was not allowed
.
Q Did you ever display any petitions?
A No .
Q Did you turn in signed petitions as in
here's petitions with X signatures on our behalf?
A I didn't do that . Tom I'dwards was doing
that project .
Q Do you recall being advised by county
representatives at a county board meeting that you
attended that the opposition members were not to
have direct contact with county board members
outside of the public hearing itself?
A At county hoard meetings'!
Q
Yes
. Do you remember being advised of that
at a county board meeting that you attended?
A No
. I think there was sonic discussion of
the process on how things would he happening with
the hearing and the procedures . We were there
usually just for the public comments . a small part
of the beginning. the opening of the meeting . and
so I don't ha' c any other knowledge of that .
Q You don't recall ever hearing anything
Pages 99 to 102
PEORIA DISPOSAL COMPANY v
. PEORIA COUNTY BOARD
PCB06-184
A Right . It was things that we had pulled
and I do not recall being told not to wear those .
I out of the counts hoard record or things that were
s part of the hearing . R e were conveying our concern
4 as members of the public to IGPA regarding the
upcoming renewal process tier the PDC hearing
- sore-
. ]or PDC's Csisting permit
.
Q Do you know Donna Schwab?
A I know that name . I had seen her at
4
6
F
Q
me .
A
Q
Do you remember actually being--excuse
Are you finished with your answer?
Yes . I am .
So the answer is you were never told not to
wear your buttons to county board meetings?
A
Q
I do not recall that . no .
Did you ever attempt to give buttons to any
9 meetings .
10 Q Do you have any personal relationship with
10
11 her or have you ever had one?
11
12 A I wouldn't call it a personal relationship
.
12
1 3 She was on the Lake' jew Wilds Board which I'm also
13
4 a member of. and the Lakeview Wilds Board is for
14
10 restoration of a stream area for a hiking path
.
15
16 Q
A
Is she a member of the Sierra Club?
I don't know
. I don't think so . ]don't
1 6
14 know .
1 9
1 9 Q What meetings had you seen her at? Just
19
2 0 this hiking path meeting?
2 0
21 A Lake'iew Wilds meetings. right .
21
22 Q Did you ever have a conversation with her
22
23 about the Peoria Disposal Company application?
23
24 A Not in my recollection that we just sat
Page 1C'0
24
down and talked about it
. It might have come tip at
'_
the I,akevie'c Wilds meetings
.
2
Q Were you aware that she was a county
4 employee?
4
A I think she worked at the nursing home
.
Beyond that --
or worked with something about the
6
7 nursing home or something
-- I . yeah .
-
Q
Did she ever provide you any information
F
9 regarding the county in relationship to the Peoria
q
1 C Disposal Company application?
10
11 A No .
1 1
12 Q Now, you frequently attend county board
12
13 meetings, don't you?
1 3
A Yes .
14
15 Q During the pendency of this application,
15
16 you continued to attend meetings of the Peoria
16
17
County Board, right?
17
18
A
Yes .
18
19 Q You would wear antilandfll buttons to
19
20 those meetings?
20
2' A Sometimes . ces .
21
22
Q Do you remember ever being told not to wear
22
2 3
your buttons at any of those meetings?
2 '
24 A Well
. we sat with the public in the back .
24
2
I about not having direct communication with county
hoard members?
3
A Again . are you saving that this was at the
4 county hoard meetings"
Q It's obvious to me, Ms . Blumenshine, that
6 someone somewhere told you not to have direct
"'
conversations with county board members, and you're
reluctant to tell me when or from whom you got that
9 information
. So that's why I'm trying to pick
10 possible sources .
11
Do you remember getting that information at
12 a county board meeting?
A No .
14
MR . WIN TWOR I H
: I think she's already
15 anssered that as well
.
16
THE WI I-NESS
: I don't . You know.
17 again . we were doing lots of things
. If something
_? "as said
. I'm th ing to he 'en accurate . I don't
19 remember that .
20
21
22
23
24
1
deposition
. and there's been no communications
2 specifically on how I narrowed the scope and
3 whether that would he acceptable to you
.
4
MR . MUELLER : Mr
. Wentworth . for what
5 it's worth . we got the objection late last night
.
6 In fact, I didn't get it until this morning . and we
have not had an opportunity to go through all of it
8 to determine whether or not we want to take that
9 issue further
.
10
It's possible that we may be content with
11 the amount of documentation that was produced .
12 It's also possible that we may not he .
13
In the event that we were not, we would
14 reserve the right to depose Ms . Blumenshine further
15 only as to matters that would be revealed by
16 additional document production .
17
MR . WENTWORTH : And if-- to the
18 extent that were the case . then I don't think we
19 would have proceeded today . So I faxed a letter
BY MR . MUELLER
:
2 0 over at 10
:30 in the morning on Friday and didn't
Q Do you know if Converse Marketing paid for
21 hear anything for the rest of the day Friday
.
maintenance of the svebsite that Peoria Families
22
As you know . I got a ton of those documents
Against Toxic Waste had?
: 2 3 delivered over the weekend, and so I just wanted it
A I think I heard led Converse say that he
2 4 a little hit on the record . I understand that
1 was paying for it . I think it was a personal --
person
. Pat or Kim . We had some discussion about
3 helping . donating mone' toward that
. Everybody was
4 going to take a month . to
support the wehsite for a
5 month . That was discussed
.
6
Q Who was the treasurer of the opposition
7 effort?
B
A Which opposition efort?
9
Q Peoria Families Against Toxic Waste?
10
A
Cindy McLean handled all the funds .
Page 103
Page 105
7
JOYCE BLUMENSHINE
10-23-2006
Page 104
Page 106
1 you're reserving your rights and we"e reserved
2
our rights
.
3
MR . MUELLER : We're telling you it may
I he a nonissue . In the event that it is an issue.
N ou know
. We may have a few more questions as to
those matters only .
MR . WEN EWORTH : And I again appreciate
the accommodation of moving this one up and
switching the Bucklars and all that .
MR . MUELLER
: Fair enough .
6
7
8
a
10
11 Q What about the Sierra Club? Who was the
11
12 treasurer that handled funds that Sierra Club might 12
(Further deponent saith not .)
1 3 have spent?
1 3
14
A That would he Grace Messner . She's our
14
15 treasurer.
15
i o
MR
. MLLLl ER : I flank %on .
: c
17 Ms. Blumenshine . I hope that wasn't too
` 17
18 McCarthy istic .
18
19
MR . WEN - 1 WORTII : We'll reserve
19
20 signature
. While we're on the record, the subpoena
20
21 called lot Rider A I through 32 . We filed an
21
22 objection. I just wanted to at least on this
22
23 transcript that you guys had that when the
. 23
2 4 deposition started and w e went ahead and did the
24
Pages 103 to 106
PEOPIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
JOYCE BLUMENSHINE
10-23-2006
STATE
OE ILLINOIS .
SS
COUNTY-7 PEORIA
"aria N
. Gllftos, CSR, RPR, and Notary
PublicIllinois,
i.ndo and
hereby
for the
certify
Count}
`_hat
of Peoria,
heretofore,
State
tc-wit,of
on
before
Monday,
me at
October
4.16 Main
23rd,
Street,
2006,
Suite
personally
1400, Peoria,appeared
Illinois :
herein .
JOYCE B=IIMENSHINE, a
mater-a_
witness
by me first duly
further
sworn
certify
to testify
that the
to
said
the truth,
witness
thewas
whole
-rut__
and nothing but the truth in the cause
witness
aforesaidwas ; that
reported
the
st_enographicaltestimony
then
.ly
Given
by
by
me
saidis
the
typewriting,
presence of said
aria
witness
the foregoing
and afterwards
is a true
reduced
and correctto
transcript
as aforesaidof
.
the testimony so given by said witness
witness was
I
not
further
waivedcertify
.
that the signature of the
further certify that I am not counsel for
nor i- any way related to airy of the parties to this
suit, nor at I in any way -n -eresteh
thereof .
the outcome
hand and affixin
testimony
; my notarial
whereof,
seal on
I hereunto
this Tray,
set
^ridap,my
October
,
2006
.
Aana N . Giftos, Certified Shorthand Reporter
(State
My commission
of Illinois
expires
License
07/24/07#004-003571)
.
,)FFICIAL SEAL .
AANA M GIFTOS
NOTARY PUBLIC -
STATE OF ILLINOIS
MY COMMISSION EXPIRES
:07124107
Page 108
PEOPIA DISPOSAL COMPAIJY v . PEORIA COUTITY BOARD
PCB06-184
A
Aana 1 :11 108 :322
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98 :21 99
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77:7 83 :19
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3 :16 66 :7
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activities 47 :21
actual 11 :5 43 :21
actually 5 :24 23 :6
78:24 79:1 89:11
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adjourns 27:7
adopted
6 :20 .23
advice 37
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69:24 70 :4
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aforesaid 107 :9.11
108 :9,12
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83 :10 89:7 91 :11
59:7 60
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73 :23 103 :23
104 :9
agenda 85 :1 .4
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agree 25 :5 26 :1
88:9
89 :19
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82:23
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41 :15 44:6 103:14
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always 25
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108 :4
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42 :7 56 :7
25:12 41 :12 64:23
65 :2 85 :20
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40:24 75 :20 84 :23
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65 :18 69 :23 70 :6
79 :12
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12 :23
28 :7.8
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101 :8,17
attempted 101 :10
101 :12
attend 25 :17 90 :23
100 :12 .16
attended
44
:18
53:2 75:2 102:12
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
JOYCE BLUMENSHINE
10-23-2006
Paqe 109
63 :19
April 51 :4 54 :15
anyone 21 :5 34
:13
60:16,20 68 :10
35 :14 42 :18 49 :4
91 :11
49 :16 51 :23 60 :9
aquifer 8 :1,5 23 :15
61 :6.7 68:20
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70:10 71 :1
53
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65 :9
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82 :20 .22 83
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89:2 90 :9.12
61 :4 80:23 86:22
92:19 96:3 98:17
97 :24 102 :24
area
69 :16 87 :16
105 :21
96
:19 99
:15
anyway 72:8 73 :8 areas 7 :20 87 :14
anywhere 15 :3
arm 10:22
63 :7
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69:11 70 :10 80 :22
46 :15
87:15
appeal 75 :17 77 :3 article 13 :12 22 :20
79:17 .19 81 :12
23 :2 33 :1523
appear 63
:14 83 :9
35 :2 36 :15 76 :11
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1 :15 2 :1
articles 14 :2 23 :15
acceptable
105
:3
accessible
63 :19
afterwards 108 :10
again 41 :4 42 :4,11
accommodation
58 :24 63 :9 72 :3
106 :8
73 :4 76 :9 78 :20
account 74 :11 .11
81 :15 82 :5,11,13
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103 :3 .17 106 :7
accountable 81
:6 .7
107 :10
accumulation
48 :23
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:11,21
17
:8,13 18 :4
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19:12 21 :9 24 :9
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32:7 48:12 76:5
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:18
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applicable
application
35 :22
3 :11
8 :8
12 :11
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42 :3 50 :20 28:4.10 29 :8
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97 :15
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95 :12
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16:5
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4 :17.18
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86:11
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102
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51
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26:16
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37:20
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59
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42 :5
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6 :12
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9:14 .19 .21
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13 :8
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1 :9
2 :4.12 .15 .16.17
2 :18 .19 .20.21 .22
3 :1,8 .10 .16 4 :17
15:10 21 :17 22 : 24
26 :182821 33 :4
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95 :8
JOYCE
BLUMENSHINE
10-23-2006
Page 110
Boulevard 4 :19
Brad 44 :16 97 :8
98
:2-i
break 16:20 30 :24
74:2 86:21
92 :22
Brian 1 :18 49:15
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Brown 1 :22 .22
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97:8
Bucklars 106 :9
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76 :1
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84
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:18 42 :10
82 :14
came 29 :10 46 :23
50:19 76 :7 84 :14
95 :6
campaign 39 :7
49 :6
Canal 37:6
capacity 5 :5
PEORIA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
29:7 31 :12 46 :2.4
107:1 .20 108
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46 :8 49
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58:1 60:23 61 :1 .7 behalf 1
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23 :22
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31 :8.16
55 :15
56:7
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compensated 59 :14
complained 68 :11
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10-23-2006
Paqe 111
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23 :17,23 24 :4,4
PEORTA DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
JOYCE BLUMENSHINE
10-23-2006
Paae
wanting 48:1 50 :16 21 :23 26 :5 27 :4
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PEORIA DISPOSAL COMPANY V .
PEORIA COUNTY BOARD
PCB06-184
JOYCE BLUMENSHINE
10-23-2006
Page 125
words 4:13
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JOYCE BLUMENSHINE
10-23-2006
Page 126
PEOP.IA. DISPOSAL COMPANY v . PEORIA COUNTY BOARD
PCB06-184
382 :16 .1746 :12 .15
39 2:18 55:6.9
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Exhibit 18
10/25/06 Tessie Bucklar
Condenselt T1"
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v . PCB
Page 1 - Page 4
Page 3
INDEX
Tessie Buckler
10/25/06
BEFORE THE ILLINOIS POLLUTION
CONTROL BOARD
PEORIA DISPOSAL COMPANY,
Petitioner,
ORIGINAL
I
No . PC5 06-184
3
3
WITNESS :
Page
TESSIE BUCKLAR
Examination by Mr . Moeller 4
6
EXHIBITS :
7
EXHIBIT 70
.
.22
a
3/29/06 a d s b
'urn, E-mail'
to Phelen
9
EXHIBIT 7
,
.33
E-mall and Attachments
10
EXHIBIT 72
34
E-mails
EXHIBIT 73,
I1
E-mails
13
'LUR :A _'OL' .CT7 bOA0.J,
EXHIBIT 1E
43
OOO[-[o-1700[ A[eas Covered
EXHIBIT 75
46
E-mails
ResPOnden[ .
1
EXHIBIT 76
46
E-mails
THE DEPOSITION of TESSIE BUCK LAR, a witness
EXHIBIT 77
46
beret,, called for examination pursuant to notice and
E-mails
.Is Court Ruses as they pertain to the taking of
C
An,O :a X . Jones . 050., RPR, an0 a
n1 I'I the County of Tanewell, State
DISK
ENCLOSED
Ir
on Wednesday, October 25, 2006, at 416 Main
Street, Bull . 1400, Peoria, Illinois, commencing at the
hour of 2-,20 p.m .
24
NOTE : Exhibits retained by Petitioner's Counsel .
APPEARANCES
Pass 2
'.
Page 4
ESQUIRE
204
a . Illm oors 61350
and
JANAKI NAIR, ESQUIRE
BRIAN J . MEGINNES, ESQUIRE
Elias, Megtnnes, Riffle L Segherri, P .C .
416 Main Street, Suite 1400
Peoria, Illinois
61602
Ue Fet.a .I cf the Petitoner,
7AVTC A . HRONN, ESQUIRE
Brace, blank 6 brown
10 : South Marc Street
Morton, Illinois 61550
On Behalf Of the Respondent ;
DAVID L . WENTWORTH 11, ES Q UIRE
HasselOerg, Williams, Grebe,
Bnodgraso I Birdsall
v4 :: Ur.bweot Adams Street . Suite 360
,~-w a, :a :nols 61602
a,
HAL SCHLICKSUP, ESQUIRE
411 Hamilton Boulevard, Suite 1720
Peoria . Illinois 61602
19
On Behalf of Tessie Bucklar ;
ALSr7 PRESENT :
ROYAL CCOULTER, PDC
JEFF COULTER, PDC
MATT COULTER, PUT
1
(Witness sworn .)
2
TESSIE BUCKLAR,
3 called as a witness, after being first duly sworn, was
4 examined and testified upon her oath as follows :
5
EXAMINATION
6
BY MR. MUELLER :
7
Q
Can you state your full name, please?
8
A Tessie Bucklar .
9
MR. MUELLER : And let the record show :
10 This is the discovery deposition of Tessie Bucklar taken
I I
pursuant to subpoena, in accordance with rules, and
12
scheduled by agreement of the parties.
13
Q I apologize for being late for the start of
14 this, You are here with Counsel today, Miss Bucklar?
15
A Yes, I am .
16
Q And that would be Mr . Schlicksup or
17 Mr. Wentworth?
18
A Both
19
Q Okay. Let me go through a little bit of
20 background information with you
. What is your address?
21
A
5045 North Bellevue Place, Peoria Heights,
22
Illinois
.
23
Q And what is your phone number?
24
A 685-0878 .
10/25/06 Tessie Bucklar
Condenselt'`''
Page 5
1
Q How long have you lived at your current
2 address?
3
A Since 1998.
4
Q Who resides there with you?
5
A My husband, Tom Bucklar, and our three
6 children .
7
Q Do you have a cell phone?
8
A Yes, I do .
9
Q What is that telephone number?
10
A
256-6447 .
11
Q Do you have an e-mail address that you use
12 regularly?
13
A Yes, I do .
14
Q What is that?
15
A It's Bucklar, which is B-u-c-k-l-a-r, at
16 sbcglobal .net
.
17
Q Miss Bucklar, are you related to Kim
18 Converse?
19
A Not technically .
20
Q Well, there's apparently some degree of
21 relation . If you could enlighten us?
22
A
She is my sister-in-law's sister-in-law .
23 So I don't know if that technically makes us related or
24 not.
Page 6
I
Q Are you employed, ma'am?
2
A No, I'm not.
3
Q When is the last time you were employed
4 outside the home?
5
A November of 2001 .
6
Q And what was your profession at that
7 time?
8
A Graphic designer.
9
Q Working for whom?
io
A Converse Marketing .
I I
Q And how long did you work for Converse
12 Marketing?
13
A From June of 1998 to November of 2001 .
14
Q Did you ever do any work for Peoria
15 Disposal Company while you worked for Converse
16 Marketing'?
17
A I don't recall any specific work
. I do
18 recall being in a meeting once with Chris Coulter . It's
19 possible I may have done something. I was not the lead
20 designer on the project, though .
21
Q What was your reason for leaving that
22 employment?
23
A
Having my second child.
24
Q Have you worked part time since 2001
Page 7
outside the home?
A
No.
•
You don't do any consulting or special
projects?
A
No.
•
Do you have any remaining affiliation with
Converse Marketing?
A No.
•
To your
knowledge, has Converse Marketing
contributed any expertise, work, or services to the
opposition campaign to the PDC landfill expansion?
MR. SCHLICKSUP : Excuse me just a second .
(Pause in proceedings
.)
A I'm sorry
. Can you just repeat that?
•
To your knowledge, has Converse Marketing
contributed any work, expertise, or services to the
opposition campaign to the PDC landfill expansion?
A No, not to my knowledge
.
•
What is your educational background?
A I have a BFA in visual communications from
Northern Illinois University and a minor in French
.
•
Are you a member of Peoria Families Against
Toxic Waste?
A Yes, I am .
Page 8
•
Who formed that organization?
A I would -- Kim Converse was a founding
member. I don't know other than that .
•
What's your understanding of how the
organization is structured? Are you a corporation?
A No. It's not incorporated
.
•
Do you have officers?
A
No.
•
Do you have an executive or a steering
committee?
A No.
•
Do you have any leadership role in that
organization?
A
No.
•
Have you ever had a leadership role in that
organization?
A
No.
•
Does Peoria Families have regular meetings?
A I wouldn't call them regular. They don't
happen in a certain time frame
.
•
Do you know if they have a membership list?
A No
. I don't believe so.
•
Did you provide any work, skill, or
expertise to the efforts of Peoria Families?
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v . PCB
Page 5 - Page
8
10/25/06 Tessie Bucklar
Condenselt rT''
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v . PCB
Page 9 - Page 12
I
2
3
4
6
7
8
9
10
i i
12
13
14
15
16
17
I s
19
20
21
22
23
24
Page 9
A Yes .
Q What was the nature of the expertise that
1
2
3
4
5
6
7
8
9
10
1 I
12
13
14
15
16
17
18
19
20
21
22
23
24
Q
Page 11
To your knowledge, is Joyce Blumenshine a
member of the Peoria Families Against Toxic Waste?
you provided?
A
Q
Yes .
A Mainly I designed some yard signs . I
When you designed the small flier which was
designed the handout . I would say that would be the
expertise that I provided .
handed out at various places, who did your fact checking
for you?
Q The handout was a small flier that was
handed out at the St . Patrick's Day parade?
A There were lots of --
MR. WENTWORTH : 64 .
A Yes .
MR . MUELLER : Exhibit 64 . Thank you,
Q Were you responsible for the editorial
content of that handout, or did you simply graphically
design it once someone gave you the written material?
Mr . Wentworth .
A There were lots of people who did checking
on that .
A
Q Can you identify the people that did the
Q
I compiled it from various sources .
Have you had any involvement in designing,
fact checking?
maintaining, or changing the Peoria Families website
which I believe is n otoxicwaste .org ?
A I know Joyce Blumenshine did, Kim Converse .
I mean, I showed it to the entire group and then
A
received suggestions, corrections from the entire group .
Q
No . I have not.
Do you know where the fliers that you
Q Let's refer to the time period November
designed were printed?
A Brown Printing .
Q Do you know where the yard signs that you
9th, 2005, through January -- or through -- excuse me --
May 3rd, 2006, as the application time . During that
period, did you have any telephone conversations with
any County Board members?
A Yes, I did.
Q Which County Board members did you have
designed were printed?
A It's either like Fast Signs or Signs Now .
1 always get those two confused
.
Page 10
Page 12
1
Q Were any materials that were distributed by
1 conversations with?
2 Peoria Families designed or printed at Converse
2
A
Mike Phelan, Jeffrey Joyce, and Tim
3
Marketing?
3 Riggenbach .
4
A
No
. I don't believe so .
4
Q Let's talk about Mike Phelan first . How
5
Q Were you involved in the design of
5 many conversations did you have with him?
6 billboards?
6
A I think just two .
7
A No . I was not .
7
Q And who initiated them?
8
Q Do you have any special knowledge or
8
A I called him . He never had a voicemail,
9
expertise preexisting the start of your involvement in
9 and then he called me back . He must have had a caller
10
Peoria Families regarding hazardous waste?
10 ID, I assume .
I I
A No . I do not .
I 1
Q Do you remember the time frame of that call
12
Q Do you have any special knowledge or
12 and call-back?
13 expertise preexisting your involvement in Peoria
13
A Early March or early to mid March .
14 Families regarding lead, asbestos, or heavy metals?
14
Q Those are both conversations, your call to
15
A No . I do not .
15 him and then his call back to you, or did you actually
16
Q Do you have any personal or family
16 have two conversations with him?
17
experience with hazardous waste disposal or management,
17
A I had two conversations with him .
18
heavy metals, lead or asbestos?
18
Q All right . So the first one was initiated
19
A No . I do not .
I9 by you calling him, and he called you back, correct?
20
Q
Are you a member of the Sierra Club?
20
A Yes . I believe so.
21
A No . I am not .
21
Q And can you tell me what was said by you
22
Q Are you a member of Citizens For Our
22 and him in that conversation?
23
Environment?
23
A That was -- he's my County Board
24
A No, I'm not .
24 representative
. I explained to him my views of the
10/25/06 Tessie Bucklar
Condenseltr"
Page 13
1 expansion at the time, and he explained that he was not
2 providing any -- was going to talk about his views of it
3 until after all the evidence was in at the public
4 hearing and pretty general conversation .
5
Q You say you explained your views, meaning
6 your opposition?
7
A
Yes .
H
Q Did you identify yourself as a member of
9 the Peoria Families group?
10
A I don't believe I did, but that was a long
I 1 time ago . I can't be 100 percent sure .
12
Q Did you urge him to vote no on the
13 application?
14
A I don't believe that I did .
15
Q But you told him that you were opposed to
16
it?
17
A Yes, I did .
18
Q When was the second time you had a phone
19 conversation with Mr . Phelan?
20
A I think it was between -- it was before the
21 vote on April 6th .
22
Q And who initiated that conversation?
23
A I think I had sent him e-mails, and he must
24 have responded .
Page 15
1
Q When was the beginning for you, by the way?
2
A Early February, probably several weeks
3 before the public hearing .
4
Q
So you came onboard fairly late in the
5 process compared to some other people?
6
A Yes . I would say so.
7
Q
By the way, let me digress for a moment .
8 What was it about this application that caused you to
9 decide to get onboard as an opponent?
10
A Initially?
11
Q Yes .
12
A You're talking about like my first
13 inclination?
14
Q Right .
15
A Was really my shock that there was a
16 facility like this in Peoria . Having grown up in Peoria
17 and lived most of my life here, I was very, very
18 surprised that I had never heard about it and was
19 concerned that it was located right outside of the city .
20
Q It never occurred to you that if you lived
21 here your whole life, never heard about it, that might
22 be because they were running things in a very
23 business-like and quiet manner that didn't create any
24 problems?
Page 16
MR . SCHLICKSUP : I'm going to object . Are
you making a statement and testifying, or are you asking
a question?
MR . MUELLER : I'm asking a question .
MR . SCHLICKSUP : okay. Ask the question
again .
BY MR
. MUELLER
:
Q Did it ever occur to you that maybe the
reason you didn't know about it was because they were
running the operation in a very business-like and
non-problematic manner?
A No .
MR . SCHLICKSUP : I'm going to object .
You're assuming that she knows how they operate their
business .
MR . MUELLER : I'm not assuming anything .
I'm asking a question . Are you instructing her not to
answer?
MR
. SCHLICKSUP : Well, do you understand
the question?
THE WITNESS : I believe I do.
MR . SCHLICKSUP : You can answer it as best
you can .
A
Then no, that never occurred to me
.
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Page
13 - Page 16
Page 14
I
Q What was the gist of that conversation?
1
2
A I actually do not recall that conversation
2
3 as well . I think it probably had to do with the county
3
4
stall report coming out prior to the close of public
4
5 comment, but I don't recall the specifics of that
5
6 conversation .
6
7
Q Prior to your initiating the first phone
7
8 call to Mr . Phelan, what was your understanding of the
8
9
procedures that applied to the application and
9
10 decision-making process?
10
I I
12
A I'm not sure that I fully understand that
I I
question . Can you help me out with that?
12
13
Q Let me rephrase it .
13
14
Did you at some point after November 9th,
14
15 2005, gain an understanding of how the County Board's
15
16 decision on the expansion application was to be made?
16
17
A Yes .
17
18
Q What was the understanding that you gained?
18
19
A Later my understanding was that their
19
20 decision was --
20
21
Q
Let's talk about at the beginning .
21
22
A At the beginning? At the beginning, I was
22
23 lust trying to come up to speed . So there was a lot of
23
24 confusion at the beginning .
24
10/25/06 Tessic Bucklar
Condenseltn"
Page 19
There were filings by parties involved that didn't
happen at the public hearing, so it was not my
understanding that the public hearing was the record
.
Q
So your understanding is everything that
would have been filed would have been part of that
record and all of that was to be considered by the
County Board?
A That was my understanding .
Q Did you have an understanding as to whether
or not the County Board was to consider the opinion or
opinions of its constituents in reaching its decision?
A I gained that understanding at some point
.
In the beginning, I was struggling trying to find
answers to that question .
Q
When did you gain that understanding, and
what understanding is it that you gained?
A It's difficult for me to say when . It was
probably sometime in March . My understanding was that
they would be basing the decisions on fact and evidence
.
Q And did you understand that to mean that
your contacting County Board members to express your
opinion if you knew that they weren't to take that into
consideration?
A I still felt that the public opinion was an
important part of the process, that we were being
encouraged by the county to be part of the process, to
attend the public hearings . I thought it was important
that the County Board members understood the gravity of
the decision and how the community felt about that and
that this was very important and this was not a decision
to be taken lightly .
Q Would it be fair to say that you disagreed
with the understanding you gained in March that public
opinion was not to be considered by County Board members
in making their decision?
MR. wENTwoRrlt : I
object
. That's not -- 1
don't even know where that question came from based on
her prior answer . I mean, you're testifying here more
than --
MR. MUELLER : I'm asking if it would be
fair to say that .
A Can you repeat that then?
MR. MUELLER : Mr. Wentworth, can we try to
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page
17 -
Page 20
Page 17
1
Q Fair enough . So you get onboard in early
1
2 February ; and as you say, you were trying to get up to
2
3 speed?
3
4
A Uh-huh
4
5
Q At that time, what was your initial
5
6
understanding of how the decision-making process was
6
7 going to work?
7
8
A At that time, I did not fully understand
8
9
it.
9
10
Q
When did you gain an understanding of how
10
I I the process was going to work?
12
A Of how the process was going to work'?
I I
12
13
Q
The decision-making process .
13
14
A Probably after the public hearings .
14
15
Q The public hearings, referring to the five
15
16 days in late February, correct?
16
17
A Yes
. I can't he entirely sure when my
17
I8
understanding of that process took place .
18
19
Q Well, we've got some e-mails from you in
19
20 late March, and at the time that --
let's back up a
20
21 second.
21
22
At the time that you called Mr . Phelan, the
22
23
first time, what was your understanding then of how the
23
24
decision-making process was going to work?
24
Page 18
I
A I don't think I had a full understanding of
1
2 it. I mean, I really didn't .
2
3
Q Did you have an understanding as to whether 3
4 or not any rules applied to you in the process?
4
5
A No.
5
6
Q You did attend the public hearings,
6
7
correct?
7
8
A Portions of it, yes .
8
9
Q Were you there on the first day of the
9
to public hearing in February?
10
I I
A No. I was not .
12
Q Did you at any time gain an understanding
I I
12
13 that the decision of the County Board was to be based 13
14 solely on the evidence introduced at the public hearing? 14
15
A Yes, evidence that was in the record .
15
16
Q
How do you distinguish evidence introduced
16
17 at the public hearing from evidence that was in the
17
is record?
18
19
A You're asking me that?
19
20
Q Yes, because I asked you about the public
20
21 hearing and your answer was about evidence in the
21
22 record. In your mind, is there a distinction?
22
23
A Well, yes. There were things in the public
23
24 comment file that didn't happen at the public hearing . 24
they were not to consider public opinion?
A In making their decision?
Q Yes.
A
Yes
.
Page 20
Q That being the case, what was the point of
10/25/06 Tessie Bucklar
Condenselt'T''
Page 21
1 limit speaking objections and just make them based upon
2
evidentiary rules? Otherwise, I think a suspicious
3
person like me gets the sense that perhaps there's some
4
coaching going on .
5
MR . WENTWORTH : well, for the record,
6 Mr . Mueller, I believe that is the first objection that
7 1 have made that could even possibly be classified as a
8 speaking objection, and I don't believe that that one
9 was ; but I'll take your point, and we can move on
.
10
MR . MUELLER. Thank you
. Let me reask it
II since we digressed here .
12 BY MR . MUELLER
13
Q
Would it be, first of all, fair to say that
14
you understood by sometime in March that public opinion
15
was not to be considered by the County Board in making
16 their decision?
17
A Yes .
18
Q
And would it also be fair to say that you
19
disagreed with that rule?
20
A No, that's not fair to say .
21
Q
You did agree with that rule?
22
A I did not understand -- I did not
23
necessarily understand that . I did not -- but I
24
understood that those were the rules .
Page 22
1
Q
Let me show you what's going to he marked
2 as Exhibit 70
. Janaki will number it .
3
MS
. NAIR : if we can go off the record for
4 just a minute .
5
(Discussion off the record .)
6 BY MR . MUELLER.
7
Q I lave you had a chance, Miss Bucklar, to
8
review Exhibit 707
9
A Yes, I have .
10
Q Is this a true and correct copy of an
I I e-mail sent from you to Board Member Phelan on
12 March 29th?
13
A It appears to be . Yes .
14
Q And, first of all, it makes reference to
I S multiple prior e-mails?
16
A Uh-huh .
17
Q
How many prior e-mails had you sent to
18
Board Member Phelan?
19
A Prior to what?
20
Q Prior to this one on March 29th .
21
A Well, I believe they're included with this
22 one.
23
Q Well, let's see
. It says, "My original
24 e-mail was dated March 13th," and I'm not seeing a March
Page 23
1 13th --
oh, there it is on the second page . So there
2 were two prior ones
; is that correct?
3
A It appears to be .
4
Q One on March 13th and one on March 26th .
5
What was the purpose of sending these three a-mails to
6 Board Member Phelan?
7
A I was trying to determine what the quality
8 of life meant regarding a decision-making process .
9
Q Why were you contacting Board Member Phelan
10 as opposed to other board members?
I I
A Because he's my representative . I live in
12 his district .
13
Q Was he at the time running for re-election?
14
A I don't honestly know
.
15
Q If I can direct you to the March 29th
16 e-mail, you make a statement, "It appears there was no
17 consideration given to the massive amount of public
18 opposition that has been expressed in many forums
19 regarding this landfill expansion ." You wrote that
20 statement, correct?
21
22
23
24
I
2 referencing the county staff report, that they did not
3 make reference to that .
4
Q And if you could read the next paragraph
--
5 you don't need to read it out loud, but just tell me
6 what you meant by the portion of that last paragraph
7
that says, "Will not be taken into consideration by the
8
County Board based on the instructions that you were
9 given at your last meeting ."
10
A You want me to tell you what I mean by
11 that?
12
Q Yeah, what you meant by that statement .
13
A Well, I think it's pretty clear the way
14 I've stated it . I was trying to find out -- this is
15 when I was grasping with, you know, what was going to be
16 considered when they made their decision .
17
Q And would it be true that you wanted him,
18
as you were writing this, to take the fact of public
19
opposition into consideration in making his decision?
20
A No. That's not true .
21
Q Would it be true that you wanted him at the
22 time that you wrote this to consider public opinion
23 together with all the other material in the record?
24
A I wanted to find out what was going to be
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v- PCB
Page 21 - Page 24
A Hang on a second . I'm trying --
Q End of the first paragraph .
A Oh, okay . Yes .
Q What did you mean by that statement?
Page 24
A Hang on a second . I think I was
10/25/06 Tessic Bucklar
Condenseltr''i
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v . PCB
Page 25 - Page 28
I
Page 25
considered.
l
Page 27
Is that a true statement?"
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9
Itl
1 i
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1 S
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Q Well, let's go to the fourth paragraph .
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A Well, first of all, I'm not sure we're
talking about -- do you know what meeting I'm talking
about there? I'm not talking about the meeting that was
the whole County Board on this issue .
Q Then let me ask you: What meeting are you
talking about in that second paragraph?
A It was a televised meeting.
Q And what instructions are you making
reference to that were given at that meeting?
A Their instructions that, as I believe I
describe in my March 13th e-mail, instructions that my
husband saw on iv regarding -- that were given to the
board members . I did not see them, and I stated that
.
I did not see the televised meeting
.
Q
And I, in fact, am looking at the March
13th e-mail, That would be the instructions in which
your husband stated that a gentleman told the board that
their decision needed to be based only on the facts and
the nine criteria from the IEPA; is that correct?
A That's what we're talking about .
Q So you were disappointed that the County
Board needed to base their decision only on the facts
and the nine criteria?
You see where you wrote, starting in the middle of that
paragraph, "The citizens of Peoria County have a right
to hear whether or not their elected officials will
consider their voice in this most important decision"?
You wrote that?
A Yes .
Q What did you mean by that statement?
A
I meant that I wanted to know whether or
not they were going to be considering that in their
decision-making .
Q Did you ever get an answer from Mr
. Phelan
as to whether or not he would be considering the voice
of the public?
A I don't believe I did
. No .
Q
And would it be a fair statement that at
the time you wrote this e-mail you wanted the voice of
the public to be considered?
A No .
statement.
I don't believe that's a fair
Q
Would it be fair that you didn't want the
voice of the public to be considered?
A
I don't think I was trying to -- I didn't
Page 26
Page 28
1
have an opinion either way . I was trying to determine
1
A Well, I wanted to make sure that it was
2
if it was, and nobody was answering that question .
2 important that the County Board was considering the
3
Q Well, your reference to "the instructions
3 community feelings about this, particularly given light
4
given at the last meeting" would suggest that the
4 that if you look at the public comment file early on,
5
question had, in fact, been answered in a way that you
S there was an awful lot of things submitted to that
6
were disappointed with .
6 public comment file, form letters from Pnc business
7
A I'm sorry . I didn't understand that
7
associates . My concern was that I didn't want the
8 question .
8 County Board members to look at this and think that it
9
Q Go hack to the second paragraph of this
9 was a one-sided issue, that everybody thought this was a
IC e-mail . You make reference in the last line to the
10
great issue . I thought that it was important that they
I I instructions that were given at the last meeting . Do
11 were taking into consideration this was -- there were
12 you see that?
12 two sides to this story and there were as many people,
13
A Uh-huh .
13
if not a great deal more, that were concerned about the
14
Q So it would appear that the answer to what
14 expansion .
15 could he considered was already given to the board and
15
Q Now, did you understand that there was a
16 that you were disappointed in that answer
. Is that a
16 cutoff period for public comments?
17 true statement?
17
A To be included in the record, yes .
18
A Could you ask that again? I'm not exactly
18
Q
Yes. However, you continued to communicate
19
sure what you're asking .
19 with Mr . Phelan about the case even after that cutoff
20
MR . MUELLER'.
If the court reporter could
20 period?
21 read that back .
21
A It was not my understanding that we could
22
THE REPORTER :
"so it would appear that the
22 not communicate with board members .
23 answer to what could be considered was already given to
23
Q Then what was your understanding as to what
24 the hoard and that you were disappointed in that answer .
24 that public comment cutoff period applied to?
10/25/06 Tessic Bucklar
Condenselt'
Page 29
A It was the cutoff for individuals to
include comments in the public record .
•
But you could continue -- your
understanding was you could continue to communicate
privately with board members about your opinions even
beyond that cutoff period?
A
I understood it was okay to communicate to
the board members as long as you were talking about
things that were -- referencing things that were in the
record .
•
And who did you get that understanding
from?
A I
believe it was discussed at one of our
meetings, probably from Kim Converse.
•
That being the case, how many different
board members did you send e-mails to?
17
A I sent an e-mail to all members of the
IS
hoard, all 18 .
19
Q It would have been the same for all 18 of
20 them?
21
A The same e-mail?
22
Q Yes .
23
A
Yes .
24
Q
flow many board members did you have
Page 30
i
individualized e-mail communication with such as the
2
ones we've just been discussing regarding Mr . Phelan?
3
A
Mike Phelan and Jeffrey Joyce.
4
Q All right
. You also mentioned that you've
5
had telephone conversations with Jeffrey Joyce?
6
A
Uh-huh .
7
Q
What was your purpose in selecting him for
8 individualized communication?
9
A
I had heard that at the April 3rd meeting
10
that he had had questions about the coal mine issue that
1 I was brought up and that weren't really answered by
12 county staff . So I contacted him to see if it would be
13 okay for me to send him an e-mail directing him to the
14 coal mine information that was in the public record
.
15
Q And what did Mr
. Joyce have to say in the
16 telephone conversation?
17
A It was a very brief phone conversation . I
18 basically introduced myself, told him that I heard he
19 had questions, offered to send him an e-mail regarding
20
where the information was, and that was --
21
Q Did he accept or decline your offer?
22
A He accepted . He said that would be fine
.
23
Q Did you also at that time express your
24 opinion of the application?
Page 31
A No . I did not .
•
You also indicated you had telephone
communication with Mr . Riggenbach?
A Yes, I did .
•
Who initiated that?
A
It was in regards to an e-mail I had sent
the entire County Board. He contacted me
.
•
When did that occur?
A It was on the day of the final vote
.
•
What was the nature of the telephone
conversation?
A
We were discussing the Perpetual Care Fund
as proposed by
PDC
and their filing that was like the
response to the committee as a whole vote .
•
Did you indicate your opinion at that time?
A I indicated how I felt about that proposed
Perpetual Care Fund.
•
Did you ever hear from anyone that you were
not to contact board members outside of the hearing
process and outside of the public comment process?
A My understanding was that it was okay to
contact County Board members as long as you were not
introducing anything new or you were referencing the
record .
Page 32
•
Well, did you ever think that by pointing a
County Board member in a private communication to some
specific portion of the record you might be unduly
emphasizing it and, thereby, gaining advantage over the
other side that was unaware of the communication?
A No.
•
What was your understanding, if any, as to
what rules applied to PDC
regarding contacts with board
members outside the record?
A Could you rephrase that, please? I'm
sorry . Or just repeat it, please .
•
What was your understanding, if any,
regarding what rules applied to Poc's contacts with
board members outside of the hearing process?
A I assumed that they would be the same, that
they should only point to things that are in the record .
•
But it was your understanding that PDc was
also free to call up board members and express opinions
and the like?
A
Yes, and I had heard that they had been
doing that .
•
Well, we keep hearing about that, so
perhaps you can tell us the specifics that you had heard
regarding PDC
representative contacts with board
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page 29 - Page 32
B ar
CondenseItm
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v, PCB
Page 33 - Page 36
Page 33
Page 35
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I 1
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members .
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MR. WENTWORTH
: can we go off the record
just for a second?
MR
. MUELLER : Yes .
(Discussion off the record .)
THE WITNESS : Just this document, this is
not the whole e-mail here
. You know, this one contains
the entire e-mail
. This just contains the last line of
the May 2nd e-mail, just so you know .
MR. WENTWORTH : For the record --
BY MR . MUELLER :
Q The last line being the line that says,
"Another concern is the escrow account fund"?
A Yes .
MR. wENTWORTH
: so we're talking about 72
and 71 looking like the same thing but 72 not containing
the Pis
editorial board and the second paragraph of
what's in 71 .
Q 72, however, also contains a copy of what
appears to be a spreadsheet?
A Yes .
Q And is this the exact spreadsheet that was
prepared by the staff or by PDC, or is this a
spreadsheet that was prepared by you and your husband?
A
It was the county staff's spreadsheet with
A
I don't remember anything specifically
. 1
just remember hearing rumors to that effect
.
Q Can you remember a single specific contact
of a PDC representative with a board member that you had
heard about?
A
No
. I don't have a specific instance . No .
Q
Let me show you what's been marked as
Exhibit 71, and your Counsels can look at it with you .
(Pause in proceedings.)
Q Did you send this e-mail and its
attachments to all of the County Board members?
A Yes, I did .
MR . WENTWORTH : There's more than one
e-mail, I think you're referring to the one on the
first page . A lot of these have the e-mail strings in
them, for the sake of the record.
MR. MUELLER. Right.
BY MR. MUELLER :
Q Did you send the e-mail
and the string,
which I guess in this case is only two e-mails, to all
of the board members'?
A The one on the top, yes, was sent to all
board members .
Page 34
Page 36
1
Q Was the second one addressed from Tessie
I the new numbers that were proposed by -- well, excuse
2 and Tom Bucklar to Elaine forwarded to the other board
2 me . There were two documents attached . The first one
3 members'?
3 was the original county staff spreadsheet from their
4
A Yes .
4 report, I believe. The second is basically the same
5
Q And that would be Elaine who?
5 spreadsheet with the numbers that were presented by
PDC
6
A
Oh, Elaine Hopkins at the --
6
and their document that included those numbers .
7
Q The newspaper person?
7
Q I mean, did you run any numbers here that
8
A Yes .
8 had not previously appeared anywhere?
9
Q
Would you agree with my characterization of
9
A
The numbers come from the response to the
10 the content of these two e-mails as an analysis of the
10 committee as a whole vote from
PDC and the original
I I Perpetual Care Fund proposal?
11
assumptions of county staff that were included in their
12
A
Yes, analysis of the fund that was filed by
12 report
.
13
PDC and that response to the committee vote document .
13
Q
Now you've gotten me lost . You're saying
14
Q Who prepared the content of both of these
14 you just attached a document that had been created by
15
c-mails?
15 somebody else, or did you create the spreadsheet?
16
A
You mean who wrote the e-mails?
16
A There's two, there's two spreadsheets .
17
Q Yeah
. Did you or your husband?
17
Q Actually, I'm seeing more than that, so
18
A I did .
18 let's try to break it down
. I see one that starts with
19
Q
Who performed the analysis?
19 something called Annual Costs?
20
A Well, we both did . He --
we had the county
20
MR. WENTWORTH : Can we go off the record
21 stall Excel spreadsheet, and we just simply entered in
21 just for a second to clarify this? Because I don't have
22 the numbers that PDC had submitted in that document
.
22 a lot of time .
23
Q And then I need to show you what's been
23
MR. MUELLER : Okay.
24 marked as Exhibit 72 .
24
(Discussion off the record.)
10/25/06 Tessie Bucklar
Condenseltr*'
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PDC v. PCB
Page 37 - Page 40
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23
24
MR . MUELLER : Mr
. Wentworth has kindly
Page 37
I
2
3
4
5
6
7
8
9
10
I I
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 39
information that I believed at the time to be in the
record .
Q
You did some analysis and massaging of
other information to create the second spreadsheet?
MR . SCHLICKSUP : I'll object to
characterizing it as massaging . She's already explained
it. If you want her to explain it further, she can, but
don't characterize it the way you want
.
MR . MUELLER
: she can answer it yes or no
.
A What I did was I entered information
regarding Perpetual Care Fund that was provided by PDC
into the county staff spreadsheet .
Q And re-ran it with those numbers?
A I don't know what you mean by re-ranning,
re-running or re-ran it
.
Q You changed the data in the county's
spreadsheet?
A Yes . I entered the data that PDC provided
in the response to the committee as a whole document .
Q
The reason I'm spending some time on this
is because you previously had said you thought it was
okay to contact County Board members privately as long
as all you were talking about were things already in the
record?
explained to us that the attachment here is two separate
spreadsheets each consisting of four pages
.
MR. wENtwoRTH . sheets .
MR. MUELLER : sheets. You can tell how
much I understand Excel.
BY MR . MUELLER
.
Q
Am I correct then that the first
spreadsheet is a duplicate of something that was already
in the record?
A Yes . It is the county staff spreadsheet
for the Perpetual Care Fund that they included in their
report, county staff report .
Q The second spreadsheet, how does it differ
from the first?
A It is exactly the same except it includes
the Perpetual Care Fund numbers that PDC included in
their response to the committee as a whole vote
document .
Q
So that second spreadsheet was a document
created by you and your husband compiling information
from other sources?
A
Yes .
Q Did it re-run the analysis that the county
Page 38
Page 40
1 staff had done on the first set of numbers?
1
A Right . And I want to make it perfectly
2
A I'm sorry?
2 clear that at the time I thought that this document was
3
Q Did it re-run the analysis that's reflected
3
part of the record . It was a document that was filed by
4 by the county staff in the first spreadsheet?
4 PDC with the county. I thought that meant it was part
s
A I don't know what you're exactly saying by
5
of the record.
6
that .
6
Q Well, the second spreadsheet you knew was
7
Q How did you generate your numbers in the
7 not part of the record ; that was your creation?
8 second spreadsheet?
8
A
But all it was was information that was
9
A
Well, it was the way Excel works. I mean,
9 already being provided .
to it's all formulas
. The formulas were all there . We
10
Q So, when you say it was okay to contact
it
just put in the new numbers that were proposed by PDC, 11 County Board members regarding matters already in the
12 and then it generates them
. That's the way the
12 record, you also include in that to contact them with
13 spreadsheet's set up .
13 your analysis of things that were in the record?
14
Q Did you think that this was new information 14
A Well, I was never told I could not talk
15
that the County Board needed to have?
15
about my opinion of what was in the record
.
16
A At the time, I thought this was information
16
Q
And you were never told that you couldn't
17
that was pan of the record because it came from a
17
provide them with your analysis of what was in the
I8
document that was filed with the county by PDC and it 18 record ; is that true?
19
also contained the county staff information that was
19
MR. SCHLICKSUP : Do you understand -- I'm
20 also part of the record .
20
gonna object to your characterization of analysis,
21
Q In fact, though, the second spreadsheet was
21 Counsel. I think we have a misinterpretation of how
22 not something that was previously part of the record ; it 22 you're using analysis in this situation . She has told
23
was a document generated by you?
23 you she's put numbers into a spreadsheet and they ran
24
A
Yes
. But the content was all based off of
24 them. There's no analytical opinion attached to that .
10/25/06 Tessie Bucklar
CondenseIt
n"
Page 43
honestly, I think I printed almost all of them either
in-house or at Brown Printing . You will have to ask Ted
if he actually ended up doing some . We did discuss it,
but I don't think he ever did .
Q Fair enough .
MR . MUELLER; Let's take about five
minutes, and we're maybe very close to finished .
(Recess in proceedings from 3 :20 p .m .
to 3:25 p.m.)
BY MR . MUELLER ;
Q I'm going to try to go through some
exhibits very quickly here, Miss Bucklar, and we're just
authenticating documents .
The first one is going to be Exhibit 74,
and just ask you what this document is .
A It was a list of areas that were going to
be covered by door-to-door efforts .
Q When you say "door-to-door," meaning going
to the County Board members' homes or to residents in
those areas?
A To residents in those areas .
Q Why were the districts then identified by
board member?
A Well, I didn't create this document so --
Page 44
Q Who created it?
A I believe it was probably Julia Stone, but
I'm not 100 percent sure of that .
•
Who is Julia Stone?
A Who is Julia Stone?
•
Yes .
A She's a person
.
•
I mean --
A It's kind of a broad question .
MR . MEGINNES : You got him .
Q Mrs . Stone is someone whose identity was
unknown to us prior to these depositions, and we're
trying to figure out what connection she's had with it .
So, if you could tell us a little bit about her, what
you know about her, that would be useful .
A I don't know that much about her . She
spoke at the public hearing ; and she was, I think,
probably mostly involved with this door-to-door
campaign .
Q Are she and her husband residents of
Wisconsin now?
A Yes, I believe they are.
Q Are they retired individuals?
A No .
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page 41 - Page 44
Page 41
I
Q Let's back up a second . I think I've made
1
2 my point pretty much, and we'll leave it
.
2
3
The second spreadsheet sent to the County
3
4 Board members did not exist prior to your creating it
4
5 and sending it to County Board members, correct?
5
6
A The numbers existed . The actual
6
7
spreadsheet, no .
7
8
Q
No, the numbers did not exist?
8
9
A The raw data that was put in it existed .
9
10 Yes .
10
I I
Q The raw data from which the spreadsheet
I I
12 generated the numbers may have existed, but the numbers
12
13 did not, is that correct?
13
14
A Yes .
14
15
Q Let me show you what's going to be marked
15
16
as Exhibit 73, and I'd ask you to review this and just
16
17 tell me if it's an accurate reproduction of a string of
17
18
e-mails that were sent on the dates indicated .
18
19
(Pause in proceedings .)
19
20
A Okay . I'm sorry . I just reviewed it .
20
21 What was the question?
21
22
Q Is it a true and accurate copy of e-mails
22
23
that were sent?
23
24
A Yes . I believe so .
24
1
Page 42
Q And these are to Ted Converse -- let me
1
2 direct you to the last paragraph of the first e-mail
2
3 where it says, "Ted, let me know about having some
3
4 printed at Converse Marketing ."
4
5
A Okay .
5
6
Q What does that refer to?
6
7
A That was referring to the handouts .
7
8
Q And that would be an e-mail from Tom and
8
9 Tessie to Kim and Ted, correct?
9
10
A Well, it was -- yes, but it was me
. My
10
i i husband was not involved in the e-mail .
I I
12
Q
Did Ted Converse respond to that e-mail?
12
13
A That is his --
wait .
13
14
Q In fact, isn't his response, "I will get
14
15 some printed here and there, Tessie"?
15
16
A Yes . That appears to be the response .
16
17
Q You previously said you didn't think
17
18 Converse Marketing had printed any of the fliers?
18
19
A No, I didn't think they did .
19
20
Q In fact, does this refresh your
20
21
recollection that Converse Marketing did provide some 21
22 printing of fliers?
22
23
A It reflects that we were thinking of it
.
23
24 I'm not sure that he did . We had discussed it ; but,
24
10/25/06 Tessic Bucklar
Condenselt"
Page 45
1
Q Did you participate in going door-to-door?
2
A Yes, I did .
3
Q What district did you cover?
4
A Part of Phelan's district and part of
5 Widmer's district.
6
Q Did you hand out fliers when you went
7 door-to-door?
8
A
Yes
.
9
Q Those would be the same fliers that we
10
identified previously as Exhibit 64?
11
A
Yes. Is that --
12
MR. WENTWORTH
: I don't know . 64 is the
13
correct number, but I believe there were two versions of
14 this that were printed and it's substantially similar to
15
this.
16
THE WITNESS : Yes . There might be several
17 versions
.
18 BY MR
. MUELLER :
19
Q And did you ever go to the home of any
20 County Board member?
21
A
We left a handout at Mike Phelan's house .
22
Q
Did any County Board members ever come to
23 any meetings of Peoria Families?
24
A Not that I'm aware of
. I was not at every
Page 46
1
meeting but not that I'm aware of .
2
Q Did you ever have any personal
3
conversations during this process with Allen Mayer?
4
A No. I did not .
5
Q Let me show you what we're going to mark as
6 Exhibit 75, and this represents more e-mails
. Just ask
7 you to let us know whether or not these are true and
8 correct copies of e-mails that were actually sent on the
9 dates indicated .
10
(Pause in proceedings .)
I I
A I don't know if there's anything more to
12 that e-mail . It kind of cuts off at the end
.
13
Q These, I believe, are documents that you
14 may have provided to us .
15
MR. MUELLER : Is that correct?
16
Q No, they're not . It cuts off at the end
.
17 But to the extent other than possibly incompleteness,
18 they're true and correct copies?
19
A Yes
. I didn't write the bottom part but
20 the top, yes
.
21
MR
. WENTWORTH : And it's a single page .
22
Q
Let me show you what we're going to mark as
23
Exhibit 76, and we've crossed out the first one because
24 we believe it's unrelated completely
. But ask you to
Page 47
look at the rest and tell us if they're true and correct
copies of e-mails actually sent .
(Pause in proceedings
.)
A Yes
. I believe this is a true copy that
was sent .
•
All right .
A I don't know about some of the ones at the
end of the -- I don't know anything about that final
e-mail .
•
This one --
MR . WENTWORTH : I've got it here .
MR . MUELLER : You've got 65?
MR
. WENTWORTH : Yes.
BY MR . MUELLER
:
•
Can you tell us if you know who wrote this
exhibit?
A
You know what? I don't know, and I've been
trying to figure that out actually .
•
Is it a Peoria Families-generated
documented to your knowledge?
A
I don't know that . I would assume that it
is because it contains similar information to the
website.
•
In any event, though, you didn't generate
Page 48
it, and no one has told you that they did?
A I did not generate it, no, and I don't know
who did .
•
Let me show you what's going to be Exhibit
77, and this is a group exhibit and represents copies of
some documents that you were kind enough to provide to
us today . And I would just ask you if you could review
those and let us know whether they are true and correct
copies of the e-mails that they're represented to be
.
(Pause in proceedings .)
A Okay
. So this is more than one?
•
Right .
A Okay. The top one's missing a date
. I
don't know why the date's not there
. It should have the
date on here .
•
You're the one that provided these so --
MR
. WENTWORTH : I guess what she's asking
is
: Out of the ones that we provided, is there a page
that's missing from the ones that we provided?
A Yes. These all appear to be e-mails that I
sent.
• It would appear that the first one that is
undated predates February 13th because there's a
reference to February 13th in the last paragraph
; would
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v . PCB
Page
45 - Page 48
10/25/06 Tessie Bucklar
Con densely""
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v- PCB
Page 49
- Page 52
Page 49
Page 51
1
you agree with that?
I after May 3rd?
2
A
Yes . That would make sense .
2
A No .
3
Q
Did you recently attend an IEPA meeting
3
MR . MUELLER : Thank you very much for
4 regarding the
PDC
application for a permit renewal?
4 coming in today . We appreciate it .
5
A Yes, I did .
5
MR . WENTWORTH : We reserve signature .
6
Q And were you the person who prepared the
6
3 :35 P.M .
7 Power Point that was presented to the IEPA at that
7
8 meeting?
8
9
A No . I contributed to it . I did not
9
10
prepare it .
10
(Further deponent saith not .)
I I
Q Who was the preparer of the power point?
11
12
A Brad Stone .
12
13
Q What's Mr . Stone do for a living?
13
14
A That's a good question .
14
15
Q
He seems to be pretty technically adept .
15
16
A I believe he does something in regards to
16
17
computers, but I don't honestly know that question -- an
17
I8 answer to that question .
18
19
Q And the IEPA
wrote a letter to you after
19
20 the recent meeting . Were you the leader of the group
20
21 that presented to the IEPA?
21
22
A They wrote a letter to me?
22
23
Q We thought they did . They may not have .
23
24
A No .
24
1
Q Were you the leader of that group?
Page 50
1 PEORIA DISPOSAL COMPANY,
Page 52
2
A No. I would not say I was the leader of
2
PetBiorcr,
3 that group .
3
vs .
No. PCB t&154
4
4
s
PEORIA COUNTY BOARD,
Respondent .
Q Who was the leader of the group that
)
5 presented to the IEPA?
6
6
A I don't know that I would -- it was a group
7
1 hereby certify that I have read the
7 effort . I would not say there was a leader .
foregoing transcript of my deposition given on October
B
25, 2006, at the time and place aforesaid, consisting of
8
Q What was the purpose of that visit?
9
pages
and make
I through
oath that
51,
the
inclusive,
same is a
and
true,
I do
correct,
again subscribeand
9
A To discuss and learn more about the permit
complete transcript of my deposition so given as
10 aforesaid .
10 extension .
I
I
Q Miss Bucklar, how much money did you
2
12 personally contribute to the Peoria Families?
u
Please check one :
13
MR
. SCHLICKSUP : Hold on for a second . I'm
14
Ihave submitted errata sheet(s) .
14
having a hard time understanding the relevance of this, 15
No corrections were noted
.
15 but go ahead .
16
16
A Probably somewhere between 200 to $300 .
17
17
Q And many hours of your time?
is
TESSIE BUCKTAR
I8
A Yes, and many print cartridges as well that
19
19 were not counted .
20 SUBSCRIBED AND SWORN TO
20
Q Have you ever been on the grounds of the
21
before me Ath iss
2
day
21 PDC facility?
22
22
A No
. I have not
.
23
Notary Public
23
Q Were you present at or near the facility
24
My
Commission expires
24 for a purported traffic count or truck count shortly
10/25/06 Tessic Bucklar
1
STATE OF ILLINOIS I
I ss
2 COr .TTYOFTAQQNP1Lf
3
4
CERTIFICATE
5
6
1, Angela M
. Jones, CsR-Rf. a Notary
7 Public duly commissioned and qualified in and for the
8 County of Tazewell, State of Illinois, do hereby certify
9 that there came before me on October 25, 2006, at 416
10 Man Street, Suite 1400, Peoria, Illinois, the following
1 I named person, to wit
:
12
TESSIEBUCKLNL
13 a witness, who was by me first duly sworn to testify to
14 the truth and nothing but the truth of her knowledge
15 touching and concerning the matters in controversy in
16 this cause, and that she was thereupon carefully
17 examined upon her oath and IKr examination reduced to
18 shorthand by meant of stenotype and thereafter converted
19 to typewriting using computer-aided translation by me .
20
I also certify that the deposition is a
21
true record 01 the testimony given by the witness .
22
1 further cemfv that 1 am neither
23 attorney or counsel for nor related to or employed by
24 any of the parties to the action in which this
Page 53
I
deposition is taken, and further that I am but a
2 relative or employee of any attorney or counsel employed
3 hg the parties hereto or financially interested in the
4 acuon
5
In witness whereof, I have hereunto set my
6 hand and affix my wool seal October 30, 2006 .
7
Page 54
OFFIGALSEAL
ANGELA M
. JONES
NOTARY
MY COMMISSION
PUBLIC-STATE
EXPIRES
OF ILLINOIS4342010
SIVERTSEN REPORTING SERVICE (309) 690-3330
CondenseRT"'
PDC v . PCB
Page 53
- Page 54
10/25/06 Tessie
Bucklar
Condensclt
3T"
#084-003482 pi
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SIVERTSEN REPORTING SERVICE (309) 690-3330
#084-003482 - concern
Index Page 1
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27 :18
28 :8
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29
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31 :7
31
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32:14
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33 :12 33
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10/25/06 Tessie Bucklar
Condenselt"d
consideration Isl
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24 :7
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contact [61
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contacts [31
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containing
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content 141
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converted 111 53 :18
copies 151
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exhibits [31
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exist [2141 :4
41 :8
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7 :17
13 :1
14 :16
23 :19
28 :14
experience['] 10 :17
expertise [7] 7 :10
7 :16
8 :24
9 :2
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10 :9
10 :13
expires [21
52 :24
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explain [q
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37 :2
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express [3]
20 :2
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expressed
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extent [1)
46 :17
facility [3]
15 :16
50 :21
50:23
fact[91 11 :5 11 :14
19 :19 24 :18 26 :5
27 :16
38 :21
42 :14
SIVERTSEN REPORTING SERVICE (309) 690-3330
concerned - fact
Index Page 2
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documented
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documents
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done [2]
46 :13
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door-to-door
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early [s] 12 :13
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15 :2
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editorial [2]
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educational
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7 :19
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33 :3
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50 :7
efforts
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8 :24
43 :17
either [3]
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26 :1
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34 :2
34 :5
34 :6
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17 :16 18 :7
confused [I] 9 :24
23 :2
23 :20
confusion[')connection[I)
4414:13:24
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consider [41
19 :10
48 :8
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corrections [2]
32
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employed [4) 6 :1
6 :3
53 :23 54 :2
employee [I] 54 :2
employment [1]
6
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encouraged [11 20 :7
end [4] 23 :22 46 :12
46 :16
47 :8
ended [I]
43
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enlighten Ill
5
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entered [3]
34 :21
10/25/06
Tessie Bucklar
CondenseIt'T''
family 111
10 :16
Fast
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February
161
15 :2
17 :2
17 :16
18 :10
48 :23
48 :24
feelings p
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28 :3
felt 131 20 :5
20 :10
31 :16
figure
121
44 :13
47 :18
file
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18 :24
28 :4
28 :6
filed
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19 :5
34 :12
38 :18
40 :3
filing
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filings 11
19 :1
final 121 31
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financially [ii 54 :3
fine p l 30 :22
finished p
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12 :4
12 :18
14 :7
15 :12
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21 :6
21 :13
22 :14
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27 :2
33 :16
36 :2
37
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38 :1
38 :4
42 :2
43
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46 :23 48
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five [2) 17 :15 43 :6
flier [2) 9 :7
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fliers
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45 :6
45 :9
following [q 53 :10
follows [1)
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formulas [21
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forwarded [
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gentleman
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27 :18
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hear [21 25 :5
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32 :20
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incorporated
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indicated
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12 :13
12 :13 17 :20 19 :18
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22 :24
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23 :4
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27 :12
27 :16
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46
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6 :12 6:16 7:7
7 :9
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10 :3
42 :4
42 :18
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massaging
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massive [1)
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material [2)
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24 :23
materials
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10 :1
MATT p1
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matters [21
40 :11
53 :15
may
[71
6:19
11 :20
35 :8
41 :12
46 :14
49 :23
51 :1
SIVERTSEN REPORTING SERVICE (309) 690-3330
facts - may
Index Page 3
involved [41 10 :5
19 :1
44 :18
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involvement [31
9 :14
10 :9
issue [4127 :5
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28 :9
2 :5
11 :19
12 :2
1 :0
11 :1
30 :3
44 :4
8 :2
42
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46 :12
28 :10
30 :10
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January pl
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Jeffrey pl
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Jones pl
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Julia 13l 44 :2
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keep
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29
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kind p1 44 :9
48 :6
kindly It l
37 :1
knew [21
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knowledge Isl 7 :9
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landfill
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last poi 6 :3
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42 :2 48
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4 :13
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17 :16 17 :20
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leader [s1
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50 :1
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facts [21 27 :19 27 :23 fund [a] 31 :12
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34
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21 20 25 :17 25 :20 gain [41 14
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profession - Supreme
Index Page 5
46 :21
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shortly [I1
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10/25/06 Tessie
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Thank 131
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34
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36
:10
37 :18
vs121
1 :0
52 :3
wait[1] 42 :13
waste [4I
7 :23
10
:10
10 :17
11 :2
website [21
9 :15
47 :23
Wednesdayp] 1 :0
36
:10 37 :18 39 :19
Widmer's [1) 45
:5
Williams [11 2 :13
Wisconsin [I)
44
:21
witp) 53 :11
witness po]
1 :0
3 :3
4 :1
4
:3
16 :21
35 :5
45 :16
53 :13
53
:21
54 :5
worked(2) 6
:15
6
:24
works [1)
38 :9
write
[
1146 :19
writing p1
24 :18
written p 1
9 :12
wrote [91
23 :19
24 :22
25 :3
25 :7
25 :18
34 :16
47 :15
49 :19 49
:22
yard
[2]
9:4
9
:21
yourself [I)
13 :8
SIVERTSEN REPORTING SERVICE (309) 690-3330
surprised - yourself
Index Page 6
surprised 111 15.18
suspicious 111 21 :2
sworn
[4)
4
:1
4 :3
52:20 53:13
taking [21
1 :0
28 :1 1
Tazewell 131 1 :0
53 :2
53:8
technically 131 5 :19
5 .23
49 :15
Ted [51 42 :1 42 :3
42 :9
42 :12 43 :2
telephone [61 5 :9
1121 30 :5 30
:16
31 2 3110
televised [21
27 :8
27.15
Tessie 1121
1 :0
1
.0
2 :18
3 :4
4 :2
4 :8
4 :10
34 :1
42 :9 42 :15
52
:17 53 :12
testified p1
4 :4
testify r11
53 :13
testifying 121 16 :2
2019
testimony 111 53 :21
try [31 20 :24 36 :18
43
:11
trying 110]
14 :23
17 :2
19 :13 23 :7
23 :21 24
:14
25
:24
26 :1
44 :13 47 :18
TV p)
27 :13
two [131
9 :24
12 :6
12 :16 12 :17 23 :2
28 :12 33 :21 34 :10
36 :2
36 :16
36
:16
37 :2
45 :13
weeks [1)
15 :2
Wentworth [20) 2 :13
4 :17
11 :8
11 :10
20 :17 20
:24 21 :5
33 :14 35 :1
35 :9
35
:14 36 :20 37 :1
37 :4 45 :12 46 :21
47
:11 47 :13
48
:17
51 :5
whereof [1)
54 :5
whole [7]
15 :21
27
:5
31
:14 35 :6
Exhibit 19
10/25/06 Tom Bucklar
Condenseltt`
E 309) 690-3330
PDC v P B
Page 1 - Page 4
Page 3
INDEX
Thomas Buckler
10/25/06
BEFORE THE ILLINOIS POLLUTION
CONTROL BOARD
PWR :A : :SPOSAL COMPANY,
Petitioner,
ORIGINAL
3
3
WITNESS :
Page
4
THOMAS BUCKLAR
Examination by Mr Mueller .
6
9
EXHIBITS :
10
EXHIBIT 78
10
E-mail
I
No . PCB 06-184
PEORIA COUNTY BOARD,
14
15
16
Respondent
I
THE DEPOSITION of THOMAS BUCRLAR, a witness
: .u -.am .nauci pursuant to notice and
mu Ruses As they pertain to the taking of
before Ange:a M . Jones, CSR, RPR, and a
Ncta[y Mobil, 1n and :or the County of TaIevell, State
of Illinois, on Wednesday, October 25, 2006, at 416 Main
20
33
23
Street, Suite 1400, Peoria, Illinois, commencing at the
3 45 p.m .
NOTE :
Exhibit retained by Petitioner's Counsel
.
ASPN.ASRR ES
Page 2
:
Page 4
GEORGE MUELLER, ESQUIRE
1
(Witness sworn.)
2
52e Columbus Street, Suite 204
THOMAS BUCKLAR,
4
Ottawa, Illinois 61350
3
called as a witness, after being first duly sworn, was
and
4
examined and testified upon his oath as follows
:
JANAK : NAIR, ESQUIRE
5
BRIAN J . MEGINNES, ESQUIRE
EXAMINATION
E : :as, M,-ginres, Riffle & Seghetci, P
.C .
6
476 Male Erred , Suite 14(10
BY MR
. MUELLER :
Peoria, :_ iv a
61602
Cne n PetlCOne : ;
7
O ; . Mehe
;f of
Q
Would you state your name, please?
g
to
DAVID A
. BROWN, ESQUIRE
8
A Thomas Bucklar.
9
MR. MUELLER
: Let the record show : This is
Black, Black 6 Brown
10
the discovery deposition of Thomas Bucklar taken
101 South Main Street
Morton, Illinois 61550
On Behalf of the Respondent,
11 pursuant to subpoena and in accordance with all the
12
applicable rules of the Pollution Control Board and the
HAL SCHLICKSUP, ESQUIRE
411 Hamilton Boulevard, Suite 1720
13
Illinois Code of Civil Procedure .
14
Q
Is it okay if I call you Tom?
15
A
Yep .
Peoaril
f
a,
o
Illinois
On M
al
f Thomas 61602
Bucklaq
ALSO PRESENT :
Q Thank
Y
ou. Sir, what is
your
address?
17
A 5045 North Bellevue Place
.
18
Q In Peoria?
19
A
Peoria Heights
.
ROYAL COULTER, PDC
JEFF CO LTER, PDC
20
Q
Before we go further, I should ask you if
MATT COU TER, PDC
21
you are here today with your attorney Hal Schlicksup
.
23
22
A
Yes, I am .
24
23
Q
Who do you reside at that address with?
24
A
My wife, who you just met, and my three
10/25/06 Tom Bucklar
Condenseltm'
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page 5 - Page 8
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children
.
Page 5
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Page 7
A
Yes .
Q In connection with your employment at
Caterpillar, have you had occasion to visit any
landfills?
A Yes.
Q What landfills have you visited?
A Oh, Tulleytown Groves, which is one of
Waste Management's largest landfills in Philadelphia .
I've been to the Orange County landfill in Los Angeles,
again, one of the larger landfills . There's others .
Let me think .
Q Ever visited any hazardous waste
facilities?
A No, not to my knowledge
. All municipal
solid waste, I believe .
Q Have you ever visited any facilities owned
or operated by Peoria Disposal Company?
A Not to my knowledge, no .
Q Do you have any specialized knowledge
regarding landfills or landfill operations that relates
to the opinions that you expressed at the public hearing
in this case?
A No.
Q Do you have any specialized knowledge
Q
A
What is your educational background?
I have a bachelor's of science in
electrical engineering from Marquette University and an
MBA from the University of Chicago .
Q Where are you employed at the present time?
A Caterpillar .
Q In what capacity? Or I should say : What's
your title?
A I work with the North American dealers, so
I'm dealer development .
Q Do you have a specific job title such as
vice president of this or manager of that?
A It's a regional manager, is the position
title
.
Q What does that department principally do?
A
Is this -- I'm not sure if this is
relevant, to get into what I'm doing at Cat
.
MR . SCHLICKSUP : Yeah, George --
MR . MUELLER. just by way of general
background .
MR . scHLiCKsup : unless you can show how
it's going to lead to some relevant information
pertaining to the issues here, he's not comfortable
Page 6
Page 8
I going into his background at work .
1
gained prior to your involvement in the PDC expansion
2
MR . MUELLER : Well, I think in public
2 regarding hazardous waste management and disposal?
3 comment he purported to have an ability to speak
3
A
No
. And, again, my knowledge of landfill
4 knowledgably about landfill matters, so we just wanted
4 engineering technology and the associated processes is
5 to do a brief inquiry into the basis of that knowledge .
5 not very deep .
6
A Yeah. It's dealer development . I mean, I
6
Q Are you a member of Peoria Families Against
7 work with the dealers on developing their sales forces
7 Toxic Waste?
8 and product support and ability to sell our products.
8
A No .
9 And our products go into construction and also a line
9
Q Did you provide any services or expertise
10 for market, so I deal with both industries on a regular
10 to any of the efforts of Peoria Families Against Toxic
11 basis .
11 Waste?
12
Q Let me break it down a little bit . In your
12
A I'm not sure I understand the question .
13 employment at Caterpillar, have you had any hands-on
13
Q Well, did you volunteer any of your time,
14
experience working with the design, construction, or
14
skill, or knowledge to what PEA7w
was doing?
15
marketing of equipment commonly used at landfills?
15
A Well, I mean, my understanding of Peoria
16
A
Yes .
16
Families Against Public (sic) Waste is it's pretty much
17
Q What kinds of equipment?
17 a loose gathering of concerned citizens . There's no
18
A Compactors, track-type tractors .
18 membership cards to my knowledge . I would consider my
19
Q Have you ever been involved in compactor
19 wife -- that will probably be one of your questions --
20 design?
20 as a member, but I think that means just she was one of
21
A
No.
21 the core people that met and discussed issues
.
22
Q Would it be fair to say you're principally
22
I did on occasion help my wife out in some
23 involved now in management and marketing as opposed to
23
of her efforts with the landfill expansion issues
.
24
the engineering end of things?
24
Q I think that's what I'm getting at . In
10/25/06 Tom Bucklar
Condenseltn"
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page 9 - Page 12
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Page 9
what ways did you help her out?
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Page 11
true and correct copy in your possession right now .
Q I think this is a printout from somebody
else's computer probably
.
A Without reading it in detail, it looks
familiar, similar. But the one you have is definitely
the one I can stand behind .
Q And what was your understanding regarding
what the County Board was to consider in rendering its
decision on the application?
A That was
-- in my mind, that was a very
confusing topic for a citizen throughout the whole
process . My understanding is they definitely had to
just weigh the facts of the matter and not take external
input but just weigh the facts that they were given .
Q If they were not to take external input,
then what was the point of you providing external input
in this e-mail on April 28th, 2006?
A I had read the, I guess, response to the
vote that PDC, I believe, submitted
. I had read that
response to the initial vote that they did, and it was
posted on a website after they did it
. I think it was
the county's website . As I read it, I just saw some
inconsistencies ; and I wanted to point out the facts
that were --
I believe facts that were in that document
A
Well, primarily, I watched the kids while
she was working on the landfill, to be quite honest . 1
mean, we've got three young children, and they're all
young ; so that's a big part of what we do . So I work
during the day ; and at night, when she would generally
put her efforts towards this, my help to the cause, so
to speak, would be watching the kids
.
Q
A
Q
A
Q
Did you ever go door-to-door?
No.
Did you design any fliers?
No .
Did you provide any editorial input into
any fliers or websites or other written materials
created or generated by Peoria Families?
A No.
Q Did you ever speak on the telephone with
any County Board members about this particular proposal?
A No. To my knowledge, I've never spoken to
any of the County Board members .
Q Did you ever visit any County Board member
at their home regarding this particular proposal?
A
No .
Q One of the reasons that
you're being
Page 10
Page 12
I
deposed and you may be able to cut this very short is
1
that seemed inconsistent, and that's what I laid out in
2
that there were a number of letters sent to County Board
2
this e-mail,
3
members from an e-mail account titled Tessie and Tom
3
There's no new information in the e-mail .
4 Bucklar
. Who was the principal user of that e-mail
4
It's just pointing to some information in that filing .
5 account?
5
Q Well, it does contain your analysis of
6
A It is -- my wife is the primary user
. I do
6 facts because you just said there were some that you
7 use it . It's our personal e-mail .
7 thought were inconsistent?
8
Q Do you have a separate personal e-mail in
8
A I wouldn't call it a true analysis . I
9 your own name?
9 looked at one section, and I saw ten areas that were
10
A No,
10 listed as areas that you needed to consider and the
I I
Q Did you ever send any communications to any
11 Perpetual Care Fund
. If I recall, then I looked at the
12 County Board member or county staff member from your 12
actual cost breakdown and just didn't see some of those
13 business e-mail address?
13 areas that seemed important like insurance and some of
14
A
No . I did that through -- I sent some
14
the other things that I laid out here . But there was no
15 personal a-mails through my home which I believe are
15 greater analysis than just taking A, looking at B, and
16 part of the documents that you have .
16 seeing if they looked equivalent .
17
Q Let's mark this first exhibit as 78 . This
17
Q And you felt it was appropriate to point
18 will he Exhibit Number 78 .
18 that out to the County Board members in a private
19
A Yeah . That would be one of the ones I was
19 communication outside of the hearing process?
20 just talking about that I sent from my home address
.
20
A
In my mind, it wasn't a private
21
Q Is this a true and correct copy of an
21
communication . I sent it to all the board members and
22 e-mail that you sent to the board members indicated?
22
the Journal Star . This is where I believe -- I just
23
A The one that I gave you just a minute ago
23 didn't have the understanding of the process at the
24 is definitely a true and correct copy, so you have a
24 time, and I saw something that was posted publicly on a
10/25/06 Tom Bucklar
Condenselt"''
P RTIN
SERVICE (309) 690-3330
PDC v. PCB
Page 13 - Page 16
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website at the county and did not understand that if I
sent it back to all the County Board members as well as
the local media that that was trying to do anything
private or underhanded.
Q You were aware that the time for public
comment had expired by April 28th, weren't you?
A
I wasn't that in depth in the details, to
tell you the truth .
Q So the answer is you don't know whether the
public comment period had closed?
A I think the truth is probably that I didn't
understand what public comment meant and how it was
being used . I had heard dates about when things would
be posted on the website, and it was my understanding
that after that date things could not be posted to the
website for consideration . This is part of what caused
my confusion probably because the PDC document was
posted to the website
. But, again, I didn't have that
good of an understanding of the analysis or situation
.
Q Mr. Bucklar, could I actually ask you to
take the time to read through this exhibit, 78, to
authenticate this version of it?
A Absolutely . This is Exhibit 78?
Q
Yes.
I
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Q Are you a member of the Sierra Club?
A
No .
MR. MUELLER
: That's all the questions we
have.
MR. SCHLICKSUP
: Reserve .
4:05 P .M.
(Further deponent saith not .)
I
A
And you want me just to read it?
Page 14
1 PEORIA DISPOSAL COMPANY,
Pag
e 16
2
Q Just tell us if it is, in fact, a true and
2
Petitioner,
3
correct copy of an e-mail
3
No .
sent.
vs ,
PCB 06184
4
you
(Pause in proceedings.)
4 PEORIA COUNTY BOARD .
5
A
This copyright here which you just handed
5
Respondent.
6
6 back to me is, to the best of my knowledge, true and
7
1
hereby
certify that I have read the
7
accurate of exactly what I sent .
e
foregoing transcript of my deposition given on October
8
Q Mr . Bucklar, are you aware that Peoria
25,
pages
2006,
I through
at the
15,
time
inclusive,
and place
and
aforesaid,
I do again
consisting
subscribeof
9 Disposal Company is Caterpillar's largest customer in
9
complete
and make oath
transcnptof
that the same
m
y deposition
is a ante,
so
correct,
given asand
io Central Illinois?
10
u
afoesadd
11
A No
. Altorfer's largest customer?
12
12
Q Caterpillar's largest customer
.
Pie . check a
. :
1 3
13
MR
. ROYAL COULTER : Altorfer's largestlargest
14
1 have submitted errata sheet(s)
.
14 customer.
IS
No corrections were noted .
15
A I was not aware of that.
16
16
MR. MUELLER. Let's take about two minutes
. 17
17 We may be finished or close to it .
THOMAS BUCKLAR
18
(Recess in proceedings from 3
:57 p .m.
19
19
to 4:02 p .m.)
20
SUBSCRIBED AND SWOkN TO
20 BY MR
. MUELLER:
he fore me this
day
21 of
,A.D.2006,
21
Q Mr. Bucklar, did you have any technical
22
22 involvement in setting up or maintaining the Peoria
23
Notary Public
23 Families website?
24 My Commission expires
24
A No.
10/25/06 Tom Bucklar
Condenselt"'
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page 17 - Page 18
STATE OF ILLINOIS )
SS
Page 17
2
3
4
6
7
8
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I 1
COu
OF TAZEWEt1)
rennt1urr
1 . Angela M . Jones, ass sax . a Notary
Public duly commissioned and qualified in and for the
County of Tazewell, State of Illinois, do hereby certify
that there came before me on October 25, 2006, at 416
Main Street, Suite 1400, Peoria . Illinois, the following
mined person .w wi t
12
1 3
14
15
16
17
1 8
19
20
21
22
23
24
THOMAS nt/CRIM
a witness, who was by me Lrst duly sworn to testify to
the truth and nothing but the truth of his knowledge
touching and concerning the matters in controversy in
this cause, and that he was thereupon carefully examined
upon his oath and his examination reduced to shorthand
by means of stenotype and thereafter converted to
rypewnung using computer-aided translation by me
.
I also certify that the deposition is a
true record of the testimony given by the witness .
1 further certify that I am neither
attorney or counsel for nor related to or employed by
any of the parties to the action in which this
I
2
deposition is taken, and further that I am not a
relative or employee of any attorney or counsel employed
Page 18
3
by the parties hereto or financially interested in the
4 action.
5
In witness whereof, I have hereunto set my-
6
hand and affix my notarial seal October 30, 2006 .
7
8
9
10
I I
12
Angel
ones, CSR "It
Illinois
R kOS4- 034E2
Commission Expires 4/30/2010
13
14
15
OFFICWI-gE,qL
1617
NOTAR PUBICSTATE
JONES
OF
MY COMMISSION EXPIRES 4,0
.I0ip
19
20
21
22
23
24
10/25/06 Tom Bucklar
CondenseIt""
#084-0034821812
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[11
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affix p] 18 :6
aforesaid 121
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again 141
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APPEARANCES
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appropriate
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bachelor's [11 5 :3
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basis [216i5
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Behalf [31
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behind 111
11 :6
Bellevue [11
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big
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board [141
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brief pl 6:5
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2:11
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24:8
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43:4:10
10:4 13
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1
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111
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cards 111
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citizens [11
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[114:13
close
[I] 14
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13 :10
Club
111
15 :1
Code [114:13
Columbus 111
2:3
comfortable
[1]
5
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1 :0
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[41 6 :3
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SIVERTSEN REPORTING SERVICE (309) 690-3330
#084-003482 - fliers
Index Page 1
e-mail [111
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SIVERTSEN REPORTING SERVICE (309) 690-3330
following - RPR
Index Page 2
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rules
- young
Index Page 3
Exhibit 20
KIMBERLY CONVERSE
10-24-2006
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PCOP.IF. DISPOSAL COMPANY I .
PEORIA COUNTY BOARD
PCB06-184
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PCB06-184
KIMBERLY CONVERSE
10-24-2006
KIMBERLY McLEAN CON\ ERSL
.
a material witness herein . being duly sworn
. was
examined and testified as follows
:
EXAMINATION
BY MR . MUELLER :
•
Would you state your full name, please?
A
Kimberly McLean Converse .
•
Let the record show this is the discovery
deposition of Kim Converse taken pursuant to
subpoena, in accordance with rules and scheduled
and rescheduled by agreement of the parties
.
Kim, you have previously indicated that I
can call you Kim?
Q What is m ac .com".
:\ Stands till Macintosh
.
•
Is that your Internet service provider or
is that a domain that you have some interest in?
A
It's ms If-mail account .
•
Let me ask it another way
. I'm not sure
you understood my question
.
Is m ac.com
a domain name that you have sonic
interest in or is that just the name of some
third-party internet service provider that you use?
A
It's the name of my 1--mail account
. I hake
no interest
. I pas then to hums an I--nail account
with
them.
Pages 3 to 6
PEOFIP
. DISPOSAL COMPANY PEORIA
COUNT Y BOARD
PCB06-184
A Yes .
Q Y on are here today with your attorney
Q It wasn't familiar to us like ATT or yahoo
or SBC global
. That's why I'm asking
.
N1 r. N entworth?
What is your educational background, Kim :'
-''
A Yes .
Q
Have you ever had your deposition taken
A
I went to N hiuier tirade School in Peoria
.
I well to Manual I li^-h School and Mount I lokokc
before in any case for any reason?
College .
A
No .
Q Has Mr
. Wentworth had an opportunity to
Q
Do you have a degree?
A Yes . I do .
Q In what major
A
Political science
.
Q What year?
\
1993 .
Q What has been your employment background
acquaint you with the procedures and the basic
structure of how discovery deposition works?
A 1'es .
Q
Then I will dispense with all of that .
What is %our address?
3 A
1420 West Parkside Drive .
since college?
4 Q
How long have you lived there?
A
I worked for the Acadents of Pediatric
5
A
A little over four years .
Dentists in Chicago
. I worked tot ER Nelson
. I
6
Q
Who do you live there with?
I
worked till* my sister in Alaska
. I have worked till'
7 A My husband . Ted
. and Ill two daughters and
Caterpillar .
8
Ill doe .
Q Where are you presently employed
9 Q What is your telephone number?
A Caterpillar .
10
A
(309)671-9901 .
Q
How long have you been employed there
:'
11 Q
Do you have a cell phone that you actively
A
One sear and nine months
.
12 use?
Q
W'hat's your job title at Caterpillar?
13 A Yes . I do
.
A
Senior learning consultant .
14 Q
What is that number?
Q Do any people report to
-- directly to you
15 A
(309)696-2141 .
at that job?
16 Q You have a work telephone number?
A
Yes .
17 A Yes . I do .
Q
How many?
18 Q
What is that? We won't call you there .
A I hree .
19 A (309)675-6051
.
Q Who's your immediate supervisor at
20 Q Do you have an E-mail address that you
Caterpillar?
21 regularly use?
\ Chris An in .
A Yes . I do
.
Q
1'ou are married to led Converse?
23 Q What is that?
A Yes
.
24 A
Kimconverse!dmac .com .
Q
You are the daughter of John and Cindy
KIMBERLY CONVERSE
10-24-2006
•
When did that occur?
A August 211(15
.
•
Was the source of that lead content ever
determined?
A Yes .
•
What was the source!
A Lead Paint,
•
In your home or some other location?
A \k c think the home
.
•
To your knowledge, is your daughter
suffering any permanent negative effects from the
high normal lead content
A No. it's gone do'' n .
•
Do you have any experience with asbestos?
A No .
•
Do you have any experience on a personal or
family basis with chlorinated hydrocarbons?
A No
.
1 k
Q Are you a member of Peoria Families Against
Toxic Waste?
A Yes
.
•
Can you tell me a little bit about that
group? Is it a corporation?
A No.
•
It's just a voluntary
association?
A No .
•
Let me ask you a question that's not on my
outline but one that has troubled me
.
1'on don't fit the profile of typical
landfill opponents
. What was the force that
motivated
--
that's actually a compliment.
Mr . Wentworth . You know it is
.
MR
. AA' ENT W0RTI I
: I don't know what it
is . George .
BY MR
. MUELLER :
•
What motivated you to become so active in
this process?
A
Concern for the health and salcty of my
tamily and of my community
.
•
"as there anything specific or just a
generalized concern?
A
I was very concerned for the health and
I ' safety of my family and of my community .
1
.,
Q
W as there a single event or action that was
a trigger that set that concern into motion?
A No .
•
Does the Peoria Families Against Toxic
Waste have any officers?
A No .
•
Does it have what we might
call a steering
Pages 7 to 10
Pb( ;L1k DISPOSAL SOI1
;1,11t
PEOP :A. COUIIT't BOARD
PCB06-184
McLean?
A Yes .
Q
Why was it never incorporated?
A
Ue lust ha'en't incorporated it
.
Q W'ho formed the group?
A
I did with set erul others
.
Q
Who are the other founding members?
A
Mr husband . founding nicmhcrs
. I would sa'
A Yes .
Q
Do you have any special knowledge outside
of what the ordinarc layperson would have acquired
before the landfill application with regard to
waste disposal :'
A No .
Q
Do you have any special knowledge regarding
Peter ()dint
. Lisa Oltutt would he the ear l% ones .
asbestos?
Q
Your husband, you and the Offutts would be
A
Q
No
.
Any special knowledge regarding lead or
the driving initial numbers?
.\
Q
N c were the earliest mcmhers
.
other heavy metals?
Was your father one of the founding
A
Q
No .
Did you have any experience before the
individuals?
A
Q
No
.
hearing started in the area of waste disposal?
Did you get involved in this cause before
\
Q
A
No .
Any experience with hazardous waste??
No
.
he did or did he get involved before you did?
A
Q
I le learned of it before I did .
How did you learn of the proposed landfill
Q
Any experience with lead or other metals?
- % expansion?
A Yes .
2~': A
1totnIm hushund .
Q
What lead experience do you have?
2 : Q
Did your father take a position or
A
One of m~ daughters had a high normal
_
encourage you and your husband to get imohed
reading .
before you actually did?
KIMBERLY CONVERSE
10-24-2006
committee or a leadership group
A
lust memhers that attend meetings .
•
How many active members would you say you
have at this time?
A Ah Lite, 'sould he Itl . around Ill
.
•
How many active people, members would you
say you had on April I st of 2006?
A
April Ist
.2(0)6 .'
•
That's right in the thick of things
.
A
A goes, . 20 to 25 .
•
Did you ever keep membership lists?
A
No .
•
Does the organization maintain a mailing
list?
A Not a mailing list .
•
Do you have some other contact list then if
not a mailing list that you utilize to contact
t
individuals?
A Atiecurrenlh du .
•
In what form is that maintained?
r1
It's an I -mail group lilt .
•
Does that E-mail group list go beyond
Peoria Families Against Toxic N aste to other
individuals who are known opponents of the landfill
P . _I
expansion?
A No .
•
For example, is Joyce Blumenshine on your
E-mail group list?
A Yes .
•
She is not-- is she a member of Peoria
Families Against Toxic Waste??
A
I consider her to he --
I don't knot' 'v hat
she considers her sell to be
. but she conies to our
meetings
.
•
Does your E-mail list include the names of
people whose identities you learned from the public
comment file maintained by the Peoria County
clerk's office??
A No .
MR
. \k \[N \ O R 11l : At 'shat time
. Oeorge.'
BY MR . MtFill It :
•
Did your E-mail list ever include the names
of people whose identities and E-mails you learned
of from the Peoria County file?
A
\\hat I!-nail .'
•
The Peoria Families Against Toxic Waste
E-mail list that you maintained
A
We did not maintain than until alicr the
ale .
•
So that's a post-May 3rd development??
A Correct .
•
Did Peoria Families Against Toxic N ante
prior to May 3rd solicit support from individuals
b% E-mails directed to E-mail accounts that you
learned of from the public comment file?
:A (art' 'oil repeat the question
.,
•
Before May 3rd . 2006,did your group
solicit support, help or contributions from
individuals whose identities you learned about from
the public comment file?
\
Our I .-mail list :'
•
Not your E-mail list
. From the public
comment file kept by the clerk's office
A ('an'onclarih'sh
:ututire--~outserc
talking to me about our group I
.-mail list . I'm
1= conlused'shat Otire--
•
I'm done with the group E-mail list
. I'm
now back to before May 3rd, 2006
.
A
Ihank 'ou
.
•
During --
let's say during the period
November 9th, 2005 through May 3rd, 2006
. did
Peoria Families solicit support from individuals
whose identities you learned about from the public
comment file maintained by the Peoria County clerk?
A We contacted people Irons the public comment
list .
•
For what purpose?
A
For various purposes .
•
Such as . if you can identify the various
purposes?
A Well . to inlbrm people of the public
1 C comment dale deadline seas one purpose w share
mlornr.Won about the opportuml,\ to ha e ,sIgns
.
•
Any other purposes?
:\
We notified people ahout ctcnts like the
Sandra Steingraher e' emit
. 1here ocrcse'eral
. So
those are examples that Cone to mad at this ante
.
•
Let me go a little bit out of order . Who
arranged for the appearance of Sandra Steingraber?
\
I did .
•
Was she compensated for her appearance?
A Yes .
•
How much was she paid?
A $1
.000 .
•
Plus expenses or $1,000 then she paid her
own expenses?
i
Pages 11 to 14
:,E9PIA DISPOSAL COMPANY
PEONA COUNTY hOAPD
PCB06-184
KIMBERLY CONVERSE
10-24-2006
A
that oas the ooh one that oc sponsored .
such as River Rescue and Citizens For Our
Pages 15 to 18
i'E,--TA DISPOSAL CDMPAT!
', . PEGP.iA COUNTY BOARD
PCB06-184
A S I 000. that's all
. She paid Ior her
Q Did you have any other fundraisers,
espenses .
potluck. anything like that?
Q
You've been identified in another
A Jos ce had some for us .
deposition as the person closest to being the
Q Through the Sierra Club or just through her
leader of Peoria Families Against Toxic Waste
.
Would you say that's a fair statement?
own efforts for you?
A I roni no understanding
. It oas lust Iron
her .
Q Who is the person identified as
A
- I hat's Ilattering
.
Q Is it a fair statement?
A Sure
.
Q
I understand you don't have a president or
i nfoatnotoxicwaste.co
m ^.
A 1' on mean "ho --
Q W hose E-mail account is that?
A that's the I'-nail account Ibr
chairman as such, is that right?
A Correct .
Q Who handled the money for Peoria Families
noloxC"asle .or'g .
Against Toxic Waste??
Q Who's the author of E-mails using that
A \fi norm .
Q How much total money did the organization
address?
A Iam .
Q So you are i nfoatnotoxicwaste
.org
\
It',, --)es .I"as .
Q W'ho maintains the
n otoxicwaste .org website^.
A AJS husband and I do .
Q
I presume you represented or purchased an
raise?
A
I'p to this point?
Q l'es .
A
I don't knoss the enact numher
. hut ahos e
25 .000 . probable hemeen 25
.000 and ?8 .11110 could he
ms best guess .
actual domain name for that website?
Q W ell, that being the case, how would you
A
Q
Yes .
have been able to pay for the billboards that were
W' ho purchased the domain name?
D7
-
purchased all over Peoria County
A
Q
MN hushandand I did .
A %A e didn't pay for the hillboards
.
Who did the actual creation of the web
Q Who paid for the billboards?
A Joyce Blumenshine
.
pages?
\ ',Is hushand .
Q Do you know how much she paid for those?
A
I don't knoss the eeact figure .
Q Have you spoken to Joyce Blumenshine in the
Q
Who's responsible for the written content
in the web pages?
A
Q
lam .
last 48 hours?
So would it be fair to say that your
. . .
A Yes .
Q Did she discuss with you her deposition and
what to expect at your deposition
A
Aetualh
. I did not talk to her . I
recei)ed an l'-mail
.
Q Who--or let me finish off the money here .
Did Peoria Families Against Toxic Waste
ever
husband was responsible for the technical aspects
of setting up the website and you were responsible
for the editorial comment?
V
I was responsible for the commenl .
Q Or the editorial content?
A
I s) as responsible Ibr the content .
Q Okay . When was that website started?
1
receive any contributions or anything of value from
any county employee or county board member?
..
:\
I belie' e the end ol' Januar' or earl'
I ehruarN .
A Not to my knoo Icdge . Certainly no count)
1'^ Q
Was there, Kim, ever a coalition formed
1)^ hoard tnemher
. I has c no oas to knoss i f people
among various opposition groups or individuals that
21
donated at carious C\ Cat,
oho corked at the count .
but ccrtainh no count) hoard member
.
would have been broader than just Peoria Families
Against Toxic Waste??
2_ Q What events did Peoria Families sponsor
A t here gas not a coalition Ihrmed
.
__ besides the Steingraber lecture?
Q
For example, we've learned of other groups
KIMBERLY CONVERSE
10-24-2006
Environment and the Heart of Illinois Sierra Club .
N as there ever any attempt made at
coordinating the actions of those groups or having
representatives of those groups meet together to
plan strategy?
A No
.Ae respected the other groups . I
think once tsc tried to coordinate the color that we
might wear at the hearings . Ihat's about the
c\loot .
•
N' ell, who hired Mr
. N entworth
A
.to%cc .
•
was he hired by Joyce to be the attorney
for the Heart of Illinois Sierra Club group or for
Peoria Families Against Toxic NN'aste?
A Roth .
•
Who has paid his bill with respect to those
two organizations
A It's -- lot cc has paid some . Peoria
Families has paid sonic .
•
To your knowledge, has the Heart of
Illinois Sierra Club group paid any?
A I don't know .
•
But it is your understanding that
Mr
. \1 entworth actually represents both of those
20
voluntary associations?
A Yes .
•
Are you a member of the Sierra Club?
A
I don't think so .
•
Has any county board member ever attended
any Peoria Families meeting
A No .
•
Let's do a couple of shorthand items here.
If I say Peoria Families, I mean the group Peoria
Families Against Toxic NN'aste, fair enough?
A Yes
.
•
If I say during the application and hearing
process, I mean the time period from
November 9th, 2005 through May 3rd, 2006 . is
that fair?
A Yes
.
•
Did the Peoria Families sponsor or publish
a newsletter?
A No .
•
W ere you ever -- or strike that .
22
2 :
Did you at some time become aware of the
rules and procedures that governed the landfill
siting process
A
Ak'hich ones?
2
Q Any of those rules or procedures'!
A Ycs .
•
How did you become aware of the procedures?
\ Various was,
.
•
Can you just describe them briefly?
A I had sctcral discussion with Patrick
l rich at the count" . I had sct eral I .-mail
cychongcs with Patrick t rich and with Mrh lit own . I
attended the I chi uan I think it was 9th . I'm not
s ure "hat doe it was . where the hearing rule, were
discussed and I he lie' c \ tiled on .
•
So it would be fair to conclude that you
were by February 9th familiar with the concept
that the decision the county board members was to
be based exclusively on evidence generated at the
public hearings?
A Yes .
•
It would be fair to say that you were by no
later than February 9th aware of the fact that
county board members were not to receive ex parse
communications from the various participants in the
landfill application process?
A I don't know .
•
NN hat do you mean by You don't know?
Papa ~_
A I don't know with regards to c\ parse when
I -- when that terminology came in . I attended the
hearing . I can't sas that I had all the -- I can't
make that s tatement . no .
((
onverse I(\hihit No
.
;g marked)
11)' MR . Mt': I : I .l l :R :
Q Well, let me ask you about something --and
this is going to be Exhibit 58
. 1 will give you a
copy of that, Kim
.
First of all, I'm going to represent to you
that we believe this is a copy of the web pages
from the Peoria Families website as they appeared
on January 31st, 2006 .
1 will ask you to look at those and tell me
if, in fact, that appears to be a correct
statement .
A (N itness perusing document
.) Yes .
I -
Q Okay . Then if I can direct you to the
1
third page of--
A ('an I get a tissue?
(Discussion oll the record .)
BY MR . Mt LLLI:R :
Q Ask you to look at page 3 of 5, and direct
you to the paragraph beginning with county board
Pages 19 to
22
.~ .r . ., L) :?P03AL COMPAlIP
DEOPIA ';OUI :TI BOARD
PCB06-184
KIMBERLY CONVERSE
10-24-2006
restrictions.
Did you write this material?
.\
1'cs .
•
l\ as all of this material written before
January 31st.2006?
A It must hate bean .
•
I believe you previously said that you
started the website sometime in January
.
A Yes. I did .
•
So it would be fair to say that this
material that we're looking at now . Exhibit 58,
would have been developed sometime in January?
A I don't knoll . It could hate been -- it
1
could hate been deseloped on lanuart 30th . I
don't knots the dale .
•
Sometime in January . though
A Yes .
•
That's--actually, it's a fairly narrow
window given how imprecise some other recollections
have been .
1
You wrote this material, correct?
A Yes .
•
Then we go down two paragraphs to after
you've described what the county board restrictions
are and you write . This is unacceptable to us . It
is undemocratic and thwarts our power as citizens
to make elected officials accountable on election
day .
Did you write that?
A Yes .
•
"'bat did you mean by that statement?
A
I just meant is hat it Sat s
.
• Now, you understood at the time that you
wrote all of this material that the procedural
rules that you were not to be contacting county
board members outside the hearing process. correct?
A No .
•
You did not understand that?
A No .
•
Did anyone ever tell you not to contact
county board members outside the hearing process?
A No .
•
Then what portion of the restrictions was
unacceptable or undemocratic?
A
AA hal I ssas referencing sets that the_v tiers
not allotted to share their opinion .
•
It's your testimony that you never
24
understood that you weren't allowed to share your
opinion either
A
Ihat's correct
. I'm allotted to contact ill,
countv and elected olllciaL .
•
But you also understood that county
officials in this
--
county board members in this
process were to act as judges, right :'
A 1'es .
•
You even wrote that one of the rules here
was that county board members would be like judges,
correct ?
?
A l es .
•
Judges in your understanding rule based on
evidence, right?
A Yes .
•
They don't rule based on popularity, do
they?
1 No .
•
And Yet the Peoria Families website
encouraged people to contact county board members
to urge them to vote no to the expansion, isn't
that true
A
I his is a public process .
•
Isn't it true, though, that your website
encouraged members of the public to contact county
board members to urge them to vote no?
V Absoluleh .
•
You knew as you were doing that that that
was going against the county board members' role in
this process as being judges
A No .
•
1'on did not know that?
A 'I hat's not is hat I understand to he the
troth .
•
What do you understand to be the truth?
A I understand that this e us
--
that the\
st ere acting us judges . hilt this \\ a s a quasi
judicial process and that thev'rc also out' elected
officials and tic stcrc never
. cter precluded F0111
speaking to our public oflcials .
•
Where did you learn the term quasi
judicial?
\
I don't knots ss herc I learned that .
•
W hen did yon first hear the term ex parte
communications?
A
I don't knots .
•
Did you hear it --
were you familiar with
the context of ex parte communications during the
application and hearing process?
Pages 23 to 26
. . :OP.IA CISP'OSAO COM :-'A".NY
s
.
PEORIA
COUNTY
BOARD
PCB06-184
KIMBERLY CONVERSE
10-24-2006
A I don't rentennher w hen I did
.
(( onverse Ishihit No
.
it)
marked)
11) MR . Nit 1111 1 :R :
Q
Let me show you then Exhibit 59 -- let me
show' you then what's been marked as Exhibit 59 or
will he marked as Exhibit 59 . and this I'm going to
represent to you is what we believe to be what your
website -- what your website looked like as of
March 21st, 2006 . and ask you if that --
or just
a portion of it, if this is a true and correct copy
of what was on your website at that time?
recommendation made without knowing what all the
evidence was?
A No . that's not true .
•
\ on knew what all the evidence was going to
be as of,lanuary 31st?
A I did not know what all 01 tile ct deuce was
,-,one
to
h
e. n
o .
•
Ion
knew enough to have your mind made up
though, is that right?
A Yes .
•
Have you ever made any presentations at any
county board meetings?
-A
Presentations'!
•
Have you ever spoken at a county board
meeting?
\
l'es .
•
N hen?
A
luh ?0115 or the sunnnerol ?11115 . I don't
knnw it it 1%o, Iul\ or not .
•
Any time after that?
A
At a count\ hoard meeting . I don't believe
o . Arc
s ou talking about the hearings . too!
•
Not the public hearings . The regular
county board meetings .
A
Not to ills recollection .
•
Kim . did your website have a hit counter?
A I don't know .
•
Do you know what a hit counter is?
A I'rohahl y .
•
It's a device that lets you see how many
people access %our website, how many people get to
that page?
A You'd hat e to ask in husband .
P<, a, -
•
Did he ever tell you at any time the number
of people that were accessing the Peoria Families
website"
.
A
I don't recall .
•
Now, you testified that your understanding
of the rules was that you were free to present
information and make recommendations outside the
hearing process to county board members, is that
correct?
A Can you repeat the question?
•
Is it fair to say that you -- let me
rephrase it .
Is it fair to say that you understood the
rules that applied to you as a citizen to allow you
to contact county board members outside the hearing
process and present information to them outside the
hearing process?
A
I hat's a real long question
. l' an coo -- I
w mit to he --
want to make sure I'm hearing you .
',hut \out question k .
•
Let's have the court reporter read the last
one back .
1111
. W I INISS : I don't know it thafs
going to help .
Pages 27 to 30
2OP :Se
. . . COMPAtt
. . r-:UPTA :OUIIT'f BOARD
PCB06-184
i
A
't Cs .
Q Underneath the caption it says, Tell the
county board no toxic waste in Peoria, right on the
front page?
A lbs .
Q And on Exhibit 58, that was the same case?
A Yes .
Q That's because you wanted anyone that came
U
to your website to actually contact the county
board and urge them to vote no?
A ,\n> hod' whowantedto .yes .
Q \bu understood that the process was also
partly political, is that correct?
A
Q
What do sou mean ht 'parth political" 9
Y on really didn't want county board members
to vote on the evidence You wanted them to just
vote no, didn't you?
A
No . that's not true .
Q NN ell, the evidence hadn't even come in yet
as of January 31st, hat] it?
A
I beliete it hasn't due until
I' -
I ehruan 131h .
9
Q As of January 31st before the public
hearing started, you were urging the public to
contact county board members to tell them to vote
no, is that right?
1_
A Yes .
_'i
Q That obviously would have been a
~-
KIMBERLY CONVERSE
10-24-2006
•
Would that include county board members in
districts outside the one that you resided in
A
't c, .
•
Even though those officials were not
elected by you
A Correct .
• Did you also understand that in addition to
being allowed to contact your elected officials you
were allowed to present them with evidence or
information?
A No .
• Then what could you present your elected
officials with, if not evidence and information
A Our opinion and a e could refer them to the
record .
•
So you thought it was proper to in your
contacts with county board members to highlight
portions of the record for them?
A ((
ertainh would not he inappropriate .
•
Now, of what relevance would %our opinion
be in a county board contact outside of the
hearing?
A
Canon repeal that'
•
Let me make it simpler
. \ on knew from
having talked to Mr
. II rich and reviewed the county
rules that the county's decision was to be made
based on the evidence, right?
A Correct .
•
If the decision was to be made based on the
evidence, of what relevance would a county board
member knowing your opinion he?
A
It's important lot ,In ollicads to knot
\\ here
their constituents stand and how the
Collslittlene> urged them to pa\ attention to the
15
ev
Qidence Did
and
you
thewant
.
ladscounty
board members to take
P your opinion into consideration when you contacted
them?
A
N e wanted puhlic oficials to know that tile
public
thought this NN
as an important issue that
they should take serioush and pay attention to the
facts and the evidence on the record .
•
And to pay particular attention to evidence
that you might
highlight for them in a direct
it was --
and that would be the ,lanuarc 31st
website . if you look at that, there is something
identified as PD( toxic waste stacks in the
photograph .
A ) es .
•
Does PD( have toxic waste stacks?
A
It's nl\ understanding that \\c learned in
the hearing that that leas not the proper
tcrnlinolog\ and \\c changed it . the terminolog\ . or
it looks like vvc rcnioved it upon hearing that .
•
Who took this photograph by the wax?
A NI, lather .
•
Did you ever send an E-mail to county board
members advising them to disregard your previous
reference to PDC's toxic waste stacks on your
website?
A No .
•
Did you ever call any county board members
to say we alerted you to an incorrect fact?
:A No . It was all on the internet then to
sec
.
•
Well, the website changed, but it never
said the previous reference was incorrect, did it?
A No .
•
No it didn't or no I'm wrong
A
No . it didn't .
•
If I were to tell you that you appeared at
the county board meeting in February of 2004, the
regular board meeting, and spoke at that time,
would that refresh your recollection?
A I don't douht it
. I think I said thin
earlier . It aoulddl surprise me
. I just don't
renlenlher.
• Now, did you have an understanding of what
rules regarding ex parte communications applied to
Peoria Disposal Company?
A that applied to Peoria Disposal (lo» pam 7
•
Let me back up
. You've stated that you
thought you as a citizen were free to contact
county board members and direct them to certain
parts of the record and to give them your opinion,
correct?
A Can Non repeal Ihat'!
•
1'ou said that you believed that as a
Pages 31 to 34
'I .SP'SAL r
.oh^.PAtty
PerDP :r- COCIITI EOAPD
PCB06-184
I Record read as requested .)
communication, correct
[III : \kl IM SS : I Understood That I
A the\ should base their decision on all tile
could contact im elected officials
.
facts
.
BY MR . MI
:I:I ]_IfR :
Q Well, going back to Exhibit 58 . 1 believe .
KIMBERLY CONVERSE
10-24-2006
Company representatives had the same entitlement?
A
I -- sure . 'Cs,
•
So you thought that Mr . lleginnes and I
could also have had one-on-one contact with county
board members to give them our opinion
A Nehelie'edvou"crc .
•
Do you have any evidence, in fact, that
that was happening'
A hsidence?
•
l es .
A What constitutes em ideuce :'
•
\ on say you believed we were directly
contacting the county board .
('
an you give me an example of such contact?
A
I learned -- v es . I can .
•
Go ahead .
A I learned that Brian Meginnes had contacted
looking for?
A
Cindy Herman .
•
Do you know why he wanted to call Cindy
Herman?
A No .
•
Is she a member of Peoria Families!
A No .
•
What else was said in this conversation?
A I less as lookin!_ for %Is . I lei man's phone
numher . I don't remember it I had it or not . I
_ e don't think I did . and he shared that he had heel)
gettutu sienileant pressure from Rev stone
esecuusn . front Representative Leach . and then lie
said the comment about Mr . L.Isasser
Or
Air .Megtunes .
•
Did you say anything or did he say anything
else to you??
Pages 35 to 38
D : 3P"SF,L COMPAtt':
FED? 17, COUI;TY BOAPD
PCB06-184
2
Brian F Isasser to share that should he s me no the
pro-PUC camp nould insure that another Repuhlican
would run against Mr . Elsasser .
A
Q
A
Q
I'm sure hello and pleasanu, . I'm sure .
Did he indicate how he was going to vote?
No .
Q
Where did you --who did you learn that
Did you interpret the statements he made to
3 from?
you, however, to be indicative of the fact that he
4
A Mr . Elsasser .
was going to vote no?
5 Q
When did Mr . Elsasser tell you that?
A No .
e
7
A I don't know the exact date, It meframe .
Q Before the May 3rd meeting?
Q Can you give me any other examples of what
you believe to be an ex pare communication with a
8 A Yes .
board member from a representative of PD('?
4 Q When did you have a conversation with
A From -- to a hoard mcmhe'?
10
Mr . Elsasser before the May 3rd meeting?
Q l es .
11
A It was I believe -- I don't know . I don't
A No .
12
know if it was before the April vote or right
Q
So that's the only one that you are aware
13
after
.
of, and you got that secondhand?
14 Q
I think we're talking about the May vote
A Actaall' . can
v
oil go hack and ask me that
15 now .
question again?
-
16
A
Well, you asked the when it was .
Q Sure . Can you think of any other examples
17 Q
It might have been right before or after
of a PDC representative contacting a board member
18
the April vote?
1. = during the application and hearing process?
19 A Right .
A Iha'eoneexanpleol'PUC'representatises
20 Q Where did that conversation take place?
pruntoting contact ss ith the hoard .
21 A On the phone .
Q What is that example?
22 Q Who called who?
A Communications -- well . a meeting at the
23 A Mr. Elsasser called me .
cis tc Federation meeting and communication thin
24 Q
For the purpose of giving you this
ollnmed .
citizen you were free to contact counts board
information?
members and direct them to certain parts of the
A No .
evidence and to give them your opinion, right
Q For what purpose did he call you?
A
Entitled to . \cs
.
A
I Ic vsas looking Iora phone numher .
Q
Did you believe that Peoria Disposal
Q
Do you remember whose phone number lie was
KIMBERLY
CONVERSE
10-24-2006
qa
process to be as much political as adjudicatory, is
that fair?
A I don't know what -- I don't think I can
sav that word . Cyan sou tell me what It aI
items'
•
Judicial
.
A
Nocsthat WU'yetold methat
. wouldsou--
•
It sounds tome as if you believed that the
entire process was as much political as it was
judicial?
A I belies e that this process " :u to be based
on the facts
.
•
So my statement is not one that you can
agree with, is that correct?
A
I apologiic
. I don't -- not conithrtnhlc
enough with sour statement to ills \ CS or no
. but I
16 can tell'on''hat I do believe and that is that the
decision was supposed to he based on the facts and
_
the e' dence .
•
And that all of the people that were
2` contacting the county board to urge them to vote no
their views should not be taken into consideration,
is that right?
A the decision was supposed to he based alt
fuels .
Q Then what was the point of urging people to
contact their board members to tell them to vote
no?
A We believed it was important far the public
to he inyoled
. It was a public process alter all
and it ssas important 101 the counts hoard to know
that the puhlic scanted them to take this dins scrs
scriousls .
•
Well, You never urged on your website that
people contact the county board to tell them to
take their duty seriously .
You urged on your website that people
contact the county board to tell them to vote no
.
right
A N c urged theni to -- can sou repeat that
question.'
•
Did your website urge people to contact
county board members for the purpose of telling
them to take their duties seriously??
A N ell . we urged them ur comnwmcate that swe
hoped that they'd rote no based on the Iaets .
•
Did you hope or believe that hundreds of
people contacting county board members urging them
to vote no would be considered by those count%
board members in their decision?
A Well . PDC had hundreds of iorrn letters that
had been submitted that -- that we knew were on the
record . and so it was clear that the\ would know
front that amule that this was important to PDC . and
we wanted to he sure that the counts hoard
understood that this issue was important to the
people as well .
•
So the answer to my last question is yes?
A What was the question?.
MR
. MUELLER : Let's read the question
hack then .
(Record read as requested .)
THE WITNESS : We hoped that--
131 MR . MUELLER :
•
I think that's a yes or no question .
Either you hoped it or didn't?
A Put not going to answer yes or no . It's
not a yes or no question .
•
So the answer--your answer is you cannot
answer it yes or no?
A My answer is that I won't answer it yes or
no .
•
Can you answer it yes or no?
Pages 39 to 42
L15%056 :. CG :-0FA F,
FECF1A COUUT' DOARD
PCB06-184
3
Q
A
Q
When did that meeting occur?
I believe after the April sore .
How did you learn about what occurred at
-~ that meeting?
5
A
Several way s .
c
7
Q
A
Go ahead .
My father-in-la'y vv as in the audience for
8 the presentation which Peoria Families was not
`? invited to . That was one vva\ .
12
Q
What's your father-in-law's name?
11 A Ralph Conserse .
12 Q Did you hear about it from any other
14
sources?
A Yes .
15 Q
Who else?
16 A OSF Medical Center .
17 Q
Well, who at the medical center provided
1'
18
that information?
19 A Dr . Zwicky .
'-'
20 Q
So it sounds like you understood this
i
21 entire process to he as much political as
22 adjudicatory, is that fair?
23 A Can you repeat that?
24 Q It sounds like you understood this entire
KIMBERLY CONVERSE
10-24-2006
opinion of the public to be taken into
consideration by board members?
A
I wanted the facts to be considered . There
were plenty of facts to support a no vote
.
Q Can you answer the question? I'm going to
ask you a third time. Did you want the opinion of
rage
_,
the public to be considered by the county board,
yes or no?
A
I has c told ot' I'm not-- that is not a
acs or no question . You're u', rig to hits c me sit,
something that I don't -- I'm not willing to anss er
it the stay you „ant me to . \\'c can keep going at
this . hilt -- and I'm line with that .
•
lour website. however, and your
communications and F-mails always urged people to
-
contact the county board to tell them to vote no?
A Correct .
• After the April vote, did you send E-mails
thanking the county board members who voted
favorably to You for their vote?
A Yes .
•
What was the purpose of E-mails??
A I o thank them .
1?.
Q Did you understand that was an ex parte
1 "+ communication outside the hearing process?
A I didn't belie\ c it to he
C% parte. bill call
oil give me your definition ofes pane?
•
Apparently, you didn't believe it to be . so
you've answered my question .
A Well . I cannot go hack and --'sell --
had submitted its rccommendutions prior to
recci' inc our c' idctitiar stunntar, or-- and not
ha\ in,, had time w re' iew the e' idence suhmiucd h
.
\
Dr . I~red Lec .
•
Who hired G . Fred Lee?
A JON CC Bluntcnshinc .
F'a :e
•
On behalf of herself or the Sierra ('lab or
Peoria Families?
A I
beliesc
on hchall'ofall of us
. I clout
knoss Ito,v site
characterized
that .
•
Who paid for Mr. Lec?
\
toy cc .
•
Peoria Families did not contribute towards
his cost?
A No .
•
Who paid for Mr. \orris :'
\ Josce .
•
Did Peoria Families contribute toward
Mr. Norris's cost?
\ No . not to ill, knowle(1ge .
IConserse Group Ilshibit No . 60
marked)
BY Mit . MtiFI .I .LR :
•
Let me shoss you a group exhibit which we're
going to mark as number 60 . These appear to he
F-mails from you all dated :April 7th to
Mr . Salter, Mr. Phelan, Mr. \\ illiam s and %Jr. \layer,
and ask you if, in fact, you wrote each of those
1-mails to them .
A W fitness perusing document .
)
Yes . I did .
Pages 43 to 46
PEORIA DISPOSAL COMPANY v . PEORIA COUIITY BOARD
PCB06-184
A No, I won't .
Q
Won't or can't? Do you understand the
difference between won't and can't?
Q Did your husband also write thank you
letters to the board members who voted favorably
for you in April?
A Why don't you explain that?
Q Well, if you can't answer it, it's because
A
Q
I bchc' c so . I'm not Sure .
By the way, which county board members did
you're unable to . If you won't, it's because you
can but you're unwilling to .
you speak with on the telephone during the
application and hearing process :'
A You will -- it is not a yes or no question .
\ Brian I :lsasscr and lim I homas
.
It's unanswerable in the context that you're
Q Anyone else?
requiring me to . So whatever you want to call it .
A No .
that's --
Q When did you speak with Jim Thomas?
Q Did you want the opinion of the public to
A It w as either the 28111 or the
_29th of
be taken into consideration by county board
members?
March . It's on the public comment jr,' roterence Lo
the call . So you prohahl, know already .
A I wanted the count\ hoard members to know
Q Who called who
that the public cared about this issue and ,canted
\ I called him .
them to take their duties seriously .
Q For what purpose?
Q Let me ask you again
. Did you want the
A I o express Concern that the count, stall
KIMBERLY CONVERSE
10-24-2006
MR . MUELLER : Mr . Wentworth .Ihe\'re
all copies of the same thing . I have multiple
copies there .
MR . WENTN'ORTH : Forthe record .
the_''ve got 173 . 174 . 175 and 176 on them .
MR . MUELLER : Right .
BY MR . MUELLER :
•
Did you write to other board members on
April 7th besides the ones that we have?
A I wrote to all of the people that voted no
is nmy recollection .
•
You believe that your husband, likewise,
did the same thing?
A I think he did . I don't know for sure .
•
Did you also encourage others to send a
note of thanks to the county hoard members who
Noted no?
A Yes, l did .
•
In fact, you encouraged that on your
website, didn't you?
A Yes .
(Converse Exhibit No . 61 marked)
BY MR . MUELLER :
•
Let me show you next what's going to he
1 marked as Exhibit 61, and ask you if that is a
2 document prepared by you
.
3
A No .
4
Q It's a two-page document . Who is it
5
prepared by?
6
A It was designed by Tessie Bucklar
.
7
Q Who was it printed by?
8
A I don't know .
9
Q Who was it distributed by?
10
A It was distributed at the Sandra
11 Steingraber event .
12
Q The second page of it says, For more
13 information, visit our website
14 w ww .notoxicwaste
.org
.
15
A Yes .
16
Q Is Tessie Bucklar a member of Peoria
17 Families?
18 A Yes .
19
Q
Was this document actualIN although
20 designed by her a Peoria Families' document?
21
A Yes .
22
Q This contains the contact information of
2 3 certain county board members, correct?
24
A Yes .
Q And a recommendation that those who would
receive this document contact those county board
members and encourage them to vote no again on
Mav 3rd, correct?
A
1'es .
•
You did not consider such encouragement to
vote no as an ex parte communication, is that
right?
A Correct
.
•
Did anyone ever tell you that you shouldn't
=- be contacting county hoard members outside the
=_. hearing process?
A No . N e w crc allowed to talk to our public
ollieials .
MR . A I NTNUR I I I : George c ou said that
was a group exhibit . N e lust had two pages here .
MR . M11':F LLIR : the Iast one-- no .
that's a single exhibit . the group exhibit . I was
answering Ianuki's question . the group of liter
letter, that I show cc] 'ou .
MR . NI :NI N( )R I 11 : So I'laintill's
I~xhthit 61 is not a croup exhibit"
NIR . Ml111LFR : Just a single exhibit .
BY MR . kit !I I.LLR :
•
Is Bill Rutherford a member of Peoria
Families?
A No .
•
Have you had any dealings with him in
regard to the opposition to the expansion?
A Not with him dircctl) .
•
What do you mean by indirectly??
A One of our members had approached him ahout
a donation . but I don't csen think she talked to
hint directlc .
•
Do you know if Bill Rutherford has donated
any money to this opposition?
:A I don't hitse direct k nowledge . n o .
•
Do you have indirect knowledge or belief"
A
I think he-- I think it was his intent to
donate to Tom Ldwurds . hut I do not know
.
•
Do you believe that he's subsidized Joyce
Blumenshine's expenses for billboards and experts?
A No .
•
Do you know where Joyce Blumenshine got all
of that money which we estimate to be above
$40,000?
A It's my understanding that she had in)
Pages 47 to 50
C=SPOSA'_ COMPANY
PEORIA. CCGr :TY BOARD
PCB06-184
KIMBERLY CONVERSE
10-24-2006
the maker of the yard signs?
A No .
•
Is this a yard sign that I'm holding up for
you that was made by Peoria Families (indicating)?
A
It is
.
•
Y on don't know who made them?
A I don't knoo the nanic of the compam that
printed t hem . n o.
•
Who paid for them?
A Peoria Families .
•
Who designed those yard signs?
A
I cssic Buckler .
•
I think I might have asked you this . Is
she a relation of _yours
A
Indirectls
.
•
What is her relationship with you :'
A
My sister-in-lass is her sister-in-lass
.
•
Who's the common person there? \ ou've got
me lost there .
A
M' sister-in-lass .
•
And that would be?
A Aim Schlicksup .
•
So you're Amy Schlicksup's sister-in-law
and so is Tessie Bucklar?
--1
•
Why don't you tell me what you were
thinking of that was E-mailed to
n
otoxicwaste .or g?
A Someone h-mailed into n otostcssastc
.or
g
ahout the contact -- contacting Diane Brinkman
.
•
Do you know who that person was??
A No .
•
Did you then contact Diane Brinkman\
A U c had hebore .
•
How did you know to contact her?
A los cc had something tt ith regards -- sonic
report related to Diane Brinkmani
and she or
someone ss it hin the clott had contacted her at one
time .
Q Did you ever go to any board members' homes
during the application and hearing process?
A No .
•
Did you ever deliver anything to any board
members' home?
A No .
•
Did ,you ever assist Tom Edwards in doing
any of those things?
A No .
•
Has Tom Edwards ever come to any of your
meetings
?
A Not to ans of our meetings than I rememher .
1Con erse (irottp l vhihn No . 62
marked)
BY MR . Mt l , l 11:R :
•
I'm going to show You what is going to be
marked as Group Exhibit No . 62, and that's your and
Dave's copy to keep . I will tell you that these
are various E-mails provided by -- printouts of
various E-mails provided by Joyce Blumenshine .
My simple question for you is to look
through these, and you will notice that you are a
listed author at various places, and all I want to
know is whether the portions that purport to be
Pages 51 to 54
P0701k. DISPOSA_ 'CMPANP
PEORIA COUNTY BOARD
PCB06-184
inheritance .
Wisconsin EPA or DNR from a Diane Brinkman
Q Did Peoria Families have any involvement in
A
Q
Yes .
yard signs?
How did you come into possession of that
A Yes .
letter?
Q What was your involvement in yard signs?
1 It s'as I'-muilcd to notoyicoastcor_e .
A N e got sand signs to distribate .
t Q Do you know from whom
Q Who made the yard signs?
A Just the name--'bat s\as it :'
A You mean the compam that printed them :'
Q Diane Brinkman?
Q Yes .
A Oh . oh . wait a minute . Can )ou repeat what
A I don't knoss .
N
0u're asking :? I osas thinking of something
Q Were you the person that contracted with
difleient .
A Correct .
2 Q When did she get involved in the
1 1 opposition?
1+
A
Q
I don't rememher exactls ss hen
.
Did Converse Marketing provide any support
i
to the opposition effort
A No .
1`
iQ
A
Who designed the billboards?
Well . ullimatel\ . Adam's Umdoor
21
A Adscrtising wits the design that sse selected .
Q
A
Q
Who did the selecting?
My hushand and .10-\ Cc BILIMICIIS11111C .
Do you remember having a letter from the
KIMBERLY CONVERSE
10-24-2006
A 'That was the time to has c et idcncc --
where
cs idcncc could he considered .
'\ Yes .
Q Now, you previously told me that all you
Pages 55 to 58
-FP -,_ cOM "At:
; .
. P'1'RU
. COUniY P CAP U
PCB06-184
written by you are accurate .
Q However, you did not understand that date
A IAA imess perusing documents .)
Yes .
to cut You off from communications with hoard
IC on'erse I .shihit No . 61 marked)
members, did you?
BY MR . MI l1I.I.IJ( :
A No .
Q Okay . I made that very easy . Then I will
MR . Mt'I :1 .I .1 :R : Let's take a short
show you Exhibit 63 which purports to be an E-mail
from you to James Thomas on March 29th and ask
you if, in fact, you sent him that E-mail .
break . \\ c m:n he ten close it, linishine .
(Reces, boat 5 : I5 to 530)
MR . MI 1 1 .1,1?R
: Back on the record
.
A
BY MR . 11l'I-.I .I .11k :
1 es . I hat's the one I relcrred to earlier.
Q That's what we thought . NAe're cleaning up
Q Let me show you what looks like a handout,
17
21
the record .
Did you or any member of Peoria Families
make any political contributions during the past
1=
1'.
I
.
2P
Tell the Peoria County Board vote no
. and has
the
n otoxicwaste.org web address on it .
Is that a document prepared by Peoria
12 months to any Peoria County Board member?
Families
A Did I oramonc Gom our croup .'
Q Yes .
A Not to in, knottledge . bill I don't knot' what
V 1'a .
Q Who wrote it
?
A I helievc a number of us shored in the
other people has e d one . t o
at
s knots ledge .
ttritingol it .
Q The Peoria Families group itself did not
Q
How was that document distributed?
make any contributions?
A
Anumberofdillerenhuts .
\k chad it at
A Oh . no .
Q You didn't?
A No .
Q lour husband didn't?
A No .
Q Did you ever communicate either directly or
N arious c\ cnts
. Sandra Slcingraher and people used
it for going door to door
.
Q So would that document have been circulated
in the March-April 2006 time period
:'
Pda,
A I don't knots Mien o e created this . but can
tsc tell :' ('ertainh helme the 29th . N rs . March
indirectly to any board member that if they did not
and April tort sure .
% ote no they would have opposition in the election?
Q I mean, were you handing that out to people
A
Q
Not to inv knots ledge .
Do you know who designed and paid for the
at the St . Patrick's Day parade?
A Fcs .
stop hazardous toxic waste bumper stickers?
Q .Again, that one says . Tell the county board
A
Q
A
No .
Were they a Peoria Families product?
No .
1 ('
to vote no .
You thought it was appropriate to have the
public tell the county board to vote no, right?
1' Q Do you know who Meg Whitmer is:'
1
)'es .
12 A No .
Q To do so outside of going to the public
'. 4
MR . WIIN'"I'WORI11 : Merle Widmcr .
hearing to make a public comment?
TI II'. \\'fl'Nf:SS : Merle Widmcr :'
A Can s ou repeal the question?
11
BY MR . MtilLI .FR :
1 r.
Q It was okay to tell the county board to
Q
No. Meg Whitmer, W-H-1-T-M-E-R .
vote no in a direct communication to their home or
1 S'
A
Q
No .
In a number of your E-mails, we've seen
phone or E-mail address rather than at the public
comment period reserved for statements of opinion?
references to wanting to get things done before the
A \\
c though
t it ssas okay l6r the public to
20 public comment cutoff date
.
communicate tt ith their elected officials am time .
1
What was the significance in your mind of
Q That would include communications urging
22
that public comment cutoff date?
2 z the public official to vote no?
KIMBERLY CONVERSE
10-24-2006
wanted the county board to realh do was to base
their decision on the facts, right?
A
AA e scanted the countv hoard to lodge the
decision hased on the I'octs .
•
Is a public opinion a fact?
A I don't knoo hots to ansocr that .
•
Well,--
A I don't knmt 'shat oul-e asking .
•
Did you hope the county board members would
1 S include in their considerations all of these
expressions of public opinion that you were
encouraging people to make?
A
AAe hoped thin the counts hoard ssould tote
no hased on the facts .
•
The phrase based on the facts doesn't
appear on this flier . does it?
A A ell . I'd hate to read through AW e listed
t arious facts on one side of here . I don't knoss
ss hat s ou're asking .
•
But the phrase based on the facts doesn't
appear on that flier?
A
AA ell
. sse talk here-- sse inform the readers
of this that the counts hoard is ill determine
findings of fact on April 61h .
•
So the answer to my question is the phrase
based on the facts doesn't appear!
A I can't anssscr that unless suit slant me to
read through all of this . I can't ansster that .
•
Well . the document will speak for itself .
W'ho wrote the evidentiary summary that
t
Peoria Families submitted?
A Primarih Brad Stone .
•
Who assisted him in writing that?
,A All of us in one ssas or another .
•
There was recently a presentation made to
the IEPA on facility issues pertaining to the
Peoria Disposal Company permit and that purports to
he signed by Heart of Illinois Sierra Club, Peoria
Audubon Society and Peoria Families Against Toxic
Waste .
Are you familiar with that written
presentation made?
1 \ es .
•
Who physically prepared that document?
A Brad Stone
.
22
Q Has Brad Stone been compensated for any of
23 those efforts?
24
A No .
1/
Q Who is Brad Stone?
A A member of Peoria Families Against Toxic
W aste .
•
Does he live in Peoria?
A No
.
•
W here does he live
A Wisconsin .
•
How did he get involved with the Peoria
Families Against Toxic \ astc organization?
A He came to a hearing . I believe .
•
Has he ever lived in Illinois?
A Y'es .
•
Has he ever lived in Peoria?
A Yes .
•
When?
A This tear .
•
W'ho does the fact checking for statements
made in materials that you disseminate to
organizations such as the IEPA?
A Multiple people .
•
Have you personall been involved in any of
doing that fact checking .!
A What time period?
•
Well, let's talk about this document
submitted to the IEPA .
No .
•
Do you have any authorship interest in that
document at all?
A
I read it hctbre it tsar final .
•
Did you have any authorship interest in
that document :'
A No
. What does authorship interest mean :'
•
Did you contribute any editorial content?
A I think I s oted on 'c hat the cot cr page
ssould sot . the name of the Document .
•
You voted with who:'
A
\k e ll . a
n informal tote ssith our memhers .
•
Who were the individuals that voted on that
document?
A It seas not a formal %ote. but the people
that sscrc ins ohed in the discussion as I recall
sscrc Brad . Tcssic . .tovce . I don't knoss if there
ss cry others .
•
Do you have current contact information for
Mr . Stone?
A No .
•
Well, how do you get ahold of him
A
I Ic's in our Peoria I amilics li-mail list .
Pages 59 to 62
DISPOSAL COMPAttY v . PEORIA
COUNTY BOARD
PCB06-184
KIMBERLY CONVERSE
10-24-2006
MR . MIIICIf I R : AIr . Rcntvwrth . we could
do a subsequent subpoena or I can pmt ask roil it
~ ou'II pros ide contact mlorntutton for Mr. Stone .
MR . U IINI \\ ( )R "I I I : Yes_ to the cstenl
that vve have it . I don't think she ryas being coy
about it . I was giggling, because I think that',
the only was ae llae to real)v get ahold of him
.
\\ e'll check and ask around and see it \ce can't get
V Ou an address .
131 IVIR . Mt'II .l .l'R :
•
Did yon exercise any editorial control over
the contents of the evidentiary summary??
A Yes .
•
I don't know if I asked this before, I
_
might have, the little flier that was Exhibit 64 or
65?
MR . NN ENTWORTH : 64 .
BY MR. MUELLER :
•
Who was the author of that?
A Oh . soil did ask . I belie' e . II vcas a
numhero(us as I recall .
•
You indicate that you've raised between
25 and $28,000 or that's what you currently have on
hand
A That's what we raised .
• Can you give me the names of contributors
to the organization who gave more than $1,000 or
more?
A OSF . St . Francis Medical Center. Proctor
A There may have been more that were a
thousand . I believe that Joyce may have found some
donations that were . like . 2 .000. but I don't
remember .
(Converse Exhibit No . 65 marked)
11) MR . Mt 11111 R :
•
Let me show you what we're going to mark as
Exhibit 65, and this was among the documents
presented by you today .
11 'ho prepared this document?
A
I don't kilovv .
•
Do You know if it's a Peoria Families
document?
A I don't kilovv .
•
If You go to the backside . there's a
reference on the very bottom, Other alternatives to
Caterpillar.
Do Non see that?
A Yes . I do .
•
What does that reference refer to :'
MR . WI NTV4 OR I11
: AA hat doe, it ,av of
vv hat doe site know :'
.
131' MR . MtII!I .1 .I'.R :
•
What is Sumpter. NC, North Carolina?
MR . AA IA T\AY)R I11 : 11 oil know .
'I 111 : 0\l l M:SS : \\ ell . that"
\\
hat it
sans .
11) MR . Mt 11 : 11kR :
•
Is there a Caterpillar plant in North
'- Carolina?
A There', se\ crul . \ e .
•
Is there one in Sumpter
A
I think so
.
•
Did you provide the information for that
131' MR . sell 1 :11I :R :
•
Let me then show you as a Group Exhibit
No . 66, just one exhibit, No . 66 which again
appears to be a printout from your website as of
March 13th . 2006 .
Pages 63 to 66
FSSA- '.O . .i . .1 :
. . PHOP :A COUNTY BOARD
PCB06-184
Hospital . the physicians of OSF Hospital . the
physicians of Proctor Hospital .
statement :'
A
Q
No .
Q
You're an employee of Caterpillar, is that
A
Q
Any others?
Not that come to mind .
flow much would the contributions of those
correct?
A
Q
Yes .
four groups have been?
You're aware that Caterpillar supported
A
Q
A
Q
A
Q
Singly or total?
For each one?
One thousand .
So the total of those four is $4,000?
Correct .
And the remainder of your money has been
1- .
this expansion?
A
Q
I ant .
Do you know whether the statement about the
Sumpter, North Carolina, facility achieving
100 percent recycling of hazardous waste is true?
A
I don't knovv .
t(onvelse (romp Nhihit No . 66
marked)
raised in contributions that were less than a
thousand?
KIMBERLY CONVERSE
10-24-2006
Is that a true and accurate copy of your
wehsite's content as of that date?
A
Seems to be .
(( 'on'cise I(shihit No . 67 marked)
B1' NIR . Ml LIJJIR :
•
This is actually material that you
provided
. Then let me show you what's going to be
marked as 67, again, from the materials that you
provided us and ask you if you can identify this .
A (W uness perusing document .) 1'es .
•
Is the Jeff Joyce referred to here a State
-= Senator? Excuse me-- isn't there a Senator Joyce?
This Jeff Joyce is a county board member?
A
1'es .
•
Did you, in fact, send these E-mails to
him".
A Yes .
•
Did you then also send an E-mail to
Mr. Widmer?
A Yes .
•
What was your interest in learning_ the
position of these people?
A
I wanted to learn the position otthose
people .
•
For what reason?
A To learn the position .
•
Also one to Mr. Thomas . Did you write to
him as well?
A Yes .
•
What did you intend to do with the
knowledge that you gained from learning their
position if they were to tell you that?
A I didn't intend to do anything with it .
•
This is pure curiosity?
A Yes .
•
These are accurate, correct, these F-mails?
They accurately reflect what was written?
A
Yes .
•
Did you send those to other board members,
also?
A I sent them to all of them
.
•
All board members were asked what their
position was?
A Yes .
•
How many responded to you?
A Four.
•
Who were the ones that responded?
A Jeff Joyce
. Merle
\\
idnier, Jim Thomas and
Brian Elsasser .
•
We don't have Air
. Elsasser's . do we?
A I ie Called me to respond .
•
When did he call you?
A It t\
as around this date. I don't know the
e\nct date
.
•
Around January 27th?
A \Ys
•
What did Mr . Elsasser tell you when he
called you?
A
I hat he could not share his stance and
that . indeed . lie didn't lime a tance Net because
he had to go to the public hearing and hear the
)acts .
•
I on indicated that :11r . Thomas and
Mr . Elsasser are the only board members you've ever
spoken to on the phone during this process?
A
I hat's correct .
•
Is that still your recollection?
A
I hat's still ms recollection
.
IConserse I-.vhihit No
. 68 marked)
BY MR . Mt FI .LER
:
•
Let me show you then Exhibit No
. 68. This
is a group exhibit . It's among the documents
provided by you, and just ask you what this
represents .
A
This communication is from -- to and from
notoxIcwaste .oru .
•
Did these communications represented in
these group exhibits accurately or do those copies
accurateh, reflect the communications?
A Y es .
•
There's one specifically here that would be
a couple pages from the end . This is three pages
from the end that is an E-mail from
infoainotoxicwaste.org, which we've already
determined to be you, and it starts out with,
Absolutely, here we go
. Please also contact Eldon
Polhemus
. He was sick, et cetera .
Is that an E-mail written by you?
MR . WENTWORTH : For sorry . I had her
on the wrong page .
THE WITNESS : Yes .
BY MR . MUELLER :
•
Who was that E-mail written to?
A Cathy Schultz .
•
I see the E-mail address, but do you know
who the person is that that E-mail represents, the
Paqes 67 to 70
PP:JP :A EISPOSAL
COMPAIJI
PEOR:A COUNTY BOARD
PCB06-184
KIMBERLY CONVERSE
10-24-2006
1
don't have any more questi(ns .
2
(Further deponent saith not .)
3
9
6
7
8
a
E-mail address represents?
A It says Cathy Schultz .
Q Do you know her?
A No .
(Converse Exhibit No . 69 marked)
BY MR . MUELLER :
Q
The last but not least number 69, it's
another group exhibit with some copies of some
F-mails .
Simple question is, are these accurate
copies and do they accurately reflect the senders
and the receivers and what was written?
A 1'es .
MR . WENTWORTH : Forthe record .
there's 1 ;
pages in plaintiffs 68 .
MR . MUELLER : Right .
MR
. WENT WORTH : In Plaintiffs 69
.
there are just three pages .
MR . MUELLER : 69 is just three .
MR . W'ENTW'ORTH : We'll get you what we
have for Brad Stone .
(Pause in proceedings . )
MR . MUELLER : Back on the record .
Kint, thank you very much for coming . I
Pages 71
to 72
llSPOSAL COMPANY
.^-ECPIA COUNTY BOAPD
PCB06-184
KIMBERLY CONVERSE
10-24-2006
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KIMBERLY CONVERSE
10-24-2006
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Exhibit 21
10/27/06 Ted Converse
Condenselt"
a'
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page 1 -
Page
4
Page 3
INDEX
Tea Converse
0/Zt/O6
W :'NESS,
Paqe
BEFORE 'HE ILLINOIS POLLUTION
CONTROL BOARD
4
TED CONVERSE
Examination by Mr . Mueller . . .
4
5
6
PEOH :A D :BPOSAL COMPANY,
ORIGII ~__j 9
EXHIBITS :
I
No . PCB 06-184
EXHIBIT 95
13
E-moils
EXHIBIT 96
70
E-mails
Respondent .
THE DEPOSITION of TED CONVERSE, a witness
herein, called for examination pursuant to notice and
the Supreme Court Rules as they pertain to the taking of
Anoe:4 C . Jones, CSR, HER, and a
Lo-1, It Tasewel1, State
.rs
„ October 21, 2006, at 416 Main
:tree„ Suite 1400, Peoria, Illinois, commencing at the
hour of 10 :10 a .m .
20
P2
NOTE : Exhibits retained by Petitioner's Counsel .
Page 2
APPEARANCES :
SEOR(.k. Y .. i .IER . ESQUIRE
526
L . .
.
.
Uuere, Illinois
t, Suite
61350204
and
6
JANAMI NAIR, ESQUIRE
BRIAN J . MEGINNES, ESQUIRE
'
Elias, MegirHos, Riffle 6 Seghetti, P .C .
416 Main Street, Suite 1499
P
Peoria, Illinois 61602
111 Ha .^,
n . the Petitioner :
>;.1 :" A BROWN, ESQUIRE
Biace, Black I Brown
:01 South Main Street
Morton, Illinois
61550
Ou behalf of the Respondent ;
DAVID L . WENTWORTH II, ESQUIRE
Hasse .herq, Waliems, Grebe,
Encdgrass s Birasatl
124 So :.4hwest Adams
Street, Suite 360
Pen;, a, :liinoin
61602
Dr, beta It of Ted Converse
;
ALSO PRESENT :
ROYA : CO11L'.ER, PDC
JEEP CCL'L- EH, PDC
PDC
Page 4
I
(Witness sworn .)
2
(Ms. Nair not present .)
3
TED CONVERSE,
4 called as a witness, after being first duly sworn, was
5
examined and testified upon his oath as follows
:
6
EXAMINATION
7
BY MR . MUELLER :
8
Q Would you state your full name, please?
9
A Edward Bodman Converse .
10
Q And how do you want to be addressed?
11
A You can address me as Ted.
12
Q Thank you . Are you here with your attorney
13 Mr. Wentworth?
14
A
Yes.
IS
Q What is your address, sir?
16
A 1420 West Parkside Drive, Peoria, Illinois
.
17
Q And how long have you resided there?
18
A About four years.
19
Q What is your telephone number, sir?
20
A (309) 671-9901 .
21
Q You reside with your wife Kim Converse?
22
A
Yes, I do .
23
Q And do you have a personal e-mail address?
24
A I do.
10/27/06 Ted Converse
Condensellt"''
Page 5
1
Q What is that?
2
A T edconverse@mac .com .
3
Q Do you also have a business e-mail address?
A I do .
5
Q What is that"
6
A Tedc@conversemarketing .co m
.
7
Q What is your educational background?
8
A Graduate from the University of Illinois,
9 liberal arts and sciences .
10
Q
Where arc you employed at the present time?
I i
A Converse Marketing .
•
How long have you been employed there?
13
A About two years .
14
Q When did you graduate from college?
15
A '93 .
16
Q Where were you employed between '94 and
17 2004?
18
A I worked for -- as a bartender at a
19 roadhouse in Palmer, Alaska, for a year, '96 to '97, I
20 believe ; and I worked as a graphic designer at Colle
21
McVoy in Minneapolis, Minnesota, prior to moving to
22 Peoria
. Then I worked as a free-lancer for two years
23
prior to joining Converse Marketing .
24
Q And free-lancer in what field?
12
Page 6
1
A Graphic design .
2
Q What's your duty or title at Converse
3 Marketing?
A Graphic designer, web designer .
•
Is that business owned by your parents?
6
A
I believe it's owned by Jane Converse .
7
Q And that's your mother?
8
A Yes .
9
i0
operation of the business?
II
A Yes .
12
Q Did Converse Marketing provide any
13 materials or services to Peoria Families Against Toxic
14 Waste during the landfill hearing process?
15
A No .
16
Q Did Converse Marketing print any fliers or
17 handouts or cause to have them printed?
18
A No .
19
Q Even on a paid basis'?
20
A
I don't understand that question .
21
Q Well, I mean, did Peoria Families or any
22 other group ever contract with Converse Marketing to
23 provide any expertise, materials, or services?
24
A No .
•
Is she still active in the day-to-day
Page 7
2 around 1998, '99 time period .
3
Q Had you ever been active in any
4
environmental cause or on any environmental issue prior
5 to the PDC expansion?
6
A No.
7
Q When did you first learn of the
PDC
8
expansion?
9
A I went to a Sierra Club meeting at Forrest
10 Park Nature Center .
11
Q By the way, do you have any specialized
12 knowledge gained before the PDC
application regarding
13 waste disposal or waste handling?
14
A No .
15
(Ms . Nair enters the deposition
16
suite .)
17 Q Do you have any specialized knowledge
18 gained before the hearing regarding heavy metals,
19 asbestos, or other toxic materials?
20
A
Other than my daughter having an elevated
21
lead test, that's it .
22
Q You don't attribute that to anything PDC
23
did, do you?
24
A No .
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page 5 - Page 8
1
Q Would the same answers be true if 1
2 substituted the Sierra Club for Peoria Families?
3
A Yes .
4
Q And also Citizens For Our Environment?
5
A Yes.
6
Q Do you know where the small handoutlfliers
7 that the people gave out door to door were printed?
8
A Various places, people's houses, Kinko's,
9
Q Let's go back for a second to your jobs
10 before Converse Marketing . You indicate that you lived
11 in Alaska?
12
A
Yes .
13
Q
Your father-in-law in his deposition
14 indicated that there was something about your Alaska
15 experience which caused you to become interested in
16 environmental issues .
17
A I just like the outdoors .
18
Q Was there anything other than Alaska being
19
the great outdoors that specifically caused you to
20 develop an interest in environmental issues?
21
A No .
22
Q Are you a member of the Sierra Club?
23
A Yes .
24
Q How long have you been a member?
Page 8
I
A I don't know for sure, but I think roughly
10/27/06 Ted Converse
Condenseltn"
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page 9
- Page 12
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Page 9
Q And your wife testified that to her
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Page 1 I
Q Who offered or added the substantive
knowledge your daughter's fine and no lasting ill
content on the site?
effects
. Would you agree?
A I agree .
Q Who formed the Peoria Families group?
A My
wife, I, and it's really hard to
A Primarily my wife, but I think information
came in from many sources .
Q And did you provide some of that
information?
remember exactly how it formed
. It was really kind of a
A It's possible .
Q The website, is it still active?
A No.
Q When was it taken down?
A This summer.
Q Is there a reason why it was taken down?
A It was after the vote, and I didn't pay the
monthly maintenance fee for it .
grass roots thing where people just kind of came
together
. It's really hard to answer that question .
Q Well, when did that group, as you say, come
together?
A
Sometime in January of this year .
Q At that point, were you already in your
mind an opponent of the landfill expansion?
A
Q
Yes .
Were you the one that brought your wife
Q Just out of curiosity, what does it cost
per month to maintain a website of that size?
into the process?
A
One of the ones .
Q Who else would have brought her into the
process?
A John McLean .
Q Anyone else?
A Not that I'm aware of
.
Q Did you ever meet with any medical doctors
A
I think it's around $15 a month .
Q Is Peoria Families still an active group?
A Yes .
Q Did you, at any time prior to the hearings,
gain an understanding of what the rules were regarding
communications by citizens with board members?
A
Q
During the public hearing, yes
.
What was your understanding of what the
I
2
Page 10
to solicit their support financially or otherwise for
t
2
Page 12
rules were?
your efforts'?
A
I understand from -- understood from the
3
A
No.
3
county that the board members were to base their
4
Q When your father-in-law, Dr
. McLean, met
4
decision based on evidence from the public hearing .
5
with doctors to solicit their support, was he doing so
5
That's basically what I understood .
6
on his own or as a representative of Peoria Families?
6
Q Did you ever contact any board members
7
MR . WFNTWORTH : if you know
.
7
outside of the public hearing?
8
A
I don't know .
8
A I did .
9
Q
Do you know whether the Peoria Families
9
Q Who did you contact?
to
group directed him or asked him to enlist the support of
10
A 1 sent --
I believe I sent some a-mails to
1 1 the medical community?
11 all the County Board members
.
12
A I'm not aware
.
12
Q If you understood that County Board members
13
Q
Who is the leader of the Peoria Families
13 were to base their decision on what occurred at the
14 group?
14
public hearing, what was the point of your contacting
15
A
The closest thing you could call a leader,
15
them outside of the hearing process?
16 I would say, would be my wife
.
16
A
Well, I always understood it to be okay for
17
Q What role do you play in the group?
17
a citizen to contact their elected official .
18
A I provided layout help on occasion and
18
Q When you contacted County Board members,
19 technical help on the website,
19
did you urge them to vote no on the expansion?
20
Q
Let's talk about the website
. Who acquired
20
A
I did, yes .
21
the notoxicwaste.org
domain name'?
21
Q And did you want them to take your
22
A I did.
22
consideration -- or your opinion into consideration
23
Q And who designed the website?
23 along with everything else in reaching their decision?
24
A I did .
24
A I wanted to impress upon them the
10/27/06 Ted Converse
Condenselt
tt'`
Page 13
I importance of this issue to take seriously.
2
MR . MUELLER : Could you read back the last
3 answer, please'?
4
THE REPORTER
: "I wanted to impress upon
5 them the importance of this issue to take seriously
."
6 BY MR, MUELLER :
7
Q
Let me show you what we've marked as Group
8 Exhibit 95 . Actually, let me ask you first
: Did you
9 ever talk to any of the County Board members directly
10 either in person or on the phone?
I I
A Yes, I did .
12
Q Who?
13
A Brian Elsasser .
14
Q When was that conversation?
15
A Early April .
16
Q
Where did it occur?
17
A
Our house .
is
Q
Pardon me?
19
A
Our house, 1420 West Parkside .
20
Q How is it that Mr
. Elsasser got to your
21 house?
22
A
He phoned .
23
Q Okay
. So he wasn't at your house?
24
A No .
Page 14
1
Q It was a telephone call . He called you at
2 your home'?
3
A Yes .
4
MR . WENTWORTH : You had asked phone and --
5
MR . MUELLER : For a second there, I thought
6 1 had found a smoking gun .
7 BY MR . MUELLER :
8
Q What was the purpose of his call?
9
A
He was trying to track down a phone number .
10
Q And do you remember whose phone number he
I I was looking for?
12
A
I believe it was Cindy Herman.
13
Q Did you have a conversation with him about
14 the landfill?
IS
A
I had a brief conversation with him . Yes .
16
Q
Did you express your opposition to the
17
siting?
18
A No . I did not .
19
Q Then let me show you what we've marked as
20 Exhibit 95 and ask you to look at the first e-mail in
21 this group exhibit which is A . Purports to be a
22 letter --
an e-mail from you to Brian Elsasser?
23
A That is correct .
24
Q
Did you know him before the hearings?
Page 15
A No . I did not .
• Because I see you're on a first-name basis
with him . Is that just the informality of e-mails or
because you had some acquaintanceship?
A I had no acquaintance with Brian .
•
In looking over this e-mail, I can't find
in there any language even remotely similar to what you
had testified to about your communications, namely, that
you wanted to impress upon board members the importance
of their vote .
A Well, this is my opinion based on the
information that was presented in the public hearing,
and it is highlighting my opinion, the importance of the
issue for the county to take seriously .
•
Well, it's also communicating the fact that
you think the expansion is a bad thing, correct?
A Correct. I do .
•
You refer to lead paint dust is highly
toxic in minuscule amounts, for example?
A Correct
.
• Would it be fair to say the point of this
e-mail was that Mr
. Elsasser would consider its
contents?
A Yes.
Page 16
•
The next document is an e-mail from you to
Dave Williams?
A
Yes.
•
Is that also a true and correct copy of an
e-mail that you sent?
A Yes.
•
And the third and fourth ones, C and D, are
they also true and correct copies of e-mails that you
sent?
A Yes .
•
On your website, who did the fact checking
of materials on the website itself?
A It was a group effort .
•
Who was in the group that made that effort?
A
Primarily the core members of Peoria
Families Against Toxic Waste .
•
Who were the core members?
A
Kim Converse, Ted Converse, Tessie
Schlicksup (sic), Brad Stone, Cara Rosson, and I'm sure
there are more .
•
When
you say "Tessie Schlicksup," you mean
Tessie Bucklar?
A Correct.
•
We've previously marked as Exhibit 58 a
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page
13 -
Page 16
10/27/06 Ted Converse
Condenselttt''
Page 19
A
The network solutions had a tracking page .
Yes .
•
And did that allow you to identify the
internet locations from which hits came?
A I wouldn't know .
•
Do you know how many hits the website got
before it was taken down?
A No . I do not
.
•
Did you ever access that counter
information at the host?
A I did one or two times at the initial
launch of the site .
•
And what information did you get when you
accessed it early?
A A bunch of information I don't really
understand.
•
Well, did you get any information about
traffic on the site?
A There were hit count numbers . Yes .
•
What kind of numbers did you see at the
time that you looked?
A
I don't even recall .
•
I guess just in a general way, were you
getting dozens of hits or hundreds of hits or thousands?
Page 20
A I really don't understand .
•
Let me show you what's been marked as
Exhibit 96, and this is not a group exhibit . It is just
a single exhibit . I'll ask you if that is a true and
correct copy of an e-mail string that you were involved
in .
A It appears to be .
•
How active was Joyce Blumenshine in the
Peoria Families effort?
A I'd say she was off and on .
•
We understand from testimony of others that
she was the major financial benefactor of the opposition
effort
. Would you agree with that characterization?
A No .
•
Who would you say the major financial
benefactor was?
A Peoria Families Against Toxic Waste raised
their own funds to support their own activities .
•
Who provided for the billboards in Peoria
County?
A Joyce Blumenshine .
•
Was that a Peoria Families' effort, though,
in terms of design and so forth?
A Actually, she worked directly with Adams
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page 17 - Page 20
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Page 17
copy of what purports to be a Peoria Families Against
Toxic Waste website as of January 31st, 2006 . 1 see
Mr . Wentworth has it .
A Yes .
Q What I'm interested in is the picture on
l
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the first page which points to an area at the right-hand
side of the photographs and is designated "PDC
toxic
waste stacks ." Do you see that?
A I do .
Q Who provided the information for that
label?
A I did .
Q You're the one that labeled those items on
the right-hand side of the photograph as
PDC toxic waste
stacks?
A Yes, I did .
Q And where did you get the information from
that they were toxic waste stacks?
A I was basing it off of information of the
TRI reports that indicated toxic air emissions .
Q On the second page of the website is a
photograph also, and on the left-hand side is a label
for a portion of the photograph and it's called toxic
waste stacks . Who provided that label?
1
Page 18
A
I did .
I
2
Q Did you ever check beforehand with PDC or
2
3
any of its representatives as to whether or not the
3
4 items that you were labeling as toxic waste stacks were, 4
5
in fact, toxic waste stacks?
5
6
A No.
6
7
Q You understood that the information, once
7
8 it was on your website, was in the public domain?
8
9
A Yes .
9
10
Q Did you ever take any steps to make the
10
1 i Peoria Families website more readily accessible through 11
12 search engines such as Googles engine'?
12
13
A No.
13
14
Q Do you know what I'm talking about?
14
15
A Search engine optimization, yes .
15
16
Q You didn't do any of that?
16
17
A No.
17
18
Q
You didn't register any key words like
18
19
"toxic dump" or anything like that?
19
20
A No.
20
21
Q
Did you have a hit counter on your website? 21
22
A No.
22
23
Q Were you able to determine in any other way 23
24 how many people visited the website?
24
10/27/06 Ted Converse
Condenselt""
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page 21 - Page 24
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Page 21
Outdoor Advertising to concept those billboards, and I
offered my help as more of a consultant role in those
billboards .
Q Were you the designer of the yard signs?
A
No .
MR . MUEL1 .E.R Mr
. Wentworth, do you have
Numher 66?
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answer?
A
Q
Page 23
Peoria Families
.
And would that again be the core group that
you've identified, yourself, Kim, Tessie Bucklar, Brad
Stone, and Cara Rosson?
A
Q
And others .
What others did checking of facts that went
MR WEN WORTH t will pull it out .
into the public domain?
BY MR . MUELLER.
A
Q
time?
A
Q
I can't specifically recall . Jean Roach.
Anyone else that you can recall at this
No.
Now, you just testified that when you found
Q
the --
BY .MR.
Q
If I can direct you to the third page of
MR . WENTWORTH . 3 of 7?
MR . Mc10 .i .E R 3 of 7 is correct .
MUELLER
:
If I can have you look at the second
errors you corrected them?
A
Q
Yes .
paragraph under the photograph starting with the words
Which would mean that you're aware that
"toxic materials," do you see that?
inaccurate information about PDC was posted at various
A
times on your website?
Q
Uh-huh .
Do you see where it says at the end of that
A
Q
Yes .
paragraph, "According to their application,
PDC had four
What errors as you sit here that you found
hazardous waste spills at the facility between 1995 and
did you correct?
1997"?
A
Q
Uh-huh .
What's the source of that information?
A Specifically, the direct line of
questioning that you had indicated on toxic waste
stacks .
Page 22
Page 24
I
A I don't know .
I
Q
In looking through various iterations of
2
Q Who provided that information for you to
2 your website, I was unable to find any retractions or
3 post on the website?
3 statements in the nature of, "The previous reference to
4
A I can't recall .
4 toxic waste stacks was incorrect ." "Peoria Families
5
Q I'm assuming based upon your testimony that
5 offers its apologies to Peoria Disposal Company ." Did I
6 you did the physical posting onto the site and its
6 miss that, or did that not exist?
7
alteration from tune to time ; is that correct?
7
A Upon learning the error, it was immediately
8
A Correct .
8 removed from the website .
9
Q Did you provide this information, or did
9
Q So correction of the error consisted of
10 someone provide it to you?
10 removing the label?
I I
A I did not provide this information .
I I
A Yes .
12
Q Do you know whether the information is, in
12
Q It did not consist of also a statement that
13 fact, true?
13 the previous label had been incorrect, did it?
14
A
I don't have any specific knowledge one way
14
A No.
15 or the other .
15
Q Were there any other errors that you're
16
Q You never checked it before you placed it
16 aware of at this time?
17 into the public domain
; is that correct?
17
A Not that I can recall .
18
A
We were getting lots of information at that
18
Q Now, you said that you tried to check your
19
time to put on the website, and we worked hard to check
19 facts as best you could . Without going into how good
20 the facts as we put them on the website . We learned
20
that effort was, what methodology did Peoria Families
21
lots of things about landfills throughout the process
21
have in place to do fact checking before posting
22 and corrected many things that turned out to be
22
negative information into the public domain?
23 mistakes .
23
MR. WENTWORTH : I
object to the
24
Q
Who is "we" that you referred to in that
24
characterization of what kind of information it was .
10/27/06 Ted Converse
CondenseltrT'f
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page 25 -
Page 28
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MR . MUELLER. I'll withdraw the word
"negative ."
MR . WENTWORTH
. Thank you .
A Can you repeat the question?
Q What kind of organized system, if any, did
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7
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u
1 4
Is
PEORIA DISPOSAL COMPANY,
)
)
Petitioner,
)
vs.
) No
. PCB ObIR4
)
PEORIA COUNTY BOARD .
)
Respondent
1 hereby certify that I have read the
foregoing transcript of my deposition given on October
27, 2006, at the time and place aforesaid, consisting of
pages I through 26, inclusive, and I do again subscribe
and make oath that the same is a true, correct, and
complete transcript of my deposition so given as
aforesaid.
Please check one
f have submitted errata sheet(s) .
No corrections were noted .
Page 27
Peoria Families have in place to do fact checking before
it was posted on the website?
A I'm not aware
. My primary role was to
maintain the website
.
Q Did you do any fact checking of your own?
A Yes .
Q What fact checking did you do of your own,
and how did you do it?
A I believe I -- I believe I pulled
information on TRI reports from the EPA .
16
17
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19
20
21
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Q Any other fact checking that you did?
A NO .
17
8
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TED CONVERSE
SUBSCRIBED AND SWORN TO
before me this day
of
AoD 2006 .
Notary Public
My Commission expires
MR . MUELLER : Let's take a short recess
.
We're near the end .
Recess in
(
from 10 :40 a.m .
proceedings
to 10:45
a.m.)
MR . MUELLER : Thank you, Mr
. Converse . We
have all the information we need, so we have no further
questions .
Page 26
Page 28
1
MR . WENTWORTH : We will reserve .
1
STATE OF ILLINOLS )
) ss
2
10 :45 A .M .
2 COLWFVOFTAZEWELL)
33
4
4
CERTIFICATE
5
5
6
(Further deponent saith not .)
6
I, Angela M . Jones,
CSR "R.
a Notaiy
7
7 Public duly commissioned and qualified in and for the
8
8
County of Tazewell, State of Illinois, do hereby certify
9
9 that there came before me on October 27, 2006, at 416
I))
10
Mum Street, Suite 1400, Peoria. Illinois, the following
I I
I I named person, to wit
12
12
TED CONVERSE
13
13 a witness, who was by me first duly sworn to testify
to
14
14 the truth and nothing but the truth of his knowledge
15
15
touching and concerning the matters in controversy in
16
16
this cause, and that he was thereupon carefully examined
17
17 upon his oath and his examination reduced
to shorthand
18
18 by means of stenotype and thereafter
converted to
19
19 typewriting using computer-aided translation by me
.
20
20
1 also certify that the deposition is a
21
21 true record of the testimony given by the witness .
22
22
I further unify that I am neither
23
23
attorney or counsel for nor related to or employed by
24
24 any of the parties
to the action in which this
10/27/06 Ted Converse
Condenselt""
VI E 309) 690-3330
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Page 29
- Page 29
I
2
Page 29
deposition is taken, and further that I am not a
relative or employee of any aetorrcy or counsel employed
3
by the parties hereto or financially interested in the
4 action
5
In witness
whereof,I
have hereunto set my
(` hand and affix rtyy-nutanal seal October 37, 2006
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Angela M .
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shorthand
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show 13113i7
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p]
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p1 21 :19
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opinion [3)
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opposition
[21
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10/27/06 Ted Converse
SUBSCRIBED
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technical pl
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[91 1 :0
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131
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thereafter
111 28
:18
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121
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111
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thousands pl 19
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throughout
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SIVERTSEN REPORTING SERVICE (309) 690-3330
stenotype - yourself
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Exhibit 22
_ .-y
, and . .a_
_
ber
e
7, El ~ 7 .
--C CE
a
___ .
THOMAS EDWARDS
10-24-2006
Page
TCPAIIY
PE,oP:a
-:oua^ Z EE (,APE
PCB06-184
THOMAS EDWARDS
10-24-2006
r "4 IT .
w-,re
i ,
aE _
c ososr
:nt?t,c'~
N'EttPIA COUNTY BI, Plr
PCB06-184
THOMAS
EDWARDS
10-24-2006
I IIOAIAS I .I)AA .ARl)S .
a matertol w it ness herein . being Link sworn . "a,
cxanunel and tesulicd a> lollo", :
LSAN115 :\I[()\,
BY \IR . Nt - I(I .I
.IiR :
•
Would you state your name, please?
\
I homes I-.Jr~ :uds .
•
Let the record show this is the discovery
deposition of Thomas Edwards attempted to be taken
pursuant to the Rules of the Pollution Control
Board and the Illinois Code of Civil Procedure so
far as the same is applicable to the Rules of the
Pollution Control Board .
Mr . Edwards . (lid you receive a subpoena for
your appearance here today
A I reccised a --
something in the mail two
Sunda's ago . I opened it
. It ''as a letter in a
regular envelope with just ill' address on it . no
return address
. I opened that . and it was a
suhpoet'a .
•
So the answer is you are here today
pursuant to a subpoena that you received?
\ Yes .
•
You have not yet received the $20.11 that
is due to you by reason of your appearance .
How do you want to make arrangements to
receive those funds?
A You sent me a pholostal otthat check
. and
today?
A You "ant to pa' me something for m'
r' appearance toda'
.'
•
The rules require that we pay you $20 as a
witness fee and 41 cents for your mileage
.
A
It soil want to ei' e etc some none'
-- no . 1
Jon 't "ant an' none'
.
•
Let the record show that M r
. Edwards has
waived his appearance fee .
Mr
. Edwards . I'm going to ask you to turn
off the tape recorder that you have with you today
for the reason that the Rules of the State of
Illinois provide that only the recording made by
the court reporter and the transcription made by
her can be used as to evidence of what is said
during a deposition .
A M' under,tondim_ a 1'rom
talking
to se'cial
auorne'sand I also hclie'e one of the Pollution
Control Board ottorlie, , that it', oka' I6r me as a
pet son to ha' c ms personal tape recorder here
. So
I lea' c it on .
Q
You understand that the tape that you're
making for your personal use cannot be an official
record?
A
It's onl' a record of "hat goes on the tape
and Ibr nix own use Laid for an' Iticnds of mine "ho
1 c
ma' "cant to use it
.
Q Do you stipulate that the recording made by
the court reporter will be the official record of
_
what is said?
A
It the court reporter is correct
. I w ill
abide h' it
. of course . 11' it's incorrect . I
No ill
Idol .
_
Q Mr. Edwards, (lid you bring with you any
documents that were requested? The subpoena that
you received had a rider attached which asked for a
number of documents .
First of all, was the rider with the
subpoena that you received?
responsive documents but that they are in your
vehicle?
\ lhes're in m' ' ehicle . and I h.n c to make
copies ill them helore I call gRe Illem to son which
I can Jo after This deposition it \ou like
. go o'er
to Kinkos and make copies
. M) reason--nka) .
Q Do we have the opportunity to look at the
documents at this time and then we'll determine
what we need to have copies o r
A
I'd rather make copies of all of than
because I don't w dill
to let an' of them out of tr
Pages 3 to 6
PE:.-
_1 . FiS
CO!^.PAti': . .
PEORIA
r
('p)TY i%OFPP
PCB06-184
the letter I didn't reed' e .
A
I brought the documents . YcsN
it was,
Q The original of the check was with the
Q
What documents did you bring with you today
certified letter that you failed to claim
.
that are responsive to the request in the rider?
Do you want us to reissue you another
A I ha' c"ith ne
. which I''e just Ibund lust
check?
night --
it
.\oil w ant me to explain that . I w ill --
A I returned the photostat to son . No .
docunients hoe the last 12 month, in m' car . hill I
Q Pardon me?
ha' e to make copies otthose hclore I oik e them to
A No . I he ails" CI is nil .
dolt
. I just got them together this morning .
Q
Son do not want a check for your appearance
Q So you indicate that you did bring
THOMAS EDWARDS
10-24-2206
convol
. bill
-- rou understand that .'
•
Very simply, Mr. Edwards, do you hake
documents responsike to the subpoena request that
you are prepared to show me at this time, yes or
no??
V
I can sIhovs 'oil those documents a hi eak
lime. P e can take a break and I can eo out --
•
Can you show them to me at this time since
we are starting the deposition? I'm happy to give
you three minutes to go to your car to bring the
documents in .
A (iisc me lisc minutes
.
•
That's fine .
A Okts .
•
Take five.
A
I loses' er . the Joeuntents must Sid' \s 1111 111C .
(Pause in proceedings
.)
MR . till 1 l.l,LR : Back on the record .
131' MR
. Mill L[1R :
• Sir
. Edwards, do you have certain documents
that you are prepared to produce for our inspection
at this time?
A I o look at the table here
. Am tine during
the meeting here \ oil s' ant me to run out and make
copies I can prohobl' do it here . I "ill he glad
•
Sir. Edwards, I will ask you again, are you
prepared to produce the documents that were
specified in rider A of the subpoena you received
for inspection at this time? NN'e will be happy to
inspect the documents in your presence .
A At this meeting! Vl' plesenca at this
meeting'
.
•
At this time .
A At this time . Oktn . at this lime this is
not' . okay . hilt I 'till he glad to run out and make
copies for'ou as soon as'vc has c a hreak . I his is
_ . the one son can hate right no" . I ha\c copies of
that .
•
Mr
. Edwards, what you have produced for us
is a letter to the Peoria County Board . et al.,
dated October 31st, 2005 .
I will show you each of these, and I want
You to tell me whether I've correctly identified it
or not .
1 Yes .
•
Okay
. The second thing is a flier. I guess
_ 4 it's a petition and it's entitled Hazards Of The
PDC Hazardous Waste Landfill. dated Januark 2004
.
The second page of it is a petition
entitled no More Hazardous Toxic
\\ aste . the n there
is stapled to it another document entitled To
Peoria County Board . Re
: Peoria Disposal Company
Landfill
. The Decision Of \ our Life. Our Lises%
dated April 5th . 2006. That document appears to
be a two-page document .
Have I correctly identified that?
\ it '\asa III)('
haiardous waste tandlill .'cs .
th,ai s correclh identified
. I he decision of our
uses . 'es. that's been correctlr identified
. the
petition
. No More I laiardous I ogre AA ague .' es .
that's correcih idenufted
. and the t'so paces to
the one decision ill our hIe . our .'esInc, . ti's
correctls identified .
•
The next document you'ke tendered is a
document entitled, To the Peoria County Board .
Re
: What Now, dated Man 2nd . 2006.
Have I correctly identified that document?
\ You hare .
•
The next document is entitled, To Peoria
County Board, Re : PDC's Hazardous
\\
ant e Landfill .
dated May Ist, 2006, and that appears to be a
two-page document.
Have I correctly identified that?
A Yes . Peoria ('auntv Boar) PI)( haiardoas
haste landfill . it's two parts
. distinct parts . one
is part one . S' lit)
psis_ and second pal . second page
is --
\' hich is almost a separate doctancnt . PD( s
net' Proposal .
•
Okay . The next document you have tendered
appears to be a letter to a Representative Dave
Leach dated 4/21/06 starting out with the words,
Dear Dave.
Have I correctly identified that document?
Yes .
•
The next document is apparently some type
of flier under the caption of River Rescue dated
_' 4/17/06 and starts out with the phrase, Closure of
'l oxic Waste Landfill. That is a two-sided
document .
Have I correctly identified that?
A YOU ha' e . the second part of that one is
re' ics' of particulars .
•
The next document, sir, that you've handed
me is a document dated February 9th, 2006, also
under the River Rescue caption, Dear Peoria County
F
Pages 7 to 10
. PE' P.I!, (YIt'7i anAPD
PCB06-184
THOMAS EDWARDS
10-24-2006
I
i
2006, under the caption of River Rescue and starts
out with, Dear Wonderful Peorians in the PD(
Landfill Shadow
.
Have I correctly identified that?
:A
1'es . soil has e .
•
The next document, sir, is under
the
caption of River Rescue dated
1/18/06 and entitled,
Dear Peoria Residents, and has on the second page
of it caption, The Solution, and
that includes a
handwritten portion that says,
Contact your
neighbors to, and also provides
what appear to be
contact names, numbers and E-mail addresses for
Peoria County Board members .
Have I correctly identified that document?
A
I heard 'on title this in the first page .
•
The first page, sir . I just said it starts
out with Dear Peoria Residents and I gave it a
date . Is that correct?
A Right .
•
Thank you . The next document
I have is
under the caption of River Rescue
and is dated
1/28/05 and is addressed to Senators
Barack Obama
and Dick Durbin, Frgent, Re : Toxic
\\ante landfill
Endangers Peoria Area
.
Have I correctly identified that document?
A I'M
going to put a car eat on here .
I (,III-
brought
one page of that document .
Is there a
second page there'!
I here is a second page . and
there's ant one page here .
•
I don't have a second page
.
Have I correcth identified what
you gave
me?
A Yes
. You correcth identified it .
•
There's a second page that you've
not
produced?
A
It's not here .
•
The next document I have is dated 11/4/05
and is apparently a letter to
Linda Daily and
starts out with, Dear Linda --
A Right .
•
-- is that correct?
A
Yes
. untitled also--continues . Follow up
to mN earlier letter on ss ater pollution monitoring
.
•
And the next document that you've handed
\ 'Ies .sonhase
. IIII, onewas_th,<was
the one I aetualls submitted
to Linda . I his is one
I wrote and decided to add a couple words to it and
rev rote this is the actual leller_ Ibis one did
not eo to Linda tindiamng) .
• Mr . Edwards, are those all the documents in
tour possession or control which are responsive to
rider A of the subpoena preciously
sened upon you"
\ All the ones I could
find tin the
kill --
Sinc e the date . earliest date here I think was
hosenmher Is l . October 31st
Ill last sew. yes .
•
I notice that there are no copies
of any
F-mails .
\
I don't use I -mail . I don't hase I
•
I notice that there are no copies
of any
correspondence between you
and any of the other
opponents or opponent groups .
:A ) es . I don't rem<mher tams correspondence
between them .
•
Mr . Edwards, you have apparently
brought a
number of indis iduals with you
toda to this
deposition . Depositions are
not public hearings .
So I would ask you to identify the
individuals that
sou have brought with \ou which presuntahh \ou seek
to hase us allowed to he present
.
A Yes
. I didn't know they're all going to he
here
: hooves er . INC hose -- I'm a little short on a
Ieo names here .
\
Cl
. I don't know them all ill,
name AII right So I'm going Io go around and I
Sometime, block a name
. 1201 a little problem
mill that .
•
As I indicated to you --
A But the' can identilA themsckes
.
•
\\ell, this deposition is your opportunit
to answer our questions
. I'm not going to turn
I
this into a speaking session in
. oh ing people that
sou hase in, itcd to come and ohsene .
\m I correct that all the people in the
I
room are people that you hase invited
to he here to
obsen e?
\
I hat is incorrect .
•
I hat's incorrect!
5
ties .
•
So you did not incite them?
Pages 11 to
14
U P .Yos.L COMPANY
PROP IA CJ~tI'Pr BOARD
PCB06-184
Board, Re
: PDC Hazardous Waste Landfill .
me
. sir, appears to he another copy of the same
Have I correctly identified
that?
letter to Linda Daih with the same
date only with
A 't es. N ou ha' e .
different handwritten notations on it .
Q The next document is dated January
31st,
Have I correctly identified that document?
THOMAS EDWARDS
specifically who 'on invited to he here, we'll
excuse the remainder
.
V
I lies re all im ted to he here . I do not
,peeilicalh recall all of them . Sonic lust heard
ahout it and came ,it their of n accord
. I told them
the meeting "v as open and the' Could he here It's
wt open meeting
. I so indicated in Tm letter to
son
. I
.tenthing f\ e done has been puhlie . and I
tt alit this w he public
. too .
Q Mr
. Edwards, it's not an open meeting . It
is a deposition taken pursuant to the Rules of the
Pollution Control Board and the Illinois Code of
Civil Procedure.
Peoria Disposal Company has been kind
enough to make some exceptions to that rule in
terms of allowing individuals to be here
. I don't
know that my client is prepared to have you
accompanied, though, by individuals who you cannot
even identify .
A Okar .
Q We can terminate this and we can get an
appropriate order from the hearing officer in this
Fa
case and resume --
A Mayvis \bung
.
Q -- at an appropriate place
. So if you'll
identify the people that you want to stay, we'll do
that
.
A Mayvts Young and I'm going to say here that
I have a problem with blocking some names . I had
to ask your name when I came in
. I can't remember
it. though . I have been to seteral hearings with
you where you spoke . I had to remind nicsellof
-- Mr
. Meginnes's name
.
I called Elaine Hopkins of the Journal Star
to let her know this meeting was going on
. and if
she wanted to come . it's okay with nie . I didn't
invite her. She said it's okay with me .
MR. KLEI\ : Ed Klein
.
THE WITNESS : Ed Klein who I have
known for years and --
MS . CAROL : Kathy Carol .
THE WITNESS
: Who?
MS . CAROL : Kathy Carol .
THE WITNESS : Kathy Carol . thank
you
.
BY
MR
. MUELLER
:
Q Mr
. Edwards, we're not going to go around
deposition which is a closed session under the
appropriate rules into a public hearing
.
We're willing to accommodate you to some
degree because we understand you're not represented
by an attorney . but if you can't identify people.
it's not- we're not going to do a sign-up sheet
.
Tell us the names of the people that yon
would like to keep in the room as people that are
here at your request
.
:\
\t In n reyuelf . Ihes're all here . I put the
sturd out That this Mould he an upon ineenng- I'm
oiling to eseuse my sell for a moment o hale I rcure
and remember -- use lit t accord
.
•
A ou're indicating that you need to retire .
sir?
A I'd like to take a break lift a minute
.
•
The record should show that it's
approximately 1
:35 . \\ e've been at this for about
-- 10 or 15 minutes . I assume you're getting
fatigued . is
that correct'!
A Yes .
•
Then let's take an appropriate break
.
A
I Iovv lone did voil sus :'
•
How much time do you need, Mr . Edwards
A
II) Or 15 minutes .
•
10 minutes we have no problem with
. Turn
your tape recorder off, please
.
A
All right . I hank tou .
I Recess trom 1
:35 to 1 :45)
MIL sit'fl .l .l[R : Back on the record . All
right .
It) MR . MI 1I'.I .If R :
•
Are you refreshed, Mr . Edwards^
:A I hasn't realK tired_ hut I needed to get
net thoughts together
.
•
All right. dust so we're clear, have you
had a chance to identify the people in here' We're
going to let them all stay with the exception of
Mayvis \bung anti Diane Storey who've been
identified as witnesses and clearly, therefore, are
not properly spectators at another witness's
deposition, but just for the record, we'd like to
know who everybody in here is
.
A Nh
pastor
. ht
the tear
. Re'erend Carol
I .akota o' er here Laid Kathy Carol nest to her tt ho is
one of the parishioners who I sec at church
Pages 15 to 18
L :F si
_4" . ...
FEAFJJ,
I, .W.,"r
BUAEL
PCB06-184
10-24-2006
A I no ited some of them .
the room and raise our hands and identify
Q
All right . If you could tell us
ourselves . you're the one that attempted to turn a
THOMAS EDWARDS
10-24-2006
frequently but not too frequentN because I don't
so to church too frequenth
.
Diane Stores who has been active in this
for quite a while and I know from her activity here
and this acti)ity Alay s is Young who was -- also
been active for quite a while and is a friend of
mine, and I let her know this is going to be here
this day and she could conie if she wanted to .
Same thing with Diane Storey who called me
this morning on another matter and I mentioned it
to her .
Anybody else'! Elaine Hopkins reporter knew
about it and came which is tine with me . I guess
one other person had to go home, another
parishioner of Carol Lakota . and that's just all
that I have here .
Anybody I talked to the last few days I
said vou want to come . I said that's fine, it's
open and more ntay come .
•
Mr . Edwards, I'm going to ask Non to keep
your voice up because I notice that it trails off
and the court reporter is having some difficulty .
A
Thank you . I vv ill do that .
•
As I said, Mayvis young and Diane Storey
have previously been identified as witnesses in
this case . They, in fact, have already been
deposed . As such, it is not proper for them to sit
in on the deposition of another witness, and we
would ask you since you invited them to excuse them
with your apologies.
Il then nsant to go -- the' IL' here . I I
thev want to go . it's okas with tile . 11 , 010 don't
i want to go . it's okas ssith mc .
• Mr. Edwards, I don't think the deposition
is going to continue if they're present because
they have been identified as witnesses and under
all rules governing this process witnesses cannot
sit in on the depositions of other witnesses .
We've done a lot to accommodate you here
_ c
today . We've come to your location of choice .
We're letting you tape record . W e are letting you
1
have your parishioners and other supporters in the
room, but we're not going to tolerate other
witnesses being here and will seek an appropriate
court order .
A
1 he re lean ing ions,
•
Thank van
.
(Spectators leaving deposition suite .)
B\ MR . MH ELLER :
•
Thank yoyt . Mr . Edwards . 11 hat is )our
address . sir?
A
90_' Vlest Peoria-- AAcsi MossAsenue .
•
West Peoria or \Vest Moss?
A
VAcsl Moss Asenuc . Peoria . Illinois .
•
How long have you lived at that address?
\
\hour a y Car.
•
Is there an apartment number at that
address'
\
\pwvncnt1 .
•
Who do you reside there" ith?
A Mssell.
•
What is your telephone number, sir :'
~\
617-1979 .
•
Do you have a cell phone'
.\
No .
•
\ on indicate that you do not use E-mail
\
Right .
•
Is it correct that you do not have an
E-mail address?
A Right .
•
Do you have any other contact numbers or
locations besides your address and telephone number
such as a P.O . box or any other number at which you
can be reached?
\ No .
•
W hat is Your highest level of education,
IIr. Edwards
.\
College degree
.
•
When and from what school!
•
A I9501'nhersitn of
Michigan.
Are you currently retired from active
em ploym en t?
A I am aetisels emplosed in the t:ct that
I'm -- do home repair work . I lug en't done that
_ `
reeentl'
: hossener . I mil old enough to reeene
Social Sccurits .
•
What's the name of your home repair
business?
A lung I,dssards . I go hw ills own name .
1 f
Q When's the last time you worked actively in
hat business?
A It's been about a s car .
•
Mr. Edwards, are van a member of an
organization called River Rescue
\ Yes .
•
What is River Rescue!
Pages 19 to 22
..,tiler.: :, . . r. E-TI2 CocnTV J .',AP<c
PCB06-184
F
THOMAS EDWARDS
10-24-2006
Pages
23 to 26
PFC!P_i, C00 :'"'O BC)AP .
PCB06-184
A It's a loose) knit group that works on
Q Are you a member of an, other environmental
environmental issues
. Mostls we're focused on the
organizations such as Citizens For-Our Emironment
3 Illinois River
.
or the Sierra ('Job?
4
Q
Is it incorporated?
V I'm a member of the sierra ( 411h and
5
A
Not at this point
. I've got the papers .
\uduhon .
6 though .
Q Are you a member of Peoria Families Against
7
Q Do you maintain a membership list?
Toxic \\ ast e ?
A No
. I don't .
\
I till not .
9 Q
Are there dues that are required to he
Q Have you ever received an' financial
1 0 paid?
support from any member of Peoria Families Against
11 A No
. There are no dues .
Toxic Waste or from that organization?
12
Q Are you the founder of the organization?
V /cro . none .
13 A
I am the founder .
Q Have you received any financial support
14
Q How long has River Rescue been in
from the Sierra ('lob or anyone that you know to be
1 existence?
a member of the Sierra ('Job including but not
16 A
Since 1988 .
limited to Joyce Blumenshine
17 Q How does one become a member of River
A I reccned donations font the Sierra ( lots
18 Rescue?
oh . cosh . It's been almost thin sears ago
. I think .
19
A
Becoming active and lust know about it and
I Ibrgel the amount. It \\a, .
5c, . S3011 .
2 0 working with us .
Q Mr . Edwards
. between November 9th, 2005
21 Q You say "us." How many active members
and May 3rd, 2006, did you ever telephone or
22 would you say you have at the present time?
attempt to telephone an\ county board member
:'
23 A People who are-- I'd sap people that are
:A I has c ndkcd to all the
count,
hoard
24 associated with doing the things that we're
doing I
Illerahers
. I has e talked to se\ eral of them met tile
1 would sap five or sis .
phone us el' the last nv o N ear,
.
2 Q
Can you name those five or six people?
Q Let me ask the question again
. Between
A
People that are associated with the tsco
November 9th, 2005 and 'May 3rd, 2006, did you
4
left the room, but very looses associated_ we
telephone or attempt to telephone an county board
5
don't have a membership list . been working with us
member?
6 recently .
A AA 'hat "as the cutoffdate7
7 Q
So Mayvis Young and Diane Storey are
Q May 3rd .
8 loosely associated with River Rescue?
\ Mav 3rd. Nusentber to Ma' 3rd
. Well .
9 A Yes . they are .
there's 19 count, hoard nlenlbers
. that particular
10 Q Anyone else?
eriod . I think ouR one
. onh one .
11 A
My son Roth who has been in town in the
Q Who slid you telephone?
12 past a couple times to help out
.
:A
I haveto think of his name 11155
. tin .
13 Q
What's your son's name again?
Q Jim Thomas
14 A R-O-T-H .
A
'hat's right .
15 Q Where does he reside?
Q And when (lid you telephone him, to the best
16 A Wisconsin
.
of your recollection^
.
17
Q
Is he there at the present time?
A
Best ofnN Iecollection
. prohahly I think
18 A Yes .
about In e months ago --see tit a minute
. I'm
19 Q Anyone else associated with River Rescue
thinking in terms of the hearing . It vvan prohahh
.
2 0 besides the individuals you've just named?
oh . the kill of20th,
21
A
I'd say those are the onh ones that have
Q What was the purpose of that call:'
22
been active recent)
.
A I don't remember the purpose .
23 Q
Were you the founder of River Rescue?
Q
Do you remember what was said by you and
24 A Yes .
what was said by him?
THOMAS EDWARDS
10-24-2006
• How have you known Mr . Thomas'!
A Just ht being acthe on the Count
.\ hoard
and being a neighbor of his lot a' ear or so ns er
the block here he lis es a Jew houses doss
it .
•
Among the documents that you presented
today were four letters which appear to be
addressed to the Peoria County Board, and they are
dated October 31st, 2005, February 9th
. 2006,
May I st, 2006 . and May 2nd, 2006.
Were these documents, in fact, given to
Peoria County Board members?
A
I think one of them teas given -- either
left in their mailboxes--either mailed or left in
(heir malboycs at the count' building . Some were
prohahh given to them chrecil' . I think the doors
I didn't put-- I gasc a icw ofthcn direct)' to
them . N es .
•
N ith regard to each of these documents .
str
. did you attempt to cause them to he
hand-delivered to the homes of the 18 Peoria Count)
Board members either by you or by someone helping
you?
A One of those documents .
•
Which one do you beliese was hand-delivered
to county hoard members?
A I beliese it was the Pins 2nd one .
•
And
whit
did the hand delis en of that
letter?
A I did sescral of Ihcnr . most of them .
Mm'
IS
Young did a less and the other lad' . I can't
think of her name now
.
•
Did Diane Storey deliver some for sour'
A She delrvered I think two or three .
•
[low man' counts hoard members were )on able
to --
A One of the ladies helped_ I can't think of
her name .
•
So there were four people doing personal
delis en of the alas 2nd letter?
A
Right .
•
And those four people did they hit all
member while making the deliveries?
A Not on this issue .
(Edssards Exhibit No . 47 marked)
B) MR . MLELLER :
•
Sir, we have copies of the
!Nat' 2nd letter, and we're going to show you a
copy of this and ask you, it's going to be marked
as Exhibit 47, whether that's a true and Correct
copy of the document that you brought with you
today as the May 2nd letter to the county board .
A I'm not real sure if this was taken to
their homes or put in their boxes : but .
nevertheless . I verify the letter was sent to
count_v board members .
•
The exhibit that we have is a true and
correct copy of what you brought with you, right?
A
Best of nay knowledge . I hase to keep the
cops because I don't 111I'e a cop' Of in m' sell
.
•
We'll give you one of our copies
.
A Oh . thank cur .
•
Mr. Edw:rds,
the other three letters I
asked you about dated May 1st
. February 9th and
October 31st, 2005, were those also sent or
hand-delivered to the county board?
:\ I think that one was the onl' one
hood-deliysed . All the rest were sent .
•
They were mailed to county board members?
:\ Not necessarils . I weal ar all the count'
hoard meetings lire three' cars . I missed two . I
would put theta on their desk usual)' sshen the' came
helire the meeting. and the' were there when the'
got there .
•
In any event, if you didn't mail them, you
put them on county board members' desks or in their
county board mailboxes, is that correct?
A
One case I knosc I gas e it to the courts
clerk who I think included it in the-- I asked the
coral' to send it out
. I beliese--basicall' .
\C, . it cent in the boxes or on the desks
. I think
nwsl of them ss ere put in their desks_ I'd sa'
nine tenth, of an' thing I pill out -- ma' he one went
Pages
27 to 30
F
DIS?' ;Sr.i r')1 ,)! -11
c7 OP_A Cou:vi' ;' BOAPC
PCB06-184
A No
. I don't . I doubt it ''us about this
18 board members?
issue .
A I don't knosc for sure .
Q
l oo doubt it was about the landfill?
Q How mane did you personally deliver tot
A I doubt it was about the landfill .
A
Prohahk five or six .
Q Pardon me!
Q
Do you remember which ones?
A I doubt if it was about the landfill
. I
A No . not offhand .
hat c know n him for nun'
) Cars .
Q Do you remember speaking to ass board
THOMAS EDWARDS
10-24-2006
in their hoses
. nun he tvco . one or two . I lie rest of
them went in their desks .
•
Mr . Edwards . did you ever have an
understanding that the landfill expansion process
was supposed to result in a decision based on
evidence developed at a public hearing!
A that is not ms understanding .
•
What was your understanding of what the
rules of the process were going to be?
A
Ilie process based on the hearing that thev
would take into account the intormation the' had on
this from the two s c n,, two and a half s ears that
the' were told not to talk kith am members of the
Public hl Mr
. Brian Meginnes there .
And that two and a hall Nears not one of
those members talked to me about the landfll .
I hat was an exorbitant amount oftime . I
communicated with them . Thev did not communicate
with me .
•
Was it your understanding that they were to
2 1 . take into consideration any information that you
provided them or was that just your hope?
A I spoke at a count' hoard meeting hack in
2004 and asked that question ill could distribute
w ritten materials to Ihem or other" ise corn c' OUr
thoughts about the landfill to them . and the answer
was from the hoard auomes es .
A I Id's
not the hoard atornev .
•
Okay
. So you wrote to the board on these
various dates in October of'05, in February of'06
and twice in Mat of '06 and delivered those letters
1 to the board members with the hope that they would
take the information contained in them into account
in making their decision?
.A
first of all . sox start with I delisered
them to them . The usual w as of at' approach to the
count\ hoard was to Irate the letter . "hate'er
commnunications I had on the desk . but I did speak a
number of time, w ithout Ica% ing am thing in
writing . Again . I suited speaking in Jlanuaq or
December of 200 , --
•
Mr . Edwards . let me cut you off. I'm not
interested in the method of delivery a nymore .
VA e've covered that .
My question is . was it your intent in
getting these letters to counts board members that
they take the information contained in those
letters into account in making their decision?
A I would say I don't like the word account .
I would sac taking them in consideration in making
their decision .
•
Did anyone ever tell you that your contacts
with the county board during the application and
hearing process should be limited only to the
hearing room and public filings with the county
clerk?
A Could you repeat that question?
MR . MUELLER : If the court repotler
would read it back .
(Record read as requested
.)
THE WITNESS : No one ever told me
that
. but I don't know what you mean by the
application process . So let me just refer to the
other part of the question which refers to did the)
tell me that no contact should be made "ith the
count' hoard
. No . No one eis suggested that ever
including the attorne\5
.
B't' MR . Mt Id A FR :
•
Do you remember speaking at the Peoria
County Board meeting in March of 2006 and saying
starting inaudible by Mr
. Meginnes, I cannot talk
ex parte about the hazardous waste landfill
; and,
of course, I do everything he tells me to do
. So I
won't . Look at him
. He's smiling . I would rather
- see him smile . lie's a great guy
. I (lid pass out
-- this thing to all of you
. this thing I wrote I
1' think it is one of my better efforts and shares a
message and understanding
.
Do you remember saying that, sir??
A I rcmemhcr sa) ing some of those things
.
yes . ahout smiling and so on .
•
So Mr. Meginnes did tell you at one point
that you were to avoid ex parte contact with the
county board, is that correct?
A Delinc cs parts .
•
Pardon me?
A
What do ott meant?
•
\'ou used the word, sir . I'm asking you if
pAt:
Pages 31 to 34
PEOPIT, 'OU :IT'i BOAR[
PCB06-184
Q Do you remember who that attorney was
A
Yes . I do . It was -- I'm prett' sure he
"as the one there then because the''v e had two .
6
Q Was it Mr . Atkins?
-
A
I helicvc lie "as there . I can't sas for
sure
. 'Ehes had outer, there .
u
Q Or was it Mr
. Brown, the gentleman that's
sitting on your immediate right?
THOMAS EDWARDS
10-24-2006
4
Mr. Meginnes told you?
A I wasn't supposed to talk to the county
hoard at that particular -- what date was that?
•
It was in March of 2006, sir
.
A March of 2006 . March board meeting . I
remember standing up and say ing that . and I didn't
speak ex pane and I handed what I had in writing
instead . He was there .
•
So it was your understanding that as long
as it was in writing you avoided the prohibition on
speaking, is that correct?
A I
certainly did understand that . yes . I
have to take a break . I have a weak bladder .
(Recess in proceedings .)
BY MR . MUELLER :
•
Mr . Edwards, did you participate in the
design, purchase or placement of any yard signs
opposing the landfill?
A I participated . number one
. the placement
of some of the yard signs . one version of the yard
signs . W hat %vas the other pan of the question?
• Did you
-- that was the question . Did you
then participate in the design or ordering of any
billboards?
A The question . the first question was did I
participate in the design of any yard signs? No . I
did not . I corrected some of the wording . made it
more precise . but that wasn't nm\ wording either .
I did do--was I financially involved? I
have not been financially involved . I hope I can
be some day . Right now . I'm not inxohed with
those yard signs .
Now . billboards I had absolutely nothing to
do with .
(Edwards Exhibit No
. 48 marked)
BY MR
. MUELLER :
• Mr
. Edwards, let me show you what we're
going to mark as Exhibit 48 which is a multipage
document, it's actually seven pages . and ask you if
that is a packet of documents that was delivered to
toxics thing . I spoke at a county hoard meeting
and passed this out to
-- at the county hoard
meeting. I hey meet monthly
. I passed this out to
them for their own inlonnation . I here ''as nothing
said by them
. only by tile .
Q So all of these documents with the
exception of the petition page and the petition
itself would have been passed out to county board
members in December 2005?
V I'm looking at the first one y uu eav e me .
I his one I withdrew December 8th . I don't
remember passing that out to the county hoard . I
do remember sending it to Senator Barack Oharla and
Dick Durhin . I Into huge Liven it to some other
people . I usually do . but to Moss distribution
. I
don't hake any recall of that . It's possible .
•
If I was to tell you
. sir, that at the
January 2006 Peoria County Board meeting
y ou said .
I hank you . I came here tonight basically to give
you this little packet
. One is a lencr to Barack
Obama, Senator Durbin and Governor Rod Blagojevieh,
would that refresh your recollection as to whether
or not this packet was handed out to board members?
\ N hat 'vas there Ill the packet .'
•
The documents that you hays in front of you
that will he marked as Exhibit 48 .
\
I-rankly
. I don't recall than particular
incident . I you --
around ( hrislnl :uume . I don't
knot's
. pulling, it together and all (hose : hut .
tics erthcless . the documents I stand ho and they arc
true and correct .
•
And it "as your intent with regard to all
of those document% to have county board members see
and consider them, is that correct?
:A It wsas the content --
m_y mtent to base
these documents seen by the public including the
county hoard and anybody else m the public to base
passed out these things to many --
not this
particular one on the top. hat sale front toxics .
Inn still passing, that out to people
. and (he
Pages 35 to 38
^I
[ISP
'III PAt!Y , . PE-P! A r .MT!TT POAPU
PCB06-184
he told you that .
or put on the desks or in the mailboxes of county
A I'm using the word he used .
board members at or about the time that it is dated
Q Did you understand what Mr . Meginnes told
and it is dated December 8th, 2005 .
you?
A No
. I lie petition was ties cr gil en to the
A
Did I understand -- %%ell- I think -- well .
count_t hoard mcnlhers
.
%%hy don't you explain what ex pa rte means . Ak hat
Q
Other than the petition, was the remainder
did he tell me?
of this given to the county board members:'
Q I'm asking you if you understood what
A I'm ti's ine to think now on the sale tionm
THOMAS
EDWARDS
•
Do you remember, sir, at the December 2005
county board meeting passing out a copy of the
Peoria Disposal Company real estate tax bill for
the year 2004?
A May I see that document?
(Edwards Fshihil N'o . 49 marked)
BY MR . MUELLER :
•
We're going to mark this as Exhibit 48 --
49, excuse me .
A I remember-- what board mectin was that
again?
•
December 2005 .
A
That sounds correct . 2005 . that was over
two gears ago . over a year ago .
•
Actually, sir, it's 10 months
.
A Half a\ ear, okay . I remember certainly
passing this out . That was a board meeting . fine .
I remember passing it out to them and many other
people in town .
•
Is that your handwriting on that document
that says. Dear County Board Members?
A Yes .
(Ldwards Lyhihil No, sit marked)
BY MR . MtiFI
.l .l-R :
•
All right
. Thank you, sir . Next I'm going
to show you a document which we're going to mark as
Exhibit 50 which is dated January 18th, 2006
. and
addressed, Dear Peoria Residents, and this is a
document that urges Peoria residents to contact
county board members to urge them to vote no on the
landfill expansion, ask you
. sir . if you authored
that document and whether that's a true and correct
_ copy of it .
A
Didn't I just see this earliern or it oust
he in ms (older
. Okas Yes . I authored -- I
authored this document . And shat sea, the rcsl of
the question'
•
Who was this document distributed to
A This document was distributed to residents
on the far side of-- west side of Sterling
. most
of those houses in that area .
•
Well, if I take you to the second page of
the document, sir, there's a handwritten, it says
Peoria County Board members and in handwriting it
says, Contact some or all, be firm .
Is that your writing'
contact county board members to urge them to rote
no :'
A
I Ite>'re re presentatnc of IIt
L people .
I lies need to he contacted . of course .
Q Was it also your intent that the--to
contact urge county board members to vote no?
V It was ms Intent along w idh m ;ms other
people m tow o . I wasn't the onus one to pa
ss
this
out . I pissed them out to other people to en e .
but I don't rententhcr whom .
•
Mr. Edwards . if you go to the bottom of the
first page on this, you will see where it sacs
. I
will not support election of any board member who
supports landfill expansion
.
Did you ever send, deliver, give or place
on the desk or in the mailbox of any county board
member letters indicating that you would -- or that
they would find opposition in the November election
if they supported the landfill
A
I ha' e rio recall olgis rug this to the
counts hoard members .
•
Not this letter, other letters served
direct) to counts board members threatening them
with political consequences if the) soled to
support the landfill?
A I never hose sent am kind of later like
t hat . n o. not to the counts hoard members .
•
If I were to loll you that Diane Store)
recalls that you i% role such a letter
. would s,,it sits
that she was I> ing?
\ No . I would sas her mentors was prohabh --
shy prohabh nusspoke . She prohuhh said that
no
. I don't think --she ntas base mistermed the
letter
. but I'm certainh standing against
supporting --all two and a hall \ cars supporting
i lie
•
defeat ol'the proposal to expand the landfill.
Did you eser tell or communicate in am wa'
to any board member who "as running unopposed that
the% would have opposition in the November election
if the) supported the landfill?
A
I didn't toe that wording with an>hod) .
• \ on did write nn the second page of this
Exhibit 49 -- or 50 . Landfills are legal . This is
a political, not a legal question . correct?
A
I wrote That . It is .
•
\lm never contacted Tom O'\eill about the
2(
Pages 39 to 42
r"CMPFCI'i
.
I'S^.I':SA
'LP'.TY B' ;APG
PCB06-184
10-24-2006
petitions I have passed out probabl> 15 .000 of
A Ill at', ms w it tug .
those around town .
Q
And was it your intent to have people
political consequences of his supporting the
landfill?
3
A
I have no recollection of that . The ooh
time I talked to Tom O'Neill was at work . I saw
5 him at work one day . I remember going by his
6
off ice, and he came out not because I was there .
He just came out .
6
And, no . I did not threaten him with any --
9 anathing like that .
10
Q Did you ever contact William Phelan -- or
11 excuse me, Michael Phelan about political
12 consequences of his voting for the application?
13
A Who is Michael Phelan?
14
Q He would be a board member .
15
A I'm trying to put a face with a name . Like
16
I say
. I have problems with names . I will get
17 there . Let me look at the list
. No . I certain)'
16 did not --
didn't threaten anyhodt on the board if
19 they didn't vote this 'tat . Nobods ever.
20
I said it would he a political
21 consideration, perhaps . but like all the votes have
22 political consideration . I didn't threaten anybody
23 with defeat if then toted .
24
Q
But did you tell someone or some board
44
members it would he a political consideration?
A
I didn't tell ant hod' t hat . n o . I last
indicated I would hope' ou Note It']* this and so on
and so forth . No. I did not at any time sat to
am hoard member -- I ha' e no recollection of
say ing to any hoard memher there would he a
consequence it the soled F r it .
I talked to Sharon kenned' se' clad tines
but not about this . lust -- but not about tile
particulars . Nothing-- no . Ididn't sa' an' thing
to her about that either
. I knew it 'tus possible .
'ou know . I kind hate wondered how the 'titers would
take it . but I did not threaten them at an time .
(Edwards Fxhihit No . 51 marked)
111' MR . ML1111I,R :
Q Exhibit 51 is a letter entitled, Dear
Caunts -- Dear Peoria Count Board, dated
February 9th, 2006 .
Is that a true and correct copy of your
letter to the count board of that date?
A
I like this letter . It is a true and
correct copy .
Q Thank you, sir. You can keep that copy .
A Let ntc take a look at that letter again .
-n
1 es . sir . I certain)' endorse this letter .
•
By the was . when you spoke at count board
meetings. those are different meetings than the
public hearings on the landfill application, right :'
\ Dilierent meetings than the puhlir hearings
on the Iandlill petition . You're rclerring to the
public hearings at the I IOO I lull?
•
That's correct .
A
I 1 00 I lull . I he' certuinl' --
count' , oard
memhers . I certain I' could hat c .
• So you actually spoke at the regular count
hoard meetings that were held to conduct other
county business?
:\ the hoard meetings I attended were
hasiealh in regard to-- I went to the general
meeting . general meetings 't hick there's alwans
other business there .
(I
:dwards I(xhihit No . 52
marked)
Bl' 11R . MI LI .LLR :
•
Okay . No", if I can show you Exhibit 52 a
letter dated 2/13/06
. this is not one of the ones
you produced, you must have mislaid it, entitled,
Re : PD( Hazardous Waste Landfill
. Is landfill
14 stories higher than original hilltop?
r-~a,
I'll ask you if you are the author of that
and if son caused that to get into the possession
of count board members as well .
A 1'es . I did . I corrected a previous
statement I made by misreading a blurred number on
6
a map . and so I corrected what my other letter had
peen . I passed that out at the hoard meeting . too .
(Edwards Exhibit No . 53 marked)
Bl' MR . MLELLER :
•
I show you Exhibit 53, also addressed to
Peoria County Board dated April 3rd, 2006
. This
is again a document not brought by you today .
Actually, this particular exhibit has a letter
' dated April 3rd, 2006 ; one dated March 29th,
2006 ; one dated March 21st, 2006, and a copy of
an envelope to Board Member Prather with what
appears to be your return address on it .
Let me show you that, sir, and ask you if
that is, in fact, the packet that you mailed to
Board Member Prather .
A (Witness perusing document .) ['in glad you
found this for me because I certainty don't have it
nowe . Explain that I was gone for three months Out
of state . had no contact with anybody here . My
THOMAS EDWARDS
10-24-2006
Pages 43 to 46
PEORIA CGJETY 6')AID
PCB06-184
THOMAS EDWARDS
10-24-2006
letter stands . Ms apartment flooded . I have a
basement apartment and all of nix stuff was thrown
into a total of 60 boxes . I have only found a few
documents since then
.
• I think the question, Mr. Edwards, is did
Non author those letters in Exhibit 53 and mail
them to Board Member Prather?
A This first letter to Peoria County Board .
PDC Landfill . it has nsv signature on it . I
authored it
. The second letter-- I swill _et to
Mr . Prather in a minute . March 29th . I certainly
did author this .
March 21st letter. History of PDC hazardous
waste landfill . That was a jovt'ul one to author
.
I left out one date in particular there
. too
. I
hope you not the whole letter .
•
The last page of the exhibit, sir, is the
copy of the envelope.
A The cope of the what .'
•
The envelope .
A Oh . I'm looking at this part right here
(indicating) . Yes . I put these dates together .
this information and left out one important one .
1940 when they opened the landfill .
•
Did you nail this to \I r . I'rather as
indicated on the cops of the ens elope :'
A I don't remember nailing it to A1r . Prather.
but it1 did . fine ss ith ate .
•
Take a look at the ens elope, sir
.
A
I ant I'm ir% im_ to lied tt . Yes .
•
Is that your w riling (in the en elope?
A
Yes .
•
Did you mail this to all the other counts
hoard members a% ,ell?
A
I do not renteniher . I think I -- I don't
know it I did or not . I don't think so .
•
\\ell . what's your best recollection as to
ho, man board members sou would hoe mailed this
n .7
A lhes till gut -- I don't rementher mulling
this . I maw hase dasiributcd it again at their
desks . Short histor' . the% sure all got that I
don't rcmemher whether I mailed This one mr not .
Mr . Prather mas hose missed a meeting . I
mas base done -- mailed him sonsething . I don't
remember in pursuit (it the April 3rd lever .
Additional issues PD( landfill . It's pos,ihle thai
I did send it out I send out a lot of letters . I
hope I did . I agree ss ith it .
•
So it was --
A And PDC landfill hearing public comment .
Peoria ( ount_r Board . again . I think this look., more
like a letter I distributed Lit their de,k, . .ind I
eeII'll o
,
agree ss ith It . Itul good lever .
•
So if anybody wasn't at the meeting where
you handed it out, you would have mailed it to them
to make sure they --
V
It's possible . I don't remember . Al I
,us . I well to all the nlcellng, except two for a
-- ino-and-Lt-halI-s ear period .
•
It was your intent that even board member
. - get every one of your letters?
1
I hose letters
. sou know . I don't rein ember
_,
ss hat I did ss ith the April 3rd letter. I
prohahh -- it I ssrote it . I wrote it for a purpo,c
and that was to hase it read. but I hose to plead I
n't remember the April 3rd letter ''hat I did
ws ilh it . I he other nsu I certainh \gaol all the
hoard mcmhers to h is c .
Ihdsswrds Inhihil No . 54
marked)
13) MR
. iAit'Ill]
.IN :
•
All right . As Exhibit 54--as Exhibit 54 .
F
we are going to show you a letter dated
April 5th to Peoria County Board, The decision of
your life . our lives, and ask you if that was
distributed by you or otherwise placed in the hands
or possession of all the board members.
\ I don't remember how I placed it in their
han(I," but it eertninh Lot w them all . ses
.
•
Thank you .
~A
I belies c I pill it in their boxes or
,ometIi no at the counts hoard meeting .
(ICdww'ds IAhihil No . 55 markedl
If) NIR . Nil'tfI .1 .LR :
• As Exhibit 55, let me show you what is a
letter entitled . Dear friend, and ask you if you
recall preparing that document .
\ (\\ ime,s perusing document) . I helped
vwile tlli, . I would otn I \o, as mull responsible Ihr
the wording . though . another person was insohed .
•
Who was the other person
involved?
A 0h . God . not her nine . but ahoul I II or
I S people helped send this postcard out. and it
went to I think 1311) . 1 .500 of them went out . I
stand by tlli, postcard . the writing of it . so o n .
so forth .
I
t
Pages 47 to 50
PGS`.P i . SOOT'7 4 0)AP.L
PCB06-184
THOMAS EDWARDS
10-24-2006
I lie vfording is essentially mine_ and the
idea to NN ca' a' ellott ribbon a nthand . vs hact er . I,
certain)' mine and attend the Ma' 13th meeting
.
tte vsere all saying that at that little.
•
Do you remember who the other author was of
that postcard
A
No . but it's so much my oft n IN riling . I tt ill
take complete responsihilit' lot it
.
• NN ho paid for the postage?
A
I did .
([ shards Ii'thihit \o . 56 marked)
I he lit st one . Ma' I st . 2006 . to Peoria
('puntv Board, a quote sv ith Abraham Lincoln on it .
) es . I certainly did send that letter to the
count' hoard I don't knot host I distributed it .
Prohahly I put it in their desks .
.May I st --I could have mailed that one
out
. May 151
. I wrote the letter definitely, no
doubt about it . I wrote the letter and I don't
remember all the people I sent it to . I sent it to
a lot . I'm sure . I want to .
•
Okay .
A That's a good letter_ too . Both of them
are .
(Edwards Exhibit No . 57 marked)
BY MR . MUELLER :
•
Exhibit 57 is a letter dated March 9th,
2006, and the top of the second page you write, I
took a whiff from a cent for the gaseous emissions
from this landfill .
A Yes . Okat . What about ii?
•
First of all, is that your letter?
A I start the first pan . first -- it's
definitely my letter . Another very good letter .
•
Now,--
A Right to the point .
•
And that was also gotten to the county
board members, right?
A To the Peoria County Board and stall . It
that's what I said oil top
. that's where it went
.
Q Okay . W hen and where did you sniff the gas
rent
A
I don't knots . I let it he knatsn velk lk .
and I got admonition from Mr . Coulter that lie 'ru
going, to certainly arrest any body that ticspa,,es
on his land . and he started a patrol of his
proper(' after that . I didn't cot Cr it up when I
''as out there at all .
•
How do you know -- let's back up . Ill hen did
you go out to the property?
A Bo' . putting a date on it . It ttas heforc
A
(as cents :resisihlei1'ouvsulkonthe
outside of the fence mound the proper(' . and' ou
can see them sticking up out of the side of the
hill . I I'' ou take a tour_
lie
rte\ Cr sho\\s' au those
gas V eats .
t
•
How did you get inside the fence'
\
.lust stalked through a hole .
•
A hole in the fence?
A Yes . I got in the h nee through a big gap
heisteen the bottom of the fence and the soil .
I"rosion pmhabl' created the hole .
•
Do you remember what side of the facility
you were on when you entered it?
A Same side as the s cots .
•
What street were you coming off of.'
:A Hot . that's un interesting question . What
street? \elfV
the street that floes clossn (here--
oh . ( sod . a nante again . ( ioe, dust n -- st hat's due
- n ;mte oithc street that goes doff n the hill?
•
Were you coming off of Southport Road which
is the main road that is adjacent to the facility?
A No . Mien cuu go out -- I ssasn t canting ell
Of Southport Road . I "as coating Off a road than
goes dostn the hill limn up the top (11 the hill .
goes by the apartments out there .
MR . Cl IRIS C'O('I :1 I,R : It's the road that
goes up to the apartments .
"Il If. W I I NI .SS : You can yet on that road
Guns Southport Road . You conic up the hill and go
Pages 51 to 54
r,^?PAIi'1
-P:JR 11, G,UM' IP'iAP.D
PCB06-184
131' MR .
I'll 1 1 I'LLR :
Q Exhibit 56, another letter to the Peoria
March 9th because I
\\as
there then . It stas
helin'e then .
County Board, this one dated May I st, 2006, do
Q
N as it shortly before then!
you remember giving the board that letter, also
\ Nu . It stns se\ era] months he lore then .
A (\kitnessperusingdocument .) Didn't vve
Q
Who let you on the
properly?
just cuter this ., Yes . I ga e'ou a Cop, of that
A I did .
in that pile . Okav . And I didn't gite'ou the
Q W here did you go on the property to find a
cop' because that's the only cop' I's e got. Oka' .
gas rent?
THOMAS EDWARDS
10-24-2006
over to Sterling. but -- give me a map .
Hl' MR . MUELLER :
•
Were you on the east side of the landfill?
A
East and right --
east side -- I'm turned
around in im directions, but you kooks where that
seminars is out there
. seminar) building right near
there . That's where I parked .
•
You--
.A That's on that side . What direction is
that? I think it would he north .
•
You did not enter through a gate?
A No
. I did not enter through a gate .
•
You crawled underneath a fence, correct?
A I went underneath a fence .
•
You understood the fence was there to keel)
individuals--unauthorized individuals out, is
that correct?
A
That's interesting
. I didn't see an)
signs .
•
You understood, though, that the
fence was
to keel) unauthorized individuals out?
A I understand that's the usual purpose of a
fence . ves .
•
You did not ask permission to enter the
property?
A Only from God .
•
And you did not report that you were on the
property to anyone in authority once you were on
it, did you?
A I let them know that I was on the property
.
Yes, I did .
•
How did you let them know?
A I don't remember how I did . but Mr . Coulter
even spoke to Ine about it .
•
Did you speak to anyone while you were on
the property?
A
There was nobodk out there .
•
So it was after you were off the properh
you let them know you had been on it correct?
A After . )es, I told ever) both as )oil see by
my letter
.
•
Right . What did you do besides sniff a
cut while you were on the property ?
A Looked around at the grounds .
•
What else did you see that was of interest
to you?
A Some other pipes sticking
tip out of the
ground coming up on the roof like this, and let me
I_n c \ ou
a drawing of than .
• You don't need to make a drawing .
\\ hat da'
of the week, by the way, do You remember did this
happen on?
A I do not
rententhcr. s o long ago .
•
Was the facility open or closed at the
time?
A I think ii vvas a weekend . So n would hti c
been closed .
•
All right. So it was on a weekend . It was
during daylight hours!
A Yes .
•
Have you attempted to come on the properh
since that time?
A No . I ha'cn't .
•
You indicated Mr . Coulter is now ha ing it
patrolled?
A Last lime I was out there . I saw patrol
car, going around .
•
When's the last time you were out there?
\ Let's sec this is probabl\ --
prohuhl\
last spring sometime . I was non on the propem .
I was o\cr in the cemeter\ which has a good k iew of
the property . I he, since put tip a no u'espu„Ing
sign in the cemeter\ .
•
Now, were you out at the property shortly
after May 3rd last year with other individuals
for the purpose of having a demonstration?
A We were out there counting the trucks
6
coming in .
Q Ilow many of you were counting trucks?
A
Oh
. we had a couple shifts of people . I'm
not sure how man) were there . I . 2, d . 4 . 5 . 6 . 7 .
•
How long were you personally out there
:'
A Two hours .
•
It took seven people to count trucks?
A No . the\ came in shills .
•
Ilow many trucks did you count in your two
hours?
V I forget . Don't have that -- I don't have
that on to fingertips . I counted four in
Ill minutes just a couple days ago as I was driving
bN . less than that . five minutes, four sentitrucks .
•
Just a couple days ago . Did you stop to
see where they were going?
A Yes . They were going up the driveway
into -- I didn't stop . I didn't have to . They
were just going in front of me . and they were going
Pages 55 to 58
I' P15Ai . :J15PAHY . PEORIA COUNTY guARD
PCB06-184
THOMAS
EDWARDS
10-24-2006
Lip the hill into Peoria Disposal (ompan' landfill .
You're gelling a Ion ol'stulfup there .
aren't' on? -
•
All right . There's no question pending,
Mr. Edwards . )A e may be done . Let me check with
our team to see if we have a couple of wrap-up
items, but I think we may be finished .
A puke a break . \ ,ill mean :'
•
Yes, just take a couple minute break .
(Recess in proceedings .)
BY' 1,111 . MUELLER
:
•
Mr . Edwards . I'm going to have you look at
1
a newspaper article from February 15th, 2006, with
1 the headline, IEPA Disputes Claims Against Toxic
Waste Dump, and ask you to look that article over
and tell me whether you were accurately quoted .
A I "as not accuratel' quoted . It "as taken
out of contest
. It
\N it' a setup . I le asked ate about
something else . I told hint out there it ''a, a
setup .
•
You sound like you're pretty familiar with
this article?
A
I read the article .
•
Okay . W hat quotes of yours are not
accurate in that article?
A The context they're Put in is erroneous
.
•
I'm not asking about context, sir. I'm
asking you if any of the words attributed to you in
quotation marks are incorrect and, if so, which
ones?
A
Flux is an indirect quote . but could not
explain why he would leave IEPA . No . I didn't say
anything like that . I said we're way beyond that .
meaning that was a 20033 letter he was referring to .
it was sent onk to the
IEPA and asking a question
about something . And he said I was asserting
something . and I said that letter's long gone .
That information- no . This is totally out of
7'
context and irrelevam .
Why I have not discussed the letter
publicly because we ironed out what my question was
to the IEPA .
•
What question did you have that you ironed
out with the IEPA?
A I don't remember because it doesn't refer
to ii in here . He agreed to I ironed it out . too .
•
Just one more thing, Mr . Edwards. I think
we're done" ith that .
A That letter was panicularl' to me and the
EPA to iron out a fact
. and that was all .
\\
c pot
it ironed out
.
• Just one more question, did you write an
article for the Sierran publication, the Tall Grass
Sierran in which you said that the landfill is not
visible from surrounding areas? I give you the
specific quote--pardon me?
A
Give me the specific quote I don't
rementher that quote .
•
Well, let me just show this to con. It's a
letter entitled, PD( wants to expand its toxic
waste landfill in Peoria In Tom Edwards, and vou
write, Not visible front roadways
. The landfill
sits on a hilltop and not visible front roadways .
The landfill sits on a hilltop .
Is that true, sir?
\ It is true . Speaking about the roadways
being Route 8 and the route --
the one road I can't
think of the name of that goes by the
seminary-
vou
can't see it front there . 1 nit can't see into it .
•
'Then you goon to say, The higher earth and
berm keeps it out of the view of the thick
residential development along its east side .
Is that also true?
A
Ihere arc sonic apartments that con see into
it m die aparmlent contple\ out there
: other'' ise.
the residential development that I was referring
to . no . \ ()it can't sec into it .
•
Because I had just one question, something
that troubled me, and that was that vou had in one
of your letters dated January 31st . 2(1(16, addressed
this, Dear N onderful Peorians In The PD( Landfill
Shadow .
If the thing isn't visible, then how can
anyone be in its shadow?
A Gi' c me the letter . lanuar' 31st . 2000 .
ca,'
. li'er' landfill has been tested like this in
1
I
.urope and the I'nited Slates as a shadon of tunics
I
.,
coming out obit . You don't see them . )'on don't
smell them . bayou breathe them and the' pi'e
hirth defects . I Ill, is in the shadov' ol (lie ail
pollution tomes than conic out oh that landfill .
•
So it's kind of a symbolic shadow, is what
you're saying . You've answered my question .
A It's a shado" of fumes front the landfill .
shadow of--o'er their proper[' ' aloe c'entualh .
•
Thank you very much, Mr . Edwards . That's
Pages 59 to 62
r, ., .
' .,MsACY
IEOP.IA
:'4JT7 B(j7.PC
PCB06-184
all the questions sye have. You will provide us
1 with copies of all the things that you brought, is
3 that correct? We've identified them, and you'll
4 mail us a copy?
A It looks like sou've got them all . You got
6
more than I got .
7
Q Well, we don't have the same things that
you have .
9
A I kill mail them to vou . Sure . Mail them
10 to Mr . Meeinnes's otlice .
11
Q That's fine .
12
13
(Further deponent saith not .)
,i
16
1
16
a
2C
22
2_
29
0a sac .
THOMAS EDWARDS
10-24-2006
P
Page 63
PE0t* A n0U!F ."'i kubPD
PCB06-184
THOMAS EDWA DS
10-24-2006
--
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10-24-2006
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PCB06-184
THOMAS EDWARDS
10-24-2006
60
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10-24-2006
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10-24-2000-
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10-24-2006
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10-24-2006
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10-24-2006
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10-24-2006
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10-24-2006
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THOMAS EDWARDS
10-24-2006
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THOMAS EDWARDS
10-24-2006
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THOMAS EDWARDS
10-24-2206
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PCB06-184
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Exhibit 23
10/27/06 John McLean
Con denseltn'
E 309) 690-3330
Page 1 -
Page
4
John McLean
INDEX
k^,-NESS.
Page
BEFORE THE ILLINOIS POLLUTION
JOHN MCLEAN
Examination by s, Mueller
CONTROL BOARD
PEORIA DISPOSAL COMPANY,
6
7
9
12
13
S
18
19
20
21
22
24
ORIGINAL
EXHIBITS :
1
No . PCB 06-184
a witness
notice and
the taking of
EXHIBIT 94
39
3/30/06 Letter and Attachments
THE DEPOSITION of JOHN MCLEAN,
NOTE :
Exhibit retained by Petitioner's Counsel
.
. .e[e .1 ., called for examination pursuant to
'he Supreme Court Rules as they pertain to
leer l'to :
. := be.-
Angela M Jones, CSR, RPR, and a
5
-
County of Tazewel_, State
v1'1
O--tore! 2), 2006, at 416 Main
1400, Peoria, Illinois, comonenclng aC the
. .m . cc 9 :05 a .m .
APPEARANCES
Page 2
.
Page 4
1
(Witness sworn .)
,CR;E
v_,
LLER, ESQUIRE
2
JOHN MCLEAN,
6
.rile
:35L
204
3 called as a witness, after being first duly sworn, was
and
4
examined and testified upon his oath as follows
:
JANAKI NAIR, ESQUIRE
5
EXAMINATION
El1as,
BRAN
Meginnes,
J . MEGINNES,
Riffle I Seghetti,ESQUIRE
6
BY MR
. MUELLER :
416 Main Street, Suite 1400
P
. C
.
Peoria, IIUnccn 61602
7
Q
Will you state your full name, please?
D : . bena:f . .
the Petitioner,
8
A John Marshal McLean
.
9
Q And you are a medical doctor?
./,v
1-.'l,
-. A .
bBROHt,
.n
ESQUIRE
10
A Yes .
St .-
10
: Suth Main street
11
12
Morton, Illinois 61550
You're here today
on Behalf of the ResponaenV
Q
with your attorney David
Wentworth?
13
A Yes .
.24
DAVID L . WENTWORTH 11, ESQUIRE
Hasselberg, Williams, Grebe,
362
14
15
MR . MUELLER
: Let the record show : This is
ague All
.-.All.-
`
SBitrredesta,
l
. . .
: State
u
'.
the discovery deposition of John McLean taken pursuant
ee .
-, 11hocis McLean61602
n .
16
17
to notice, in accordance with rules, pursuant to
subpoena, and scheduled by agreement of the parties
.
18
Q Dr
. McLean, what is your address, sir?
20
19
A 1714
West Moss Avenue, Peoria, Illinois,
20
61606 .
A .SO PRESENT :
21
Q
How long have you lived at that address?
R :Iru .0,'.TER,
FCC
22
A Since 1971 .
23
Q What is your home telephone number?
24
A
(309) 674-7316 .
10/27/06 John McLean
Condenselt
t'"
Page 7
•
Did that experience impact your decision to
get involved in this hazardous waste landfill expansion'?
A No.
•
Doctor, when you were practicing, did you
have any supervisory positions at any of the hospitals
in the community?
A I was head of neurology at the medical
school and at OsF for about four years .
•
And did you ever hold offices in any
medical or other professional societies?
A I was in the Academy of Neurology . That
was my active role .
•
Since your retirement, have you stayed
active in any medical or professional societies?
A No .
•
Do you serve on --
A Correction . I still belong to the American
Academy of Neurology, but I'm now a senior member ; so,
you know, I don't pay dues .
•
Since your retirement from active practice,
have you served on the boards or advisory committees of
any of the local hospitals or medical facilities?
A No .
•
What caused you, Doctor, to first become
Page 8
involved in the opposition to the hazardous waste
landfill?
A Two years ago, my son-in-law Teddy Converse
wanted to get into environmental interests ; so he wanted
me to go to the Forrest Park Sierra Club meeting about
two years ago . And at the end of that meeting, Tom
Edwards talked about the landfill, and that was the
first I had learned about that .
•
What was your son's -- your son-in-law's
particular reason for wanting to get involved in
environmental efforts if you know?
A He had been up in Alaska, and I think that
that's sort of the laboratory for a lot of what's
happening in the environment ; and I think he was
motivated from his experience in Alaska .
•
Listening to Tom Edwards speak is what
caused you to become interested in the issue?
A No . Partly was that I learned about it for
the first time at that meeting, and I had not known
about it .
•
What did you do by way of follow-up to
acquiring that knowledge?
MR . MUELLER : And I won't belabor this,
Mr . Wentworth, because you're giving me that look .
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v. PCB
Page 5 - Page 8
1
2
3
5
6
7
8
9
10
I 1
12
13
14
15
16
18
19
20
21
22
23
24
Q
Page 5
Do you have an e-mail account that you use
1
2
3
4
s_
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
regularly?
A Yes.
Q What is that e-mail address?
A j mmclean@mac .com.
Q Do you ever use your wife's e-mail account?
A Sometimes.
Q Do you know her e-mail address?
A Yes . Cindymclean@mac .com.
Q Doctor, are you actively practicing at the
present time?
A
Q
A
Q
No .
When did you retire from practice?
July 1999 .
And prior to retirement, what was your
specialty?
A
Q
area'?
A
Q
Neurology .
How long did you practice in the Peoria
Since 1971 to 1999 .
Have you been employed in any capacity
since 1999?
A
Q
No .
You are the father of Kim Converse ; is that
I correct?
Page 6
1
2
A
That's correct .
2
3
Q Do you have any specialized knowledge
3
4 gained before these hearings began in solid waste
4
5
disposal and management or hazardous waste disposal and
5
6
management?
6
7
A No.
7
8
Q Do you have any specialized knowledge
8
9 gained before these hearings began in exposures to lead,
9
10 other heavy metals, or arsonic?
10
I I
A Say that again now .
11
12
Q Do you have any specialized knowledge in
12
13 exposures to lead, arsenic, or other heavy metals?
13
14
A I would say no .
14
15
Q Do you have any family or personal
15
16 experience with hazardous waste management or disposal?
16
17
A No .
17
18
Q Do you have any personal or family
18
19 experience with exposure to lead, ars-- asbestos, or
19
20 other heavy metals?
20
21
A Asbestos and --
21
22
Q Other heavy metals .
22
23
A I have a granddaughter that had a
23
24 borderline lead level about a year ago .
24
10/27/06 John McLean
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A Well, he announced that there was going to
be an informational meeting at the Pleasant Valley
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Q Did you know her before you first went to
the Sierra Club meeting with your son-in-law about two
Middle School in a month or so. I forget exactly when .
years ago?
So we decided to go to that .
A
I had seen her at the middle school, but I
Q "We" being who?
A Teddy and myself, Teddy Converse and
myself
.
Q
At some point after that, did you determine
didn't introduce myself and did not meet her really
until then .
Q When did you then determine that you were
going to be actively opposed to the landfill?
that you were going to be actively involved in opposing
the expansion?
A I don't think it was until several months
later, but I can't really give you a date .
A No.
Q You never made that determination?
A I did eventually, but I had later
Q Was your son-in-law Ted Converse or your
daughter Kim with you on the tour last November 14th?
A No .
informational meetings -- I went on a tour by Royal
Q Were you involved in the formation of the
Coulter and Edwards . There were a group of us from
the -- actually, it was an invitation to the Sierra
Club, but there was some other people including myself
and a few other people .
Q Are you a member of the Sierra Club?
A Yes .
Q When did you join?
A I've been national member for a long time,
Peoria Families Against Toxic Waste group?
A
Was I involved in the making of it?
Q Yes.
A Not really . No, I wasn't.
Q Do you know who the founders, for lack of a
better term, were of that group?
A Well, I know Teddy was interested in it,
but I really am not sure of the evolution of that,
pretty consistently . I may not have paid my dues once
frankly .
or twice -- I don't know -- but pretty consistently .
Q Do you consider yourself a member of Peoria
Page 10
Page 12
1 And then last year -- I'm not really sure if I hooked
I Families Against Toxic Waste?
2 into the Illinois one or not, but I am now
.
2
A Yes .
3
Q
When was the landfill tour that you took?
3
Q Did you attend their meetings?
4
A It was about a year ago, I think, but I
4
A Not many of them actually .
5 can't give you that date .
5
Q If I were to tell you that your daughter
6
Q The fall of 2005 sometime?
6 Kim Converse testified that she and her husband were as
7
A Well, it would be -- yes . That's correct .
7 close as anyone could be to being the founders, would
8
Q They're telling me it was November 14th,
8 that be consistent with your recollection?
9 2005 .
9
A I wouldn't be surprised of that, no .
10
A Pretty close .
10
Q Did you perform any volunteer services on
I I
Q
And on a day actually nicer than what we
I I behalf of the Peoria Families' effort?
12 have now, correct?
12
A Such as
--
13
A
Yes, it was .
13
Q Well, any
.
14
Q How did you find out about the tour?
14
A No. I mean, I don't think -- I mean, I
15
A
I believe Edwards told me, but I'm not
15 don't quite know what you mean by volunteer . I was sort
16 sure .
16 of my own person . I was studying the landfill industry
17
Q Did you take any photos while you were on
17 and the medical aspects of that, so I got a lot of
18 the tour?
18 literature which I dispersed to try and educate other
19
A
No.
19 people about the issue . That's what I would say would
2(0
Q At that point, had you gotten
--
strike
20 be a volunteer, but that was more in my own
-- for my
21
that
.
21 own edification and knowledge
.
22
By the time you took the tour last November 22
Q
I think you're answering my question . You
23
14th, had you gotten to know Joyce Blumenshine?
23 dispersed literature to other people ; is that correct?
24
A
Yes.
24
A Correct .
10/27/06 John McLean
CondenseIt"
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I
Q
And your recollection is that you did that
2 of your own initiative rather than at the request of or
3 in service of the Peoria Families group'?
4
A
Most definitely .
5
Q
What kind of literature did you get?
6
A
Well, I reviewed all the literature I could
7 find on landfills
. Most of them come from New York, up
8
in New York, and they are sort of the hybrid articles .
9 I mean, they are all over the map in terms of the types
10 of landfills and what's in them_ And I found it very
I I
confusing actually .
12
1 didn't get a whole lot out of that except
13 that, you know, there was some association with, you
14
know, low weight babies at birth, newborns, and then
15 some correlation with cancer of the prostate with some
16 landfills . But that was the kind of issue that I was
17
trying to delve into and have an opinion about .
18
Q
Would I be correct in assuming that the
19 materials you found were on the internet?
20
A I got them through the intemet
. I
21 worked --
I did all my research through Saint Francis
22
I lospital library and got the internet -- got them
23 through the intemet there . Some of them were in the
24
journals, but most of them were from the intemet .
Page 14
I
Q Now I'm confused again
. You did your
2 research at the Saint Francis Hospital library?
3
A Correct
. That's where I got the
4 internet --
that's where I got the -- some of the
5 toxicology books, for example, that are on reserve
6 there . I was able to get -- I wanted to get a book on
7
landfills, and the library got it from a place -- I
8 think it was Illinois Wesleyan . I got two books from
9 there
.
10
Q So we're way beyond just basic
i I
intemet-based search and into actual medical literature
12 that you thought was related to landfilling?
13
A That's correct .
14
Q
Do you still have privileges at Saint
15 Francis Hospital'?
16
A I'm honorary staff there, yes -- I mean --
17
yeah, honorary . As you retire, then you go on honorary
18 staff. So, yes, but I don't have privileges .
19
Q I understand you don't perform services
20
there
.
21
A But I can go to the library, and I have
22 those services, and I can go to their conferences which
23 I do fairly regularly .
24
Q
I had asked you that at the beginning, if
Page 15
you were still active
. So you do go to conferences
regularly at Saint Francis?
A The one I go to is the neurology . There's
two conferences every Friday, and we get CME, which is
required
--
•
Continued medical education?
A Right, continuing medical education to keep
your license, which I still have .
•
Lawyers are actually now finally required
to get continuing legal education after all these years .
So we're getting into the 21st Century
.
Doctor, did you share the information that
you were acquiring and the knowledge that you were
acquiring with any other doctors?
A Yes.
•
Who did you share that with?
A I think the first one I brought that to was
the medical director at Saint Francis, Dr . Miller, and I
tried to give him the filtered information that I
thought was, you know, the best papers . There's a tot
of literature that is pretty inconclusive, so I tried to
give him that and then also the toxicology
-- there's a
lot of chapters in the toxicology which I found helpful,
and I gave him that .
Page 16
•
In your medical and other research related
to this subject, did you become aware that most, if not
all, of the literature referencing negative health
impacts from landfilling refer to landfills that are
real -- that were really open dumps prior to federal and
state requirements for engineered barriers?
A Yes
. I had a view of that .
•
And in your research, did you also learn
that most of the negative effects from this open dumping
were related to chlorinated hydrocarbons and other
liquid wastes?
A Correct . I agree
.
•
And you're aware that
PDC does not accept
liquid wastes or chlorinated hydrocarbons?
A Yes.
•
And you're aware that PDC, for their
expansion, proposes a rather elaborate engineered
barrier?
A Yes .
•
Then I guess my question is
: Based upon
those awarenesses on your part, what caused you to still
he opposed to the PDC expansion?
MR . WENTWORTH : I
guess I object . We've
gone from his learning process and now you're saying
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10/27/06 John McLean
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1
that he was opposed . I don't think you've gotten
2
into --
3
MR MUELLER : I think he's already
4
indicated at some point after he did this literature he
5 decided to oppose the project .
6 BY
MR.Mt
;ELLER:
7
Q Is that a fair statement?
8
A I think that's a fair statement .
9
Q I'm pretty much done with this area; but I
10 guess, given the fact that you agreed with my
I I characterization about where the negative health effects
12 came from, which puts you way ahead of the curve of most
13
of the public, why did you decide to still be opposed?
14
A I never had any issue with what
PDC did or
15 how they did it, only where it was
.
16
Q And that would get us into the whole
17 aquifer issue and the related issues to that, correct?
18
A Well, in the sense that I felt that --
you
19 know, I'm 71 years old, and I have seen many, many very,
20 very competent people make mistakes
; and I've seen time
21 take its toll on things, and I've seen unexpected
22 calamities . And accordingly, I just think that this
23 adds up to an unnecessary gamble to our community .
24
So, on balance, I recognize all the
Page 18
I advantages to having this facility in this town, the
2 jobs, the advantage of the other industries . My only
3 issue is that it's a gamble, it's a risk, and I felt it
4
was a risk that I didn't think I wanted my community to
5 have
(I
Q Thank you for that explanation, and I will
7 move on
8
After you talked to Dr . Miller -- who I
9 believe you said is the chief of staff at
OSF?
10
A He's the medical director .
I I
Q
Okay . As opposed to the hospital
12
administrator')
13
A Right .
14
Q
Did he arrange for or did someone arrange
15 for you to present your views to any group or in any
16
meeting kind of format?
17
A Yes .
Q And who was that?
19
A
Dr . Zwicky .
20
Q Did you approach Dr
. Zwicky directly?
21
A
Actually, I was going into the hospital . I
22 think it was a Monday or Tuesday
. I don't know which it
23 was, but it was the day before
-- it was the day of
24
their quarterly staff meeting . And I bumped into him in
18
Page 19
the hall in the lobby, and I said -- you know, at this
point, I had been voicing my concern as I've outlined to
you ; and I said that I was interested in making sure
that people were aware of this because it became very
astounding to me that nobody, even well -- you know,
people who kept informed were not aware of this
. I
found that absolutely amazing .
So he said that he would announce it ; and
he said, "Would you like to come up" -- you know, he
invited me to come up to talk about it . He said, "You
know more about it."
So I did .
•
What's Dr
. Zwicky's role at the hospital?
A He's the staff president, the physicians
part of it .
•
What group is it that you spoke to there?
A
First group I spoke to was -- on the 11th
of January was the hospital staff
. That includes all
the doctors that want to go, the nurses, technicians,
then the administration .
•
How large was that audience?
A
I would say probably 100 people there .
That's a real guesstimate .
•
Did you directly approach Dr
. Vidas or was
he just a listener at the presentation you made in
Page 20
1
January?
2
A I don't think he was there .
3
Q Do you know how he got involved?
4
A
I do .
5
Q
How's that?
6
A
He, I believe, saw one of the signs ; and he
7
called my daughter, and she referred him, said to call
8 me because he wanted to get involved in the medical
9 aspects of this
.
10
Q
Do you know Dr. Bill Scott?
11
A I do now .
12
Q When did you meet him?
13
A I first met him when -- well, there was a
14
letter that PDC had on their initial -- I don't know if
15
it was initial, but there was a letter from -- on the
16
OSF stationery, the logo, from actually an employee of
17
his in support of PDC .
18
Q An employee of Dr
. Scott's?
19
A
He's an employee of the hospital but in
20 Dr
. Scott's division of occupational environmental
21 medicine .
22
Q
How did that cause you to get to know
23 Dr.
Scott?
24
A Well, we wanted to know on what authority
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10/27/06 John McLean
Condenseltr'"
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about continuing what I was doing which was teaming and
trying to get people to be knowledgeable about the
presence of it.
And then I got a call from Dr
. Zwicky on a
Monday about a month later, and he said that he would
like me to come to the Saint Francis Executive Committee
and talk . He asked me to call Dr . Steve Smith at
Methodist Hospital who is the chief of staff there
because he wanted me to come to the staff meeting -- the
executive committee at Methodist . He asked me to call
Dr
. McRae at Proctor to do the same thing out there .
Q
And did you, in fact, talk at the executive
committee meetings at Proctor and at Methodist?
A I did not talk to Proctor . I talked to
Methodist .
Q What was your -- let me back up a second .
There's information in the record,
including correspondence from you, I believe, talking
about a petition with 750 medical signatures on it
opposed to the landfill . Did such a petition ever
exist?
THE WITNESS : is this the --
MR. WENTWORTH : Go ahead, if you know .
A Is this the one that was sent to -- clarify
Page 24
that for me, please .
Q Let me back up and make it more simple .
Was there ever a petition circulated among
medical professionals opposed to the landfill expansion?
A A petition? No
.
Q Was there ever a letter signed by multiple
medical professionals evidencing their opposition?
A Well, I knew that Dr . Zwicky -- only what
Dr . Zwicky read at the hearing .
Q You were not involved in any of that then
is what you're telling me?
A No .
MR. WENTWORTH : This question was correct?
THE WITNESS : Yes.
MR . MUELLER : Thank you, Mr . Wentworth .
MR . WENTWORTH : Sorry .
MR . MUELLER : That's okay .
BY MR . MUELLER :
Q There's a reference in the record to 750
doctors being opposed to the expansion, and I guess my
ultimate question is : Are you aware of any
documentation evidencing that number?
A No .
Q Did you solicit any donations to Peoria
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he had written this -- signed this letter .
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Q We, meaning you or --
A
Actually, the administration was aware of
this letter, and they were puzzled by it .
Q Do you recall the name of the person that
signed the letter just so we can reference it?
A I never heard his name
. Do not know him .
Q When you say the administration of the
hospital, who are you referring to?
A
Q
Keith Steffen and Sue Wozniak.
Who approached Dr . Scott then about this
person who reported Dr . Scott having written this
letter? Was it you or the administration?
A It was the administration .
Q How did you get involved in that?
A Well, I brought the letter in when we found
it and asked them about it, and they then were puzzled
by it ; and they followed up on that, and they called
Dr. Scott and the rest --
Q Okay . Now I understand . You brought the
letter in?
A
Right .
Q The administration followed up with
Dr
. Scott?
Page 22
A Right .
1
2
Q And that resulted in a conversation at some
2
3 point between you and Dr . Scott?
3
4
A Yes . They wanted Dr. Scott to correct
4
5 that -- they wanted to rectify whatever this letter
5
6
implied by their employee
. My impression was that it 6
7 was unauthorized . I don't know that, though .
7
8
Q Did you then convey information to
8
9 Dr. Scott regarding the health -- potential health
9
Io impacts of landfilling?
10
II
12
A No.
Q
You never talked to him about the merits of
I I
12
13 the proposal?
13
14
A Well, subsequently, the administration
14
15 decided to have him testify or -- yeah, testify . So
15
i6 they arranged for that .
16
17
Q Were you involved with organizing medical
17
18 opposition at any of the other medical facilities in
18
I9 Peoria?
19
20
A Well, I don't know what you mean by
20
21 organize
. I tried to educate them
.
21
22
Q Fair enough .
22
23
A What transpired is after I talked to
23
24 Dr. Zwicky -- I mean to the Saint Francis staff, went 24
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Families or other groups such as the Sierra Club from
other medical professionals?
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Page 27
No . I really don't .
Did you ever solicit South Side Bank to
A
Yes_
Q And where did you solicit?
A Radiology Department at Saint Francis,
donate any money?
A
Q
No.
You never made a public comment during the
neurology/neurosurgery at Saint Francis --
are you
talking about physicians?
siting hearing, did you?
A I did not .
Q Is there a reason why?
MR . WENTWORTH : If you want to answer that
.
A I will
. I have a cardiac problem, and I
Q Yes .
A Although I didn't talk to too many
physicians at Proctor, I know they gave as a group, as
did the stall physicians at Saint Francis and Proctor
gave money as a group
.
get very nervous and it affects me adversely
.
Q So you just didn't want to be in front of
Q Do you remember how many total
presentations you made to groups opposed to individuals
during the time that the application was pending,
meaning up through May 3rd?
that kind of crowd?
A That's correct .
Q It's understandable
. Doctor, did you ever
gain an understanding of what the rules and procedures
were that would be applied to the County Board's
decision-making process?
A
All groups?
Q Yes .
MR . WENTWORTH
: All groups or medical
groups?
MR . MUELLER . All groups.
A I talked at the Moss-Bradley Homeowners
A I think I had the average understanding of
that.
Q What was your understanding regarding the
question of whether individuals could communicate with
Association to let them aware of the presence of the
County Board members outside the hearing process?
landfill and the upcoming issue to be decided . I talked
A Well, it was my understanding that you
Page 26
Page 28
I to the Uplands . I talked to hospitals, as you know
.
1
could talk to your elected officials any time
.
2
Q
Let me stop you for a second there . That
2
Q
From whom did you gain that understanding?
3 would have been two presentations at Saint Francis, one
3
A
Civics class .
4
to the group of 100, one to the executive committee, and
4
Q
I was going to say other than your high
5 then a presentation to the executive corm ittee at
5 school civics teacher
.
6 Methodist?
6
A
A lot of people around me told me that .
7
A Correct .
7
Q
Did you understand that -- strike that .
8
Q
Any other presentations to doctors or
8
Did you perceive the county's
9 medical groups?
9
decision-making process as being legislative or being
to
A Not that I can remember
.
10
adjudicatory?
1 1
Q
Any other presentations to the general
11
A
My understanding from reading it was both,
12
public besides the two that you mentioned?
12
but I don't have a real profound insight into what I
13
A
I did -- well, I wouldn't call it a
13 think is the complexity of that issue
.
14
presentation, but there was a school that Teddy Converse
14
Q
Did you periodically monitor the Peoria
15 and I talked at
. Actually, what I talked about was what
15
Families website?
16 I had learned about aquifers
. I didn't talk about
16
A No.
17
anything other than what I teamed about aquifers which
17
Q So it would
be fair to say you never
18
was considerable because I didn't know anything about
18 offered any content
for the website?
19
them
. It was like a geology lesson for me, and I passed
19
A I was -- the only content, they asked me to
20 it on to them.
2o
go out and take pictures of the landfill . I did that
.
21
Q Was this like in the grade school in the
21
Q
When did you go out and take pictures of
22 Peoria area?
22 the landfill?
23
A Right, exactly .
23
A
Let's see . I would say it was in January .
24
Q Do you remember which one?
24
Q
Do you remember from what location you took
10/27/06 John McLean
CondenscIt m`
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them'?
A
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letter addressed to Fellow Democrats?
Yeah. It was Aspen Bluff, I believe, it's
A
Q
A
Right .
Did you author this document?
Well, it was sent out . As I say, I saw
called, but it was on Marengo Street .
Q The pictures, I believe, showed up on the
Peoria Families website, correct?
this for the first time to my knowledge yesterday when
A
Correct
.
Dave Wentworth showed it to me
.
Q
Were you the person that provided the label
Q So the answer is you didn't author it?
toxic stacks that was attached to an item depicted in
A Well, I mean, I
-- no. I mean, my name's
the photograph that you took?
on there. And if I may, I talked to my wife about this
last night; and she vaguely remembers something about
it, and it was an e-mail that they were sending this
A
Q
No.
Were you the person that provided the
information that part of what you photographed was a
toxic stack?
out . I can't say any more than that .
Q How well do you know Jean Roach?
A Very peripherally .
Q Are Jean Roach and your wife friends?
A
Well, they're just acquaintances that we've
A
Q
Say that again.
Were you the person that provided the
information that part of what you photographed was a
toxic stack?
A No.
Q Did you ever write any letters to County
met through this issue.
Q Now, your wife Cindy McLean was active in
the Peoria Families group, correct'?
Board members?
A
I wrote a letter to my County Board
A
Yes.
Q
And was she, in fact, the de facto
representative Jim Thomas
.
treasurer of the group?
Q And when was that letter written?
A I think it was towards the end
. I'd say it
A
Q
Yes
.
Were you involved in the handling of any of
Page 30
Page 32
I was in late February .
I the money?
2
Q Were you aware that there was a cutoff date
2
A No.
3 after which people were no longer supposed to submit
3
Q
Did you do any of the accounting or make
4 material and contact the board?
4 any of the deposits or log any of it in?
5
A Yes .
5
A No.
6
Q And did you -- let's back up .
6
Q Your wife did all of that?
7
What was the content of your letter to
7
A
Yes .
8 Board Member Thomas?
8
Q Is it your belief that your wife is the
9
A
Well, I wrote that longhand, I believe --
9 person that authorized your name to be included on
10 not longhand, but I typed it . I sent it by snail mail,
10 Exhibit 94A?
I I
and I don't have a copy of it; but the bottom line is
11
A No. I mean, I -- she probably told me
12 that I wanted him to vote no
.
12 about it, you know, but I can't say more than that
. I
13
Q And, obviously, you wanted him to take your
13 can't blame her
. She's probably -- I sometimes don't
14 recommendation into consideration in making his
14
listen, I guess .
15 determination?
15
Q To your knowledge, is that a true and
16
A Exactly .
16 correct copy of the letter that was sent?
17
Q
Did you co-author or co-sign any other
17
A I don't know .
18 written communications to board members?
18
Q If you look at Exhibit
B, which is the
19
A Well, I learned I did that yesterday for
19
third page, that purports to be an e-mail from Cindy
20 the first time.
20 McLean to Dave Williams.
Have you ever seen that
21
Q Let me show you, in fact, what's been
21
before?
22 marked as Group Exhibit Number 94, and it purports to be
22
A I may have seen this
.
23 a letter dated March 30th, 2006
. It's a group exhibit .
23
Q That purports to be signed by Cindy and
24 The first page I'm talking about, A, purports to be a
24 John McLean?
10/27/06 John McLean
Condenselt'r"
RTIN
ERVICE (309) 690-3330
PDC v. PCB
Page
33 - Page 36
I
2
3
4
5
6
7
8
9
10
I 1
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 33
A
Right
Q
Did you author it, or did Cindy?
A I guess we both did
. 1 mean, I don't know
I
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Page 35
A No .
Q When you first talked to Bill Scott about
the letter that had been written by someone he
supervised, did he ever advise you that he does work for
Peoria Disposal Company?
what to say .
Q This e-mail, by the way, makes reference to
the Illinois State Medical Association passing a
resolution and sending it on to the AMA?
A
I don't think I talked to him about that .
Q
I thought you said you got to know him in
A Okay .
Q
Who introduced that resolution at the
connection with that letter?
A
I did, but I got to know him only at the --
Illinois State Medical Association?
before the hearing when the administration decided to
A I don't know, but I know that Dr
. Vidas
have him
time .
write a letter
. I had not met him until that
talked to us about that
. I don't know if it was the
Peoria Medical Society or what
. I'm not sure .
Q Did you have any role in drafting the
Q
I guess I'm still not understanding why
--
how you would get to know him based upon the
resolution referred to in this exhibit or getting it
administration asking him to write a letter .
before the State Medical Association?
A
Well, they referred me to him in the sense
A
No .
Q
If I could direct you to the next page
which is another Fellow Democrats letter, this one dated
April 27th, this, again, appears to be signed by Jean
and El mo Roach as well as your wife and yourself?
that they said that he was the superior to this person
and that he would be the one that would read the letter
to clarify this issue
.
Q
So, if I understand you correctly, you met
with him for the purpose of helping him write his
A Right .
letter?
Q
Did you author this document?
A
Here again, I just saw this yesterday, and
A No
. I did not .
Q
Where did you meet with him?
Page 34
Page 36
1 same thing applies
to what I said about the first one .
I
A
I think the first time I met with him was
2
Q That expedites
the questioning . If I could
2
just before he was to go to the hearing
.
3 direct your attention to the second to the last
3
Q
And do you remember where that occurred?
4 paragraph that starts with, "Studies around the globe,"
4
A
I'm not sure, but I think I went over to
5 there's a reference here that says, "The European Union
5 his office to tell him what time he was supposed to be
6
of 25 nations has banned all hazardous chemical and
6 there, things like that .
7 metal landfills as of this July
." Do you know what the
7
Q Did Dr . Scott ever provide you with any
8 source of that piece of' information is?
8
information regarding Peoria Disposal Company or any of
9
A
No.
9 its practices or operations?
It)
Q Is that information that you secured?
10
A No .
11
A No.
11
MR . MUELLER
: Let's take a short break . We
12
Q
Do you know whether or not that information
12 may be done .
13 is, in fact, true?
13
(Recess in proceedings from 10 :00 a .m .
14
A
No, I don't .
14
to 10 :05 a.m .)
15
Q There
was a medical or a press conference
15
MR . MUELLER
: Dr . McLean, thank you very
16
held by a group of doctors at the Twin Towers on March
16 much . We don't have any further questions
.
17 27th . Were you
a participant in that?
17
MR . WENTWORTH
: We reserve signature .
18
A I did not talk. I was there.
18
10:05 A.M.
19
Q Were you one of the organizers of that?
19
20
A Let's see . I think I might have called
20
21 Eric hlwood I don't know
. I don't know . I can't be
21
(Further deponent saith not.)
22 sure .
22
23
Q
Do you know who the other organizers were
23
24
of that press conference?
24
10/27/06 John McLean
CondenscIt' T''
SIVERTSEN REPORTING SERVICE (309) 690-3330
PDC v PCB
Page 37 -
Page 39
PEORIA DISPOSAL COMPANY,
pa g e 37
)
Petitioner,
)
.
No PCB 06-154
4 PEORIA ( 'ill "STY BOARD ,
Respondent .
t
7
I hereby certify that I have read the
foregoing transcript of my deposition given on October
S 27, 2006, at the time and place aforesaid, consisting of
pages I through 36, inclusive, and I do again subscribe
9 and make oath that the same is a true, correct, and
mpletc vanscnpi of my deposition so given as
alun n md
Please check one.
I have submitted errata sheet(s) .
No corrections were noted .
tORN McLFA
20 SUBSCRIBED AND SWORN TO
before me this
day
21 of
,A .D .2006
Notary Public
)4 My ( nmmlss,on expires
Page 39
1 deposition is taken, and further that I am rot a
2 relative or employee of any attorney or counsel employed
3 by the parties hereto or financially interested in the
4 action
5
In witness whereof, I have hereunto set my
.
6 hand and affix
;~:Lx
notarial uat October 31, 2,00(
.
7
8j
9
10
/
I I
Angel . Jones, CSR-RPR
12
Illinois CSR YORFW34S2
Commission Expires 4/302010
13
14
15
16
OFFICIALSEAL
17
NOTARY PUBLIC
STA
JONES
18
TEOOFILLINOIS
19
MY COMMISSION EXPIRES 4,90.2010
20
21
22
23
24
STATE OF ILLMOIS
)
Page 38
SS
2 COLINYOF TAZEWELL)
3
4
CeariFtrATE
S
6
I, Angela M . Jones, CaR-RPRR
a Notary
7 Public duly commissioned and qualified in and for the
8 County of 'farewell, State of Illinois, do hereby certify
9 that there came before me on October 27, 2006, at 416
10 Man Street, Suuc 1400, Peoria, Illinois, the following
I I
named person . m air.
12
JOIN MCLEAN .
13 a wa ess, who was by me first duly sworn to testify to
14 the truth and nothing but the truth of his knowledge
15 touching and concerning the matters in controversy in
16 this cause, and that he was thereupon carefully examined
17 upon his oath and his examination reduced to shorthand
18 by means of stenotype and thereafter converted to
19 typewriting using computer-aided translation by me .
20
I also certify that the deposition is a
21
true record of the testimony given by the witness.
22
I further certify that I am neither
23
attorney or counsel for nor related to or employed by
24 any of the psoes to the action in which this
10/27/06
John McLean
Condenselt
17N
Academy [21
7 :11
7 :18
accept [11
16
:13
accordanceui 4 :16
accordingly [q 17
:22
addressed
111
31 :1
adds p l 17:23
adjudicatory28
:10
111
administration [91
19:19
21 :3
21 :13
21 :8
21 :14
21 :23
22 :14
35:10
35 :15
administrator18
:12
Ill
advantage
I11
18:2
advantages [11 18:1
adversely
pl
27 :11
advise Ill
35:4
advisory [t l
7 :21
affects
p 1
27:11
affix p) 39 :6
aforesaid
[21
3710
37 :8
again 16)
6:11
14:1
29 :14
33
:20
33:24
37 :8
Against [2)
11 :15
12:1
ago [s) 6
:24
8:6
8:3
10:4
11 :3
agree p
1
16:12
agreed pl
1710
agreement
111
4:17
ahead [2)
17:12
23:23
Alaskat2)
8:12
8:15
AMA [I)
33:7
amazing
I11
19:7
American
[1] 7 :17
among ] 1l
24:3
Angela p]
1 :0
38:6
39 :11
announce [i) 19:8
announced pi 9:1
answer (2)
27:9
31 7
answering[) 12 :22
APPEARANCES2:1
[I)
application fit 25:15
applied p l
27:17
applies
(11
34:1
approach [21
19:23
18:20
approached [1] 21 :11
April It]
33:20
aquiferp]
17 :17
aquifers
[21
26:16
26:17
area p1 5:19
17 :9
26:22
arrange [2]
18 :14
18:14
arranged p)
22
:16
ars [1]
6:19
arsenic It 1
6:13
arsonic p l
6:10
articles It 1
13 :8
asbestos [2)
6:21
6:19
aspects [2)
12:17
20:9
Aspen Ill
29
:2
association [5] 13 :13
25 :23
33 :6
33:10
33 :16
assuming
[11
13 :18
astounding
111
19:5
attached
I
I I
29:8
Attachments ill
3:14
attend[,)
12:3
attention 11
34:3
attorney p]
4:11
38:23
39:2
audience
[I
1
19.20
author (4)
31 :7
31 :3
33:2
33:23
authority
Ill
20 :24
authorized
III
32:9
Avenue
Ill
4:19
average
111
27 :19
aware16:13 [91
16:16
1619:2.4
19:6
21 :3
24
:21
25 :23
30:2
awarenesses
16:21
It)
B[I1
32:18
babies [I)
13:14
balance
111
17 :24
Bank 11] 27.2
banned
111
34
:6
barrierp]
16 :18
barriers ill
16 :6
based [2)
16 :20
35:14
basic
Ill
14 :10
became [ t
l
19 :4
become
[31
7:24
8
:17
16 :2
began [2)
6:4
6 :9
beginning pl 14 :24
behalf [41
2:12
2:8
2 :17
12 :11
belabor[tl
8:23
belief p)
32 :8
belong[l)
7:17
best
pl
15:20
better p l
1 :20
between
111
22:3
beyond
111
14:10
BiII
[2)
20 :10
35:2
Birdsall
111
2:15
birth p) 13
:14
Black [21
2 :11
2 :11
blame[,]
32:13
Bluff [11
29:2
Blumenshine 111
10:23
board [91
1 :0 27 :23 29
1
:0
:20
2930:21:18 30:4
30:8
37 :4
Board's
[I]
27:17
boards p)
7:21
book[ I1 14 :6
books
[21
14:8
14
:5
borderline [q
6:24
bottom[n
30 :11
break III
36 :11
BRIAN 111
2:6
brought [31
21 :16
15 :17
21 :20
Brown
[21
2 :11
2:10
bumped
[I)
18:24
calamities III
17:22
cancer
II)
13:15
capacity p)
5:21
cardiac
III
27:10
carefully 11]
38:16
caused
[31
8:17
7 :24
16 :21
Century p)
15:11
CERTIFICATE p l
38 :4
certify [4)
37:7
38:8
38 :20
38:22
chapters [I 1
15 :23
characterization ill
17 :11
check p
l
37 :12
chemical p)
34 :6
chief [2) 18:9
23 :8
chlorinated
[21
16 :10
16:14
Cindy [41
31
:18
32 :19
32:23
33 :2
Cindymclcan®mac .co m
[1]
5:9
circulated Ill
civics
28:5
[2)
clarify
[2)
35:19
23 :24
class p] 28 :3
close
[21
10
:10
12:7
Club
[s)
8:5
9
:17
9:19
11 :2
25:1
CMEp)
15 :4
co-author [11 30 :17
co-sign (1]
30 :17
Columbus 11] 2 :3
commencing
1 :0
111
comment p
I
27 :5
Commission
[21
communicate
27 :22
[I1
communications [it
computer-aided 111
38 :19
concern ill
19 :2
concerning Ill 38
:15
conference
[2)
34:15
34 :24
conferences pl 14 :22
15:1
15:4
confused p)
14 :1
confusing [Il 13:11
connection 111 35 :8
consider pl
11 :24
28 :19
30:7
24:3
28 :3
SIVERTSEN REPORTING SERVICE (309) 690-3330
#084-003482 - content
Index Page I
38 10
14thp1 10 :8 10 :23
11 :12
17141114
:19
1971 [214
:22 5:20
19991315 :14 5:20
5 .22
2005 121 10 :6
10:9
2006161 1 O
30:23
37 :8
37 :21 38:9
39 :6
204[]1 2
:3
21stp) 15 :1]
25it1
34 :6
27131
37:8
38 :9
27th
121
33.20 34.17
3/30/06111
3:14
4/30/2010 I11
41638
:9pl
1
:0
528 Ill 2:3
61350111
61550111
616021212
16
61606111
674-7316111
39 :12
2:7
2:4
2
:12
2:8
4.20
4:24
71 p)
17:19
750 [21 23 :19 24:19
911]
1 :0
94[21
3
:13
30.22
94A ill
3210
A .D 111 37 21
a.m141 1 :0
36:13
36:14
36:18
able It] 14 :6
absolutely 111 19:7
account
5 :6
[2)
accounting [11
5 :1
32
:3
acquaintances I I)
31
.16
acquiring [31 8:22
15:13
15 :14
action [21
38 :24
39:4
active [51
7:12
7
:14
7
:20
15 :1
31
:18
actively
[31
5 :10
9 :9
11
:8
actual Ill
14 :11
Adams 111
2:16
address
4:21
[41
4:18
5:4
5:8
30:18
community17:23
[31
7 :6
18 :4
Company [41 1 :0
35:5
36:8
37:1
competent p 1 17:20
complete 11I 37 :9
complexity 111 28:13
#084-00348211139
12
00111
36:13
05 [3)
l:o 36:14
36 :18
06-184(2137
:3
1
:0
1
111
37 8
10111
36 .13 36_14
3618
10/27/06111
1 :0
100121
19 :21 26 :4
101111 2 :11
11th[]) 19 :16
124111 2 .16
1400131 I 0
2 :7
37:24
39:12
commissioned38:7
p ]
Committee [51 23 :6
23:10
26 :5
23:13 26 :4
committees p 1 7:21
30111
3 :13
309p]
4 :24
30th III 30:23
31 III 39:6
36[11 37:8
360111 2:16
3rd li1
2516
4pl
34
considerable 111
26:18
consideration Ill
30:14
consistent p ] 12:8
consistently izi
9 :23
9:24
consisting [1) 37:8
contact [I]
30:4
content
[31
28:18
10/27/06 John McLean
Continued [II
15 :6
continuing [31 15 .7
15 :10
23-1
CONTROL
111
1
:0
controversy[
I1
38
:15
conversation
22 :2
[ I1
Converse
[61
5 :24
8 :3
9 :6
11 :11
12 :6
26
:14
converted
1u 1
38 :18
convey I11
22
.8
COPY 121 30
. 1 1
32
.16
correct 1201
6'.1
6:2 10:7 10
:12
12 :23
12 :24 13 :18
14 :3
14 :13 16
:12
17 :17 22 :4
24 :13
26 7
27
:14 29 :5
29 6 31:19 32:16
37
.9
Correct ion p] 7:17
corrections [ I1 37
:14
correctly I11 35 :20
correlation p] 13 :15
correspondence
II I
decision-making
[21
27 :18
28 :9
definitely
[I I
13
:4
delve
111 13:17
Democrats [21 31 1
33
:19
Department [1125 :5
Condenselt
effects [2]
16 :9
17 :11
effort
I i 1
12 :11
efforts
[I l
8,11
elaborate
[11
16 :17
elected p
1
28'.1
Elias p12 :7
Elmo
M
33
:21
Elwood p 1
34 :21
employed
[31
5 :21
38 :23
39 :2
employee
Isl
20 :16
20 :18 20 :19 22 :6
39 :2
end [2] 8 :6
29 :24
engineered
[21
16 :6
16 :17
environment[]]
8 :14
environmental p]
8 :4
8
:11
20 :20
Eric [I]
34 :21
errata p1
37 :13
ESQUIRE [s]
2:3
2 :6
2 :6
2 :10
2 :14
European It I 34
:5
eventual ly p ] 9:13
evidencing
[21
24 :7
24 :22
evolution p]
11 :22
exactly pl
9 :3
26 :23
30 :16
examination [41
1 :0
3 :4
4 :5
38 :17
examined [21 4 :4
38 :16
example [I]
14 :5
except
p]
13
:12
executive [5] 23 :6
23 :10
23 :12
26 :4
26 :5
exhibit
[7]
3 :13
3 :24
30 :22
30 :23
32 :10
32 :18
33
:15
EXHIBITS In 3
:12
exist
pl
23 :21
expansion [61 7 :2
9 :10
16 :17
16 :22
24 :4
24 :20
expedites
(1)
34 :2
experience [41 6 :16
6 :19
7
:1
8 :15
expires [2]
37
:24
39
:12
explanation [I] 18 :6
exposure [1]
6 :19
exposures [21 6 :9
6 :13
facilities [2]
7 :22
22 :18
facility p]
18 :1
fact [s]
17 :10
23 :12
SIVERTSEN REPORTING SERVICE (309) 690-3330
30 :21
31 .21
34 13
facto p 131 :21
fair [4)
17
:7
17 :8
22 :22
28 :17
fairly
171
14 :23
fall p1 10 :6
Families [7]
11 :15
12 :1
13 :3
25 :1
28 :15
29 :5
31.19
Families' p]
12 :11
family [21
6 :15
6 :18
father
[
11
5 :24
Februaryp] 30 :1
federal p]
16 :5
Fellow [21
31 :1
33 :19
felt [2]
17 :18
18 :3
fewp]
9:18
filtered
[I]
15 :19
finally p]
15 :9
financially
p] 39 :3
first p514 :3
7 :24
8
:8
8 :19
11 :1
15 :17 19 :16 20 :13
30 :20 30 :24 31
:5
34 :1
35 :2
36 :1
38 :13
follow-up
[11
8 :21
followed [21
21 :18
21 :23
following p
1
38 :10
follows p]
4 :4
foregoing [13 37 :7
forget [11
9 :3
format[I]
18 :16
formation
p 1
11 :14
Forrestp]
8 :5
found [51
13 :10
13 :19 15 :23 19 :7
21 :16
founders
121
11 :19
12 :7
fourp]
7:8
Francis p q
13
:21
14 :2
14 :15 15 :2
15 :18 22 :24 23 :6
25 :5
25 :6
25 :11
26 :3
frankly [I]
11
:23
Friday
[2]
1
:0
15 :4
friends [I
1
31
:15
front [11 27 :12
full p] 4 :7
gain [2] 27:16
28 :2
gained
[2]
6 :4
6 :9
gamble
[2]
17 :23
18 :3
general
[I]
26 :] 1
geology [1]
26 :19
GEORGE [1] 2 :3
Continued - hour
given [41
17 :10
37 :7
37 :9
38 :21
giving [l l
8 :24
globe
[II
34 :4
gone p] 16 :24
grade p]
26 :21
granddaughter
pI
guesstimate [I] 19 :22
hall p] 19 :1
handy] 39 :6
handling p
1
31 :24
happening[i] 8 .14
Hasselberg
[ 112 :15
hazardous [s] 6 :5
6 :16
7 :2
8 :1
34 :6
head p] 7:7
health [4]
16 :3
17 :11
22 :9
22 :9
heardpi
21 :7
hearing [s]
24 :9
27 :6
27 :23
35 :10
36 .2
hearings [2]
6 :4
6 :9
heavy
[41
6 :10
6 :13
6 :20
6 :22
held[I] 34 :16
helpful
[I3
15 :23
helping
111
35 :21
hereby [21
37 :7
38 :8
herein [I]
1 :0
hereto p]
39 :3
hereunto [11
39 :5
high [I] 28:4
hold
[I] 7
:9
home
p ]
4 :23
Homeowners [v
25 :22
honorary p]
14
:16
14 :17
14 :17
hooked[I]
10 :1
hospital [101 13 :22
14 :2
14 :15 18 :11
18 :21 19 :12 19 :17
20:19
21 :9 23 :8
hospitals p1 7 :5
7 :22
26 :1
hourpl 1 :0
Index Page 2
depicted
[1)
deponent[1]
deposition
16]
29 :8
36
:21
1 :0
37 :9
1 :0
32 :4
[21
9 :8
33.18
18 :20
15 :18
4 :15
12.18
1 :0
6 :16
37 :1
20 :20
4 :9
7 :24
15
:14
26 :8
31 :3
4 :15
38 :20
37 :7
39 :1
depositions p]
deposits m
determination
9 :12
30 :15
determine
11 .7
121
direct 121
34 :3
directly [2]
19
:23
director
[2]
18 :10
discovery
III
dispersed [21
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