File No . 05611-105

Illinois Pollution Control Board

100 W

. Randolph, Suite 11-500

Chicago, IL 60601

Ladies and Gentlemen :

Enclosed you will find the original and four copies of Notices to Appear for

Discovery Deposition for the following individuals for the above referenced case :

1 .

Jim Thomas ;

2 .

Mike Phelan ;

3 .

Lynn Scott Pearson ;

4 .

Russell Hauppert;

5 .

Carol Trumpe;

6 .

Phil Salzer ;

7 .

Allen Mayer ;

8.

Dave Williams ; and

9 .

Junior Watkins .

Please file and return the excess copies to me in the self addressed envelope provided

herein .

Thank you for your anticipated cooperation in this matter .

Very truly yours,

JN/jmr

cc

:

David A. Brown

Kevin Lyons

George Mueller

Chris Coulter

ELIAS, MEGINNES, RIFFLE & SEGHETTI, P.C

.

ATTORNEYS AT LAW

JOHN S . ELIAS

416 MAIN STREET, SUITE 1400

DAVID N . SCHELLENBERG

BRIAN ) . MEGINNES

PEORIA, ILLINOIS 61602-1611

JANAKI NAIR

ROBERT M . RIFFLE

TELEPHONE : (309) 637-6000

SONYA A . PASQUINI

MICHAEL R. SEGHETPI

FACSIMILE: (309) 637-8514

CYNTHIA L . ELIAS . OF COUNSEL

TROY N . PUDIK

w ww.emrslaw.com

RE: Peoria Disposal Company v

. Peoria County Board

PCB 06-184

August

R ECEIVED

006

RAs,NA

L

CLERK'S

SEP 0 5

OFFICE

2006

Pollution

ATE

OF

ILLINOIS

Board

pcblever

---

PEORIA DISPOSAL COMPANY,

)

Petitioner,

)

v.

)

PEORIA COUNTY BOARD,

)

Deponent .

)

TO :

JAMES THOMAS, County Board Member

c/o Mr. David A

. Brown

Black, Black & Brown

101 South Main Street

P.O . Box 381

Morton, Illinois 61550

You are hereby notified that you are required to appear and testify at a discovery

deposition, on Tuesday, September 12, 2006, at 9

:00 a .m ., at the law offices of Elias,

Meginnes, Riffle & Seghetti, P .C ., 416 Main Street, Suite 1400, Peoria, IL 61602,

and

you are hereby further notified that you are required to produce at the deposition, all of

the documents or tangible things identified in Rider A, attached hereto

.

Respectfully submitted,

Peoria Disposal Company, Petitioner

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

(815) 431 .1501-Facsimile

george(a),, m uelleranderson .com

RECEIVEDCLERK'S

OFFICE

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

SEP

0 5 2006

Pollution

STATE OF

Control

ILLINOIS

Board

NOTICE TOAPPEAR

FOR DISCOVERY DEPOSITION

1

PCB 06-184

(Pollution Control Facility Siting Appeal)

BRIAN

EG

NE

d

GEORG

L R, Its Att

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria,

Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637.8514-Facsimile

b meginnespemrslaw.co m

---

RIDERA

All documents in the possession or control of JAMES THOMAS

("Deponent") referring to the Application that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107 .300.

2.

All documents in the possession or control of Deponent referring to Peoria

Disposal Company that were not included in the Record filed with the Pollution Control

Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

3.

All documents in the possession or control of Deponent received from any

member or representative of the Heart of Illinois Sierra Club that were not included in

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300.

4 .

All documents in the possession or control of Deponent received from any

member or representative of the organization Peoria Families Against Toxic Waste that

were not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300.

5.

All documents in the possession or control of Deponent received from any

member or representative of the organization Citizens for Our Environment that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107

.300 .

6 .

All documents in the possession or control of Deponent received from any

member or representative of the organization River Rescue that were not included in

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

(815) 431-1501

- Facsimile

georgena, m uelleranderson

.com

2

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637-8514 - Facsimile

bmeginnes(a? e mrslaw.com

---

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107.300 .

7.

All documents in the possession or control of Deponent portraying the

PDC 1 landfill or any property located within one (1) mile of the PDC 1 landfill that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107

.300.

8 .

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, considered by the Deponent regarding the Application

.

9.

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, available to the Deponent in its consideration of the

Application .

10 . All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Heart of Illinois Sierra

Club that were not included in the Record filed with the Pollution Control Board pursuant

to Illinois Administrative Code Title 35, Section 107 .300

.

11 .

All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Sierra Club that were not

included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300 .

12 .

All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the organization Peoria

Families Against Toxic Waste that were not included in the Record filed with the

3

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431-1501

- Facsimile

(309) 637-8514 - Facsimile

george(a),muelleranderson .cam

bmeginnesna,e

mrslaw

.co

m

---

Pollution Control Board pursuant

to

Illinois Administrative Code Title 35, Section

107 .300.

13. All documents in the possession or control of Deponent received from or

authored by Citizens for Our Environment that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

14 . All documents in the possession or control of Deponent received from or

authored by River Rescue that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

15 . All documents in the possession or control of Deponent received from or

authored by Tom Edwards that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

16 . All documents in the possession or control of Deponent received from or

authored by Kim Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300

.

17 . All documents in the possession or control of Deponent received from or

authored by Joyce Blumenshine that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107 .300 .

18.

All documents in the possession or control of Deponent received from or

authored by Diane Storey that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

(815) 431-1501 - Facsimile

george(a muelleranderson .com

4

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(309) 637

.8514-Facsimile

bmeginnes(&emrslaw .com

---

19 . All documents in the possession or control of Deponent received from or

authored by Jean Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

20 . All documents in the possession or control of Deponent received from or

authored by Elmo Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

21 . All documents in the possession or control of Deponent received from or

authored by Amy Schlicksup that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

22 . All documents in the possession or control of Deponent received from or

authored by Cara Rosson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

23 . All documents in the possession or control of Deponent received from or

authored by Tessie Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

24 . All documents in the possession or control of Deponent received from or

authored by Tom Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

25 . All documents in the possession or control of Deponent received from or

authored by Mayvis Young that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

5

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602 .1611

(309) 637-6000 - Telephone

(815) 431-1501 -

Facsimile

(309) 637-8514 - Facsimile

george(admuelleranderson .co m

bmeginnes(&emrslaw .co m

---

26.

All documents in the possession or control of Deponent received from or

authored by Lisa Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

27. All documents in the possession or control of Deponent received from or

authored by Peter Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

28 . All documents in the possession or control of Deponent received from or

authored by Cathy Stevenson that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

29 .

All documents in the possession or control of Deponent received from or

authored by Beth Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

30 .

All documents in the possession or control of Deponent received from or

authored by Jeff Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

31

. All documents in the possession or control of Deponent received from or

authored by Bill Scott that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

32 .

All documents in the possession or control of Deponent received from or

authored by Ted Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

(815) 431-1501 - Facsimile

george(7am uelleranderson .com

6

BRIAN J . MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637.8514-Facsimile

bmeginnes(q? emrslaw.co m

---

33 . All documents in the possession or control of Deponent received from or

authored by Bill Cook that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

906-1153

7

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431-1501 -Facsimile

(309) 637-8514 - Facsimile

george(a? m uelleranderson.co m

bmeginnes(a) emrslaw.co m

---

STATE OF ILLINOIS

COUNTY OF PEORIA

The undersigned further states that a copy of the foregoing NOTICE TO

APPEAR

facsimileFOR and

DISCOVERY

by enclosing

DEPOSITION

copies of

was

same

served

in separate

upon

envelopes,

the following

addressed

personsas

setby

forth below, and depositing said envelopes in a U .S . Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5 :00 p .m

., with all fees thereon fully

prepaid .

Mr. David A. Brown

Black, Black & Brown

101 South Main Street

P

.O

. Box 381

Morton, Illinois 61550

(309) 266-9680 - Telephone

(309) 266-8301 - Facsimile

dbrown(o-)

b lackblackbrown .co m

Subscribed and sworn to before me

this 31st day of August, 2006 .

-

u

AVA

i

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

(815) 431-1501 - Facsimile

george(g)m

uelleranderson .co m

AFFIDAVIT OF SERVICE &FILING

The undersigned being first duly sworn on oath, states that a copy of the

foregoing NOTICE TO APPEAR FOR DISCOVERY DEPOSITION was served upon the

following persons by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U .S . Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5 :00 p .m ., with all fees thereon fully

prepaid .

OFFIGAL SEAL

NOTARY

W COMMOScN EXPIRESSTATE

ILLINOIS

0& 11-0r

Mr

. Kevin Lyons

Peoria County State's Attorney

324 Main Street, Room #111

Peoria, Illinois 61602

(309) 672-6029 - Facsimile

Bria

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(309) 637-8514 - Facsimile

bmeginnes(Demrslaw .com

Illinois Pollution Control Board

100 W . Randolph, Suite 11-500

Chicago, Illinois 60601

Ms . Carol Webb, Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

(312) 814-3620 - Telephone

P .O. Box 19274

(312) 814-3669 - Facsimile

Springfield, Illinois 62794-9274

[ORIGINAL plus FOUR (4)]

(217) 524-8503 - Telephone

webbccu,ipcb

.state,

il.u s

---

RECEIVEDCLERK'S

OFFICE

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

SEP

0 5 2006

PEORIA DISPOSAL COMPANY,

Pollution

STATE OF

Control

ILLINOISBoard

)

Petitioner,

)

PCB 06-184

V)

(Pollution Control Facility Siting Appeal)

PEORIA COUNTY BOARD,

)

Deponent

.

)

NOTICE TO APPEAR FOR DISCOVERY DEPOSITION

TO : LYNN SCOTT PEARSON,

County Board Member

c/o Mr

. David A . Brown

Black, Black & Brown

101 South Main Street

P .O. Box 381

Morton, Illinois 61550

You are hereby notified that you are required to appear and testify at a discovery

deposition, on Wednesday, September 13, 2006, at 9 :00 a .m.,

at the law offices of

Elias, Meginnes, Riffle & Seghetti,

P .C .,

416 Main Street, Suite 1400, Peoria, IL 61602,

and you are hereby further notified that you are required to produce at the deposition, all

of the documents or tangible things identified in Rider A, attached hereto

.

Respectfully submitted,

Peoria Disposal Company, Petitioner

BRIAN J . M

and

GEORGE

Its Attorneys

1

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

BRIAN J . MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431-1501 - Facsimile

(309) 637-8514 - Facsimile

george(7a, m uelleranderson .co m

bmeginnes(ahenrrslaw.corn

---

RIDER A

All documents in the possession or control of LYNN SCOTT PEARSON

("Deponent") referring to the Application that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107 .300.

2.

All documents in the possession or control of Deponent referring to Peoria

Disposal Company that were not included in the Record filed with the Pollution Control

Board pursuant to Illinois Administrative Code Title 35, Section 107 .300,

3.

All documents in the possession or control of Deponent received from any

member or representative of the Heart of Illinois Sierra Club that were not included in

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300.

4 .

All documents in the possession or control of Deponent received from any

member or representative of the organization Peoria Families Against Toxic Waste that

were not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300 .

5 .

All documents in the possession or control of Deponent received from any

member or representative of the organization Citizens for Our Environment that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300 .

6 .

All documents in the possession or control of Deponent received from any

member or representative of the organization River Rescue that were not included in

2

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309)

637-6000 -

Telephone

(815) 431-1501 - Facsimile

(309) 637-8514 - Facsimile

george(aumuelleranderson .com,

bmeginnes(d

emrslaw

.co m

---

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300.

7 .

All documents in the possession or control of Deponent portraying the

PDC 1 landfill or any property located within one (1) mile of the PDC 1 landfill that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300

.

8 .

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, considered by the Deponent regarding the Application .

9.

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, available to the Deponent in its consideration of the

Application .

10 . All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Heart of Illinois Sierra

Club that were not included in the Record filed with the Pollution Control Board pursuant

to Illinois Administrative Code Title 35, Section 107 .300 .

11

. All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Sierra Club that were not

included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300.

12 . All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the organization Peoria

Families Against Toxic Waste that were not included in the Record filed with the

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

(815) 431-1501 - Facsimile

peorcie(a).muelleranderson . coin

3

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637-8514 - Facsimile

bmeginnes(a,,

e

mrslaw.com

---

Pollution Control

Board pursuant to Illinois Administrative Code Title 35,

Section

107 .300 .

13 . All documents in the possession or control of Deponent received from or

authored by Citizens for Our Environment that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107 .300 .

14 .

All documents in the possession or control of Deponent received from or

authored by River Rescue that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300

.

15 .

All documents in the possession or control of Deponent received from or

authored by Tom Edwards that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300

.

16 .

All documents in the possession or control of Deponent received from or

authored by Kim Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

17 .

All documents in the possession or control of Deponent received from or

authored by Joyce Blumenshine that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107

.300 .

18 .

All documents in the possession or control of Deponent received from or

authored by Diane Storey that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431

.1500-Telephone

(815) 431-1501

- Facsimile

george(o)m uelleranderson.co

m

4

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000-Telephone

(309) 637-8514 - Facsimile

bmeginnes(a?emrslaw .coin

---

19 . All documents in the possession or control of Deponent received from or

authored by Jean Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

20 . All documents in the possession or control of Deponent received from or

authored by Elmo Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

21 . All documents in the possession or control of Deponent received from or

authored by Amy Schlicksup that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

22 .

All documents in the possession or control of Deponent received from or

authored by Cara Rosson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

23 .

All documents in the possession or control of Deponent received from or

authored by Tessie Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

24 . All documents in the possession or control of Deponent received from or

authored by Tom Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

25 . All documents in the possession or control of Deponent received from or

authored by Mayvis Young that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

5

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(815) 431-1500- Telephone

(309) 637-6000 - Telephone

(815) 431-1501

- Facsimile

(309) 637-8514 - Facsimile

george[o)m uelleranderson .co

m

b

mertinnes@emrslaw .co m

---

26 . All documents in the possession or control of Deponent received from or

authored by Lisa Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

27 .

All documents in the possession or control of Deponent received from or

authored by Peter Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

28 . All documents in the possession or control of Deponent received from or

authored by Cathy Stevenson that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

29 .

All documents in the possession or control of Deponent received from or

authored by Beth Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

30 . All documents in the possession or control of Deponent received from or

authored by Jeff Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

31 .

All documents in the possession or control of Deponent received from or

authored by Bill Scott that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

32 .

All documents in the possession or control of Deponent received from or

authored by Ted Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300

.

6

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(815) 431-1500-Telephone

(309)

637-6000 - Telephone

(815) 431-1501 - Facsimile

(309) 637.8514

- Facsimile

george(&, m uelleranderson .com

bmeginnes(lDemrslaw.co

m

---

33 .

All documents in the possession or control of Deponent received from or

authored by Bill Cook that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

906-1158

7

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431.1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637 .6000-Telephone

(815) 431-1501 -

Facsimile

(309) 637-8514 - Facsimile

george@muelleranderson .co

m

bmeginnes nemrslawa

.com

---

STATE OF ILLINOIS

)

SS

COUNTY OF PEORIA

)

AFFIDAVIT OF SERVICE & FILING

The undersigned being first duly sworn on oath, states that a copy of the

foregoing NOTICE TO APPEAR FOR DISCOVERY DEPOSITION was served upon the

following persons by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U

.S

. Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5

:00 p .m .,

with all fees thereon fully

prepaid .

The undersigned further states that a copy of the foregoing NOTICE TO

APPEAR FOR DISCOVERY DEPOSITION was served upon the following persons

by

facsimile

and by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U

.S

. Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5

:00 p.m.,

with all fees thereon fully

prepaid .

Mr. David A

. Brown

Black, Black & Brown

101 South Main Street

P .O . Box 381

Morton, Illinois 61550

(309) 266-9680 -

Telephone

(309) 266-8301 - Facsimile

dbrown(@ b lackblackbrown

.com

Subscribed and sworn to before me

this 31st day of August, 2006

.

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431

.1500-Telephone

(815) 431-1501

- Facsimile

george d(d3muelleranderson

.co m

Mr

. Kevin Lyons

Peoria County State's Attorney

324 Main Street, Room #111

Peoria, Illinois 61602

(309) 672-6029

- Facsimile

OFFICIAL SEAL

NOTARY

JESSICAM

PUBLIC-STATE

ROCKEY

OF ILLINOIS

MY coWASSION Elt Ob134T

BRIAN J

. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000

- Telephone

(309) 637.8514-Facsimile

bmeginnes(& emrslaw.com

Illinois Pollution Control Board

100 W

. Randolph, Suite 11-500

Chicago, Illinois 60601

Ms. Carol Webb, Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

(312) 814-3620

- Telephone

P.O . Box 19274

(312) 814-3669 - Facsimile

Springfield, Illinois 62794-9274

[ORIGINAL plus FOUR

(4)]

(217) 524-8503 - Telephone

webbc{cr, ipcb

.state .il .us

---

PEORIA DISPOSAL COMPANY,

)

Petitioner,

)

v .

)

PEORIA COUNTY BOARD,

)

Deponent .

)

TO: DAVID T. WILLIAMS, SR

., County Board Member

c/o Mr. David A

. Brown

Black, Black & Brown

101 South Main Street

P

.O

. Box 381

Morton, Illinois 61550

You are hereby notified that you are required to appear and testify at a discovery

deposition, on Friday, September 15, 2006, at 9

:00 a.m ., at the law offices of Elias,

Meginnes, Riffle & Seghetti, P .C .,

416 Main Street, Suite 1400, Peoria, IL 61602, and

you are hereby further notified that you are required to produce at the deposition, all of

the documents or tangible things identified in Rider A, attached hereto

.

Respectfully submitted,

Peoria Disposal Company, Petitioner

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

RECEIVED

CLERK'S

OFFICE

SEP 0 5 2006

Pollution

STATE OF

Control

ILLINOIS

Board

PCB 06-184

(Pollution Control Facility Siting Appeal)

NOTICE TO APPEAR FOR DISCOVERY DEPOSITION

1

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

BRIAN J . MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431-1501

- Facsimile

(309) 637-8514 - Facsimile

george(a)muelleranderson .co

m

bmeginnes(a) emrslaw.co m

---

RIDER A

1 . All documents in the possession or control of DAVID T . WILLIAMS, SR.

("Deponent") referring to the Application that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107 .300.

2.

All documents in the possession or control of Deponent referring to Peoria

Disposal Company that were not included in the Record filed with the Pollution Control

Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

3 .

All documents in the possession or control of Deponent received from any

member or representative of the Heart of Illinois Sierra Club that were not included in

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300 .

4 . All documents in the possession or control of Deponent received from any

member or representative of the organization Peoria Families Against Toxic Waste that

were not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300.

5. All documents in the possession or control of Deponent received from any

member or representative of the organization Citizens for Our Environment that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300.

6 .

All documents in the possession or control of Deponent received from any

member or representative of the organization River Rescue that were not included in

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

(815) 431-1501 - Facsimile

george(a)m uelleranderson.co m

2

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637.8514 - Facsimile

bmeginnes(rDemrslaw,com

---

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300 .

7.

All documents in the possession or control of Deponent portraying the

PDC 1 landfill or any property located within one (1) mile of the PDC 1 landfill that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300.

8 .

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, considered by the Deponent regarding the Application .

9 .

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, available to the Deponent in its consideration of the

Application .

10 .

All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Heart of Illinois Sierra

Club that were not included in the Record filed with the Pollution Control Board pursuant

to Illinois Administrative Code Title 35, Section 107 .300 .

11 . All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Sierra Club that were not

included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300 .

12 .

All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the organization Peoria

Families Against Toxic Waste that were not included in the Record filed with the

3

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61802-1611

(815)

431-1500 - Telephone

(309) 637-6000-Telephone

(815) 431-1501 - Facsimile

(309) 637-8514 - Facsimile

george(d m uelleranderson . com

bmeglnnes(d e mrslaw.co m

---

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

13 . All documents in the possession or control of Deponent received from or

authored by Citizens for Our Environment that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

14. All documents in the possession or control of Deponent received from or

authored by River Rescue that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

15 . All documents in the possession or control of Deponent received from or

authored by Tom Edwards that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

16 . All documents in the possession or control of Deponent received from or

authored by Kim Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

17. All documents in the possession or control of Deponent received from or

authored by Joyce Blumenshine that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

18 .

All documents in the possession or control of Deponent received from or

authored by Diane Storey that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

(815) 431-1501 - Facsimile

george(Mmuelleranderson.com

4

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637.6514-Facsimile

bmeglnnes1&Demrslaw .com

---

19 . All documents in the possession or control of Deponent received from or

authored by Jean Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

20 . All documents in the possession or control of Deponent received from or

authored by Elmo Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

21 . All documents in the possession or control of Deponent received from or

authored by Amy Schlicksup that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

22. All documents in the possession or control of Deponent received from or

authored by Cara Rosson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

23 . All documents in the possession or control of Deponent received from or

authored by Tessie Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

24. All documents in the possession or control of Deponent received from or

authored by Tom Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

25. All documents in the possession or control of Deponent received from or

authored by Mayvis Young that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

(815) 431-1501

- Facsimile

george(cD.muelleranderson.com

5

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637.8514-Facsimile

bmeginnes(cDemrslaw .co m

---

26 . All documents in the possession or control of Deponent received from or

authored by Lisa Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

27 . All documents in the possession or control of Deponent received from or

authored by Peter Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

28 . All documents in the possession or control of Deponent received from or

authored by Cathy Stevenson that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300

.

29. All documents in the possession or control of Deponent received from or

authored by Beth Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

30 . All documents in the possession or control of Deponent received from or

authored by Jeff Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

31 .

All documents in the possession or control of Deponent received from or

authored by Bill Scott that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

32. All documents in the possession or control of Deponent received from or

authored by Ted Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

(815) 431-1501

-

Facsimile

peorge(e) m uelleranderson .com

6

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 -Telephone

(309) 637-8514 - Facsimile

bmeginnes(dlemrslaw.com

---

33 . All documents in the possession or control of Deponent received from or

authored by Bill Cook that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

906-1162

7

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 81602-1611

(309) 637.6000-Telephone

(815) 431-1501 - Facsimile

(309) 637-8514 - Facsimile

george(d muelleranderson.co m

bmeginnes(d emrslaw .co m

---

STATE OF ILLINOIS

COUNTY OF PEORIA

The undersigned further states that a copy of the foregoing NOTICE TO

APPEAR FOR DISCOVERY DEPOSITION was served upon the following persons by

facsimile

and by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U .S. Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5 :00 p .m ., with all fees thereon fully

prepaid .

Mr. David A . Brown

Black, Black & Brown

101 South Main Street

P .O . Box 381

Morton, Illinois 61550

(309) 266-9680 - Telephone

(309) 266-8301 - Facsimile

d brown (ci)blackblackbrown . co m

Subscribed and sworn to before me

this 31st day of August, 2006 .

AFFIDAVIT OF SERVICE & FILING

The undersigned being first duly sworn on oath, states that a copy of the

foregoing NOTICE TO APPEAR FOR DISCOVERY DEPOSITION was served upon the

following persons by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U .S . Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5 :00 p .m ., with all fees thereon fully

prepaid .

Illinois Pollution Control Board

100 W. Randolph, Suite 11-500

Chicago, Illinois 60601

(312) 814-3620 - Telephone

(312) 814-3669 - Facsimile

[ORIGINAL plus FOUR (4)1

ian J

. M

rent

GEORGE MUELLER

628 Columbus Street, Suite #204

OFFICIAL BEAT.

Ottawa, Illinois 61350

JE$$ICAMROOC.EY

(815) 431-1500-Telephone NOTARY

PUEUC •$TATEOFMLMIOI$

(815) 431-1501 - Facsimile MYCOMiM$IOttE>WMiE8:06.1a07

george(d muelleranderson .com

Ms. Carol Webb, Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

P.O . Box 19274

Springfield, Illinois 62794-9274

(217) 524-8503-Telephone

webbc(Wipcb . state. il. us

Mr. Kevin Lyons

Peoria County State's Attorney

324 Main Street, Room #111

Peoria, Illinois 61602

(309) 672-6029 -

Facsimile

BRIAN J

. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000-Telephone

(309) 637-8514-Facsimile

bmeginnes(d emrslaw .com

---

RECEIVED

BEFORE THE ILLINOIS

POLLUTION CONTROL BOARD

SEP 0 5 2006

PEORIA DISPOSAL COMPANY,

STATE OF ILLINOIS

)

Pollution Control Board

Petitioner,

)

PCB 06-184

v.

)

(Pollution

Control Facility Siting Appeal)

PEORIA COUNTY BOARD,

)

Deponent

.

)

NOTICE TO APPEAR FOR DISCOVERY DEPOSITION

TO : MICHAEL PHELAN, County Board Member

c/o Mr

. David A . Brown

Black, Black & Brown

101 South Main Street

P .O. Box 381

Morton, Illinois 61550

You are hereby notified that you are required to appear and testify at a discovery

deposition, on Tuesday, September 12, 2006, at 1 :00 p.m., at the law offices of Elias,

Meginnes, Riffle & Seghetti, P

.C ., 416 Main Street, Suite 1400, Peoria, IL 61602, and

you are hereby further notified that you are required to produce at the deposition, all of

the documents or tangible things identified in Rider A, attached hereto

.

Respectfully submitted,

Peoria Disposal Company, Petitioner

BRIAN J

NES and

GEORG

ER, Its Attorneys

1

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

BRIAN J . MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431-1501 - Facsimile

(309) 637-8514 - Facsimile

george(a? m uelleranderson .co m

bmeginnes(d emrslaw.com

---

RIDER A

1 .

All documents in the possession or control of MICHAEL PHELAN

("Deponent") referring to the Application that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

2 .

All documents in the possession or control of Deponent referring to Peoria

Disposal Company that were not included in the Record filed with the Pollution Control

Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

3 .

All documents in the possession or control of Deponent received from any

member or representative of the Heart of Illinois Sierra Club that were not included in

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300 .

4 .

All documents in the possession or control of Deponent received from any

member or representative of the organization Peoria Families Against Toxic Waste that

were not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107

.300 .

5 .

All documents in the possession or control of Deponent received from any

member or representative of the organization Citizens for Our Environment that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107

.300.

6 .

All documents in the possession or control of Deponent received from any

member or representative of the organization River Rescue that were not included in

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

(815) 431-1501 - Facsimile

george(& m uelleranderson .com

2

BRIAN J

. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 81602-1611

(309) 637-6000-Telephone

(309) 637-8514 - Facsimile

bmeginnes(7g, emrslaw .co m

---

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300 .

7

. All documents in the possession or control of Deponent portraying the

PDC 1 landfill or any property located within one (1) mile of the PDC 1 landfill that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300 .

8 .

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, considered by the Deponent regarding the Application

.

9 .

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, available to the Deponent in its consideration of the

Application .

10 . All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Heart of Illinois Sierra

Club that were not included in the Record filed with the Pollution Control Board pursuant

to Illinois Administrative Code Title 35, Section 107

.300 .

11 .

All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Sierra Club that were not

included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300

.

12 .

All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the organization Peoria

Families Against Toxic Waste that were not included in the Record filed with the

3

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(815) 431-1500-Telephone

(309) 637-6000 - Telephone

(815) 431-1501 - Facsimile

(309) 637-8514 -

Facsimile

qeorqe(ci),muelleranderson . corn

bmeginnestdo emrslaw

.co m

---

Pollution Control Board pursuant to Illinois Administrative Code Title 35,

Section

107 .300.

13 . All documents in the possession or control of Deponent received from or

authored by Citizens for Our Environment that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

14.

All documents in the possession or control of Deponent received from or

authored by River Rescue that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

15.

All documents in the possession or control of Deponent received from or

authored by Tom Edwards that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

16 .

All documents in the possession or control of Deponent received from or

authored by Kim Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

17.

All documents in the possession or control of Deponent received from or

authored by Joyce Blumenshine that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107 .300 .

18.

All documents in the possession or control of Deponent received from or

authored by Diane Storey that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431

.1500-Telephone

(815) 431-1501

- Facsimile

george(a,m

uelleranderson .co m

4

BRIAN J

. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000-Telephone

(309) 637-8514

- Facsimile

bmeginnes(& emrslaw.com

---

19 .

All documents in the possession or control of Deponent received from or

authored by Jean Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

20 .

All documents in the possession or control of Deponent received from or

authored by Elmo Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

21 .

All documents in the possession or control of Deponent received from or

authored by Amy Schlicksup that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

22 . All documents in the possession or control of Deponent received from or

authored by Cara Rosson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

23 . All documents in the possession or control of Deponent received from or

authored by Tessie Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

24 .

All documents in the possession or control of Deponent received from or

authored by Tom Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

25 .

All documents in the possession or control of Deponent received from or

authored by Mayvis Young that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

(815) 431-1501

- Facsimile

george & m uelleranderson . com

5

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000-Telephone

(309) 637-8514 - Facsimile

bmeginnes(Womrslaw .com

---

26 . All documents in the possession or control of Deponent received from or

authored by Lisa Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

27 . All documents in the possession or control of Deponent received from or

authored by Peter Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

28

.

All documents in the possession or control of Deponent received from or

authored by Cathy Stevenson that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107 .300 .

29 . All documents in the possession or control of Deponent received from or

authored by Beth Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

30 . All documents in the possession or control of Deponent received from or

authored by Jeff Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

31 . All documents in the possession or control of Deponent received from or

authored by Bill Scott that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

32 .

All documents in the possession or control of Deponent received from or

authored by Ted Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

6

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431 .1501 - Facsimile

(309) 637 .8514 - Facsimile

george(am uelleranderson .com

bmeginnes(oDemrslaw .co m

---

33 .

All documents in the possession or control of Deponent received from or

authored by Bill Cook that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

906-1157

7

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

BRIAN J . MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 616021611

(309) 637-6000 - Telephone

(815) 431-1501

- Facsimile

(309) 637-8514 - Facsimile

george(a?muelleranderson.coin

bmeginnes(cilemrslaw.com

---

STATE OF ILLINOIS

)

COUNTY OF PEORIA

The undersigned further states that a copy of the foregoing NOTICE TO

APPEAR FOR DISCOVERY DEPOSITION was served upon the following persons

by

facsimile and by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U

.S . Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5 :00 p .m ., with all fees thereon fully

prepaid .

Mr. David A . Brown

Black, Black & Brown

101 South Main Street

P .O. Box 381

Morton, Illinois 61550

(309) 266-9680 - Telephone

(309) 266-8301 - Facsimile

dbrown(d-blackblackbrown

.com

Subscribed and sworn to before me

this 31st day of August, 2006 .

i

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

(815) 431-1501 - Facsimile

goorgep,m

uelleranderson .co m

SS

AFFIDAVIT OF SERVICE & FILING

The undersigned being first duly sworn on oath, states that a copy of the

foregoing NOTICE TO APPEAR FOR DISCOVERY DEPOSITION was served upon the

following persons by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U .S . Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5 :00 p .m

., with all fees thereon fully

prepaid .

OFFIQAL SEAL

STATE OFE

ILLINOIS

W COMMISSION EXPIRES

16'107

Mr. Kevin Lyons

Peoria County State's Attorney

324 Main Street, Room #111

Peoria, Illinois 61602

(309) 672-6029 - Facsimile

BRIAN J. MEGINNES

416 Main Street, Suite #1400

t Peoria, Illinois 61602-1611

(309) 637-6000-Telephone

(309) 637-8514 - Facsimile

bmeginnes(a),e mrslaw .co m

Illinois Pollution Control Board

100 W. Randolph, Suite 11-500

Chicago, Illinois 60601

Ms

. Carol Webb, Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

(312) 814-3620

- Telephone

P .O. Box 19274

(312) 814-3669 - Facsimile

Springfield, Illinois 62794-9274

[ORIGINAL plus FOUR (4)]

(217) 524-8503 - Telephone

webbc(a, ipcb

.state.il .us

---

RECEIVED

CLERK'S OFFICE

SEP 0 5 2006

STATE OF ILLINOIS

PEORIA DISPOSAL COMPANY,

)

Petitioner,

)

PCB 06-184

v.

)

(Pollution Control Facility Siting Appeal)

PEORIA COUNTY BOARD,

)

)

Deponent .

)

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

NOTICE TO APPEAR FOR DISCOVERY DEPOSITION

TO: JUNIOR WATKINS, County Board Member

c/o Mr. David A . Brown

Black, Black & Brown

101 South Main Street

P .O. Box 381

Morton, Illinois 61550

You are hereby notified that you are required to appear and testify at a discovery

deposition, on Friday, September 15, 2006, at 1 :00 p .m.,

at the law offices of Elias,

Meginnes, Riffle & Seghetti, P .C., 416 Main Street, Suite

1400, Peoria, IL 61602, and

you are hereby further notified that you are required to produce at the deposition, all of

the documents or tangible things identified in Rider A, attached hereto

.

Respectfully submitted,

Peoria Disposal Company, Petitioner

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

(815) 431-1501 - Facsimile

george(lImuelleranderson .com

1

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637.8514-Facsimile

bmecinnes(demrslaw.com

Pollution Control Board

---

RIDER A

1 .

All documents in the possession or control of JUNIOR WATKINS

("Deponent") referring to the Application that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300.

2.

All documents in the possession or control of Deponent referring to Peoria

Disposal Company that were not included in the Record filed with the Pollution Control

Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

3 .

All documents in the possession or control of Deponent received from any

member or representative of the Heart of Illinois Sierra Club that were not included in

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300.

4.

All documents in the possession or control of Deponent received from any

member or representative of the organization Peoria Families Against Toxic Waste that

were not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107

.300 .

5 .

All documents in the possession or control of Deponent received from any

member or representative of the organization Citizens for Our Environment that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300 .

6.

All documents in the possession or control of Deponent received from any

member or representative of the organization River Rescue that were not included in

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

(815) 431.1501-Facsimile

a eorae@muelleranderson .co m

2

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637-8514 - Facsimile

bmealnnes(Wemrslaw.com

---

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107

.300 .

7.

All documents in the possession or control of Deponent portraying the

PDC 1 landfill or any property located within one (1) mile of the PDC 1 landfill that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107

.300.

8.

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, considered by the Deponent regarding the Application

.

9 .

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, available to the Deponent in its consideration of the

Application .

10 .

All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Heart of Illinois Sierra

Club that were not included in the Record filed with the Pollution Control Board pursuant

to Illinois Administrative Code Title 35, Section 107 .300 .

11 .

All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Sierra Club that were not

included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300.

12

. All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the organization Peoria

Families Against Toxic

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 51350

(815) 431

.1500-Telephone

(815) 431-1501 - Facsimile

aeorge(d!muelleranderson .com

Waste that were not included in the Record filed with the

3

BRIAN J

. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 537-5000-Telephone

(309) 537.

8514-Facsimile

bmeglnnes(r .. emrslaw.co m

---

Pollution

Control Board

pursuant to Illinois Administrative Code Title 35, Section

107.300.

13.

All documents in the possession or control of Deponent received from or

authored by Citizens for Our Environment that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300

.

14.

All documents in the possession or control of Deponent received from or

authored by River Rescue that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

15 .

All documents in the possession or control of Deponent received from or

authored by Tom Edwards that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300

.

16

.

All documents in the possession or control of Deponent received from or

authored by Kim Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300

.

17 .

All documents in the possession or control of Deponent received from or

authored by Joyce Blumenshine that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300

.

18

. All documents in the possession or control of Deponent received from or

authored by Diane Storey that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500- Telephone

(815) 431 .1501-Facsimile

aeorge(W.muelleranderson.com

4

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 . Telephone

(309) 537.8514 - Facsimile

bmeuinnes(r@emrslaw.com

---

19 .

All documents in the possession or control of Deponent received from or

authored by Jean Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

20. All documents in the possession or control of Deponent received from or

authored by Elmo Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

21 . All documents in the possession or control of Deponent received from or

authored by Amy Schlicksup that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

22. All documents in the possession or control of Deponent received from or

authored by Cara Rosson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

23. All documents in the possession or control of Deponent received from or

authored by Tessie Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

24.

All documents in the possession or control of Deponent received from or

authored by Tom Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

25.

All documents in the possession or control of Deponent received from or

authored by Mayvis Young that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

(815) 431-1501-Facsimile

aeoroe(r'muelleranderson.com

5

BRIAN J

. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 537-5000-Telephone

(309) 537.8514-Facsimile

bmeglnnes(Wemrslaw.com

---

26.

All documents in the possession or control of Deponent received from or

authored by Lisa Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

27

. All documents in the possession or control of Deponent received from or

authored by Peter Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

28 .

All documents in the possession or control of Deponent received from or

authored by Cathy Stevenson that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

29 . All documents in the possession or control of Deponent received from or

authored by Beth Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

30.

All documents in the possession or control of Deponent received from or

authored by Jeff Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

31 . All documents in the possession or control of Deponent received from or

authored by Bill Scott that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

32. All documents in the possession or control of Deponent received from or

authored by Ted Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

6

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

(815) 431-1501 - Facsimile

aeorae(&mueileranderson

.com

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637.8514-Facsimile

bmealnnes(oDemrslaw.com

---

33 .

All documents in the possession or control of Deponent received from or

authored by Bill Cook that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

906-1163

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 81350

(815) 431.1500-Telephone

(815) 431-1501 - Facsimile

george(&muelleranderson

.co m

7

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(309) 037-8514-Facsimile

bmeginnestraemrslaw.com

---

STATE OF ILLINOIS

)

SS

COUNTY OF PEORIA )

AFFIDAVIT OF SERVICE & FILING

The undersigned being first duly sworn on oath, states that a copy of the

foregoing NOTICE TO APPEAR FOR DISCOVERY DEPOSITION was served upon the

following persons by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U .S. Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5

:00 p .m., with all fees thereon fully

prepaid.

Illinois Pollution Control Board

100 W. Randolph, Suite 11-500

Chicago, Illinois 60601

(312) 814-3620 - Telephone

(312) 814-3669 - Facsimile

[ORIGINAL plus FOUR (4)1

The undersigned further states that a copy of the foregoing NOTICE TO

APPEAR FOR DISCOVERY DEPOSITION was served upon the following persons by

facsimile

and by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U

.S

. Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5

:00 p .m .,

with all fees thereon fully

prepaid .

Mr. David A. Brown

Black, Black & Brown

101 South Main Street

P.O . Box 381

Morton, Illinois 61550

(309) 266-9680

- Telephone

(309) 266-8301 - Facsimile

dbrown (ilblackblackbrown .com

Subscribed and sworn to before me

this 31st day of August, 2006 .

Notary PublicAA" \0(

is

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

(815) 431-1501 - Facsimile

aeorge(dlmueileranderson.co

Ms . Carol Webb, Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

P .O. Box 19274

Springfield, Illinois 62794-9274

(217) 524-8503 - Telephone

webbc(a)ipcb. state

. il . us

Mr. Kevin Lyons

Peoria County State's Attorney

324 Main Street, Room #111

Peoria, Illinois 61602

(309) 672-6029 -

Facsimile

e nes

BRIAN J. MEGINNES

°`

416 Main Street, Suite #1400

OFFICIAL SEAL

Peoria, Illinois 61602-1611

NOTARY

JBSOM

~

M

,RAW -

STATEOFkU"S

(309) 637.854-Facsimile

bmeginnes(dDemrslaw.com

---

RECEIVEDCLERK'S

OFFICE

SEP 0 5 2006

STATE OF ILLINOIS

PEORIA DISPOSAL COMPANY,

)

Pollution Control Board

Petitioner,

)

PCB 06-184

V

)

(Pollution Control

Facility Siting Appeal)

)

PEORIA COUNTY BOARD,

)

Deponent .

)

NOTICE TO APPEAR FOR DISCOVERY DEPOSITION

TO: G

. ALLEN MAYER, County Board Member

c/o Mr

. David A . Brown

Black, Black & Brown

101 South Main Street

P .O. Box 381

Morton, Illinois 61550

You are hereby notified that you are required to appear and testify at a discovery

deposition, on Thursday, September 14, 2006, at 1

:00 p .m.,

at the law offices of Elias,

Meginnes, Riffle & Seghetti, P .C.,

416 Main Street, Suite 1400, Peoria, IL 61602, and

you are hereby further notified that you are required to produce at the deposition, all of

the documents or tangible things identified in Rider A, attached hereto

.

Respectfully submitted,

Peoria Disposal Company, Petitioner

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

1

BRIAN

ELJ

.

GI

GEORG

L

NE and

E , Its Aft

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431-1501 - Facsimile

(309) 637-8514 -

Facsimile

aeorge(d-muelleranderson.com

bme,linnes('emrslaw.com

---

RIDER A

1 .

All documents in the possession or control of G . ALLEN MAYER

("Deponent") referring to the Application that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

2 .

All documents in the possession or control of Deponent referring to Peoria

Disposal Company that were not included in the Record filed with the Pollution Control

Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

3 . All documents in the possession or control of Deponent received from any

member or representative of the Heart of Illinois Sierra Club that were not included in

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300 .

4.

All documents in the possession or control of Deponent received from any

member or representative of the organization Peoria Families Against Toxic Waste that

were not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300.

5 .

All documents in the possession or control of Deponent received from any

member or representative of the organization Citizens for Our Environment that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300.

6 .

All documents in the possession or control of Deponent received from any

member or representative of the organization River Rescue that were not included in

2

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431-1501 - Facsimile

(309) 637-8514 - Facsimile

george(d)muelleranderson .com

bmeginnes(d emrslaw.com

---

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300 .

7. All documents in the possession or control of Deponent portraying the

PDC 1 landfill or any property located within one (1) mile of the PDC 1 landfill that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107

.300.

8 .

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, considered by the Deponent regarding the Application .

9 .

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, available to the Deponent in its consideration of the

Application

.

10 .

All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Heart of Illinois Sierra

Club that were not included in the Record filed with the Pollution Control Board pursuant

to Illinois Administrative Code Title 35, Section 107 .300 .

11 . All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Sierra Club that were not

included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300 .

12 . All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the organization Peoria

Families Against Toxic Waste that were not included in the Record filed with the

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

(815) 431-1501 - Facsimile

Qeorae(cimuelleranderson.com

3

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 -Telephone

(309) 637-8514 - Facsimile

bmeoinnes(a),emrslaw.co m

---

Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section

107

.300 .

13 .

All documents in the possession or control of Deponent received from or

authored by Citizens for Our Environment that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107 .300.

14 . All documents in the possession or control of Deponent received from or

authored by River Rescue that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

15 . All documents in the possession or control of Deponent received from or

authored by Tom Edwards that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

16. All documents in the possession or control of Deponent received from or

authored by Kim Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

17. All documents in the possession or control of Deponent received from or

authored by Joyce Blumenshine that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300.

18. All documents in the possession or control of Deponent received from or

authored by Diane Storey that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

(815) 431-1501 - Facsimile

g eorge@muelleranderson .com

4

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637-8514 -

Facsimile

bmeoinnes(

.emrslaw.com

---

19 . All documents in the possession or control of Deponent received from or

authored by Jean Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

20 . All documents in the possession or control of Deponent received from or

authored by Elmo Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

21 . All documents in the possession or control of Deponent received from or

authored by Amy Schlicksup that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

22 . All documents in the possession or control of Deponent received from or

authored by Cara Rosson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

23. All documents in the possession or control of Deponent received from or

authored by Tessie Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

24. All documents in the possession or control of Deponent received from or

authored by Tom Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

25. All documents in the possession or control of Deponent received from or

authored by Mayvis Young that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

(815) 431-1501

- Facsimile

george6Dmuelleranderson.co m

5

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637-8514 - Facsimile

bmeginnes(a'emrslaw .com

---

26 . All documents in the possession or control of Deponent received from or

authored by Lisa Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

27

. All documents in the possession or control of Deponent received from or

authored by Peter Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

28 . All documents in the possession or control of Deponent received from or

authored by Cathy Stevenson that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107 .300.

29 . All documents in the possession or control of Deponent received from or

authored by Beth Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

30 . All documents in the possession or control of Deponent received from or

authored by Jeff Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

31

. All documents in the possession or control of Deponent received from or

authored by Bill Scott that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

32 . All documents in the possession or control of Deponent received from or

authored by Ted Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

6

GEORGE MUELLER

BRIAN J. MEGINNES

628 Columbus Street, Suite #204

416 Main Street, Suite #1400

Ottawa, Illinois 61350

Peoria, Illinois 61602-1611

(815) 431-1500 -Telephone

(309) 637-6000 - Telephone

(815) 431-1501 - Facsimile

(309) 637-8514 - Facsimile

george(ddmueileranderson.co m

bmeginnes(a emrslaw.co m

---

33 .

All documents in the possession or control of Deponent received from or

authored by Bill Cook that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

906-1161

7

GEORGE MUELLER

628 Columbus

Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431-1501 - Facsimile

(309) 637-8514 - Facsimile

george(dmuelleranderson.com

bmeginnes(nlemrslaw.com

---

STATE OF ILLINOIS

)

COUNTY OF PEORIA

The undersigned further states that a copy of the foregoing NOTICE TO

APPEAR FOR DISCOVERY DEPOSITION was served upon the following persons by

facsimile and by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U .S

. Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5 :00 p .m ., with all fees thereon fully

prepaid

.

Mr. David A . Brown

Black, Black & Brown

101 South Main Street

P .O . Box 381

Morton, Illinois 61550

(309) 266-9680 - Telephone

(309) 266-8301 - Facsimile

dbrown@blackblackbrown .com

Subscribed and sworn to before me

this 31st day of August, 2006 .

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

(815) 431-1501 - Facsimile

g eorge@muelleranderson .com

SS

AFFIDAVIT OF SERVICE & FILING

The undersigned being first duly sworn on oath, states that a copy of the

foregoing NOTICE TO APPEAR FOR DISCOVERY DEPOSITION was served upon the

following persons by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U .S . Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5:00 p.m

., with all fees thereon fully

prepaid .

Illinois Pollution Control Board

100 W. Randolph, Suite 11-500

Chicago, Illinois 60601

(312) 814-3620 - Telephone

(312) 814-3669 - Facsimile

[ORIGINAL plus FOUR(4)]

Ms . Carol Webb, Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

P .O. Box 19274

Springfield, Illinois 62794-9274

(217) 524-8503 - Telephone

webbc(Wipcb .state .il .us

Mr. Kevin Lyons

Peoria County State's Attorney

324 Main Street, Room #111

Peoria, Illinois 61602

(309) 672-6029 - Facsimile

JESSICAOFFICIALSEAL

M ROCKEY

I

NOTARY KSLIC-STATE OFILLINOIS

MYOOLMMBgNEKMRES:O&13-01

Br'

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637-8514 - Facsimile

bmeginnes(&emrslaw.co m

---

RE RK,E I VI

ED

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

SEP 0 5 2006

PEORIA DISPOSAL COMPANY,

Pollution

STATE OF

Control

ILLINOIS

Board

)

Petitioner,

)

PCB 06-184

v.

)

(Pollution Control Facility Siting Appeal)

PEORIA COUNTY BOARD,

)

Deponent .

)

NOTICE TO APPEAR FOR DISCOVERY DEPOSITION

TO: PHILLIP SALZER, County Board Member

c/o Mr. David A . Brown

Black, Black & Brown

101 South Main Street

P .O. Box 381

Morton, Illinois 61550

You are hereby notified that you are required to appear and testify at a discovery

deposition, on Thursday, September 14, 2006, at 9 :00 a.m., at the law offices of Elias,

Meginnes, Riffle & Seghetti, P .C ., 416 Main Street, Suite 1400, Peoria, IL 61602, and

you are hereby further notified that you are required to produce at the deposition, all of

the documents or tangible things identified in Rider A, attached hereto

.

Respectfully submitted,

Peoria Disposal Company, Petitioner

GEORGE MUELLER

628 Columbus Street, Suite

#204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

(815) 431-1501 - Facsimile

george(tmuelleranderson.com

1

BRIAN JM

E and

GEORGE

UE

DELL R,,

Its Attorneys

BRIAN J

. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(309) 637.8514-Facsimile

bmeginnes6Demrslaw .co

m

---

RIDER A

1 . All documents in the possession or control of PHILLIP SALZER

("Deponent") referring to the Application that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

2 .

All documents in the possession or control of Deponent referring to Peoria

Disposal Company that were not included in the Record filed with the Pollution Control

Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

3 .

All documents in the possession or control of Deponent received from any

member or representative of the Heart of Illinois Sierra Club that were not included in

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300 .

4. All documents in the possession or control of Deponent received from any

member or representative of the organization Peoria Families Against Toxic Waste that

were not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300.

5 . All documents in the possession or control of Deponent received from any

member or representative of the organization Citizens for Our Environment that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107

.300.

6 .

member or

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431.1500-Telephone

(815) 431-1501 -

Facsimile

george(r!muelleranderson .com

All documents in the possession or control of Deponent received from any

representative of the organization River Rescue that were not included

2

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000-Telephone

(309) 637-8514 - Facsimile

b meglnnes6Demrslaw.com

in

---

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300 .

7. All documents in the possession or control of Deponent portraying the

PDC 1 landfill or any property located within one (1) mile of the PDC 1 landfill that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300.

8 .

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, considered by the Deponent regarding the Application

.

9 . All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, available to the Deponent in its consideration of the

Application

.

10.

All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Heart of Illinois Sierra

Club that were not included in the Record filed with the Pollution Control Board pursuant

to Illinois Administrative Code Title 35, Section 107

.300 .

11 .

All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Sierra Club that were not

included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300 .

12 .

All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the organization Peoria

Families Against Toxic Waste that were not included in the Record filed with the

3

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 81602.1611

(309) 637-6000 - Telephone

(815) 431-1501 - Facsimile

(309)

637-8514 - Facsimile

aeorae(aimuelleranderson .co m

bmealnnes(Memrslaw.com

---

Pollution Control Board pursuant to

Illinois Administrative Code Title 35, Section

107 .300.

13 .

All documents in the possession or control of Deponent received from or

authored by Citizens for Our Environment that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

14 .

All documents in the possession or control of Deponent received from or

authored by River Rescue that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

15 .

All documents in the possession or control of Deponent received from or

authored by Tom Edwards that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

16.

All documents in the possession or control of Deponent received from or

authored by Kim Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

17 .

All documents in the possession or control of Deponent received from or

authored by Joyce Blumenshine that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300.

18 .

All documents in the possession or control of Deponent received from or

authored by Diane Storey that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

(815) 431-1501 - Facsimile

georgeCD,muelleranderson .com

4

BRIAN J

. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000-Telephone

(309) 637-8514 - Facsimile

bmeglnnes(a

emrslaw.com

---

19 .

All documents in the possession or control of Deponent received from or

authored by Jean Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

20 .

All documents in the possession or control of Deponent received from or

authored by Elmo Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

21 . All documents in the possession or control of Deponent received from or

authored by Amy Schlicksup that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

22 . All documents in the possession or control of Deponent received from or

authored by Cara Rosson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300 .

23. All documents in the possession or control of Deponent received from or

authored by Tessie Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

24 . All documents in the possession or control of Deponent received from or

authored by Tom Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

25

. All documents in the possession or control of Deponent received from or

authored by Mayvis Young that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

5

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431-1501 - Facsimile

(309)

637-8514 - Facsimile

george(W.muelleranderson .com

bmeginnes(r .emrslaw.co

m

---

26 . All documents in the possession or control of Deponent received from or

authored by Lisa Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

27 . All documents in the possession or control of Deponent received from or

authored by Peter Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

28 . All documents in the possession or control of Deponent received from or

authored by Cathy Stevenson that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

29. All documents in the possession or control of Deponent received from or

authored by Beth Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

30 . All documents in the possession or control of Deponent received from or

authored by Jeff Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

31 . All documents in the possession or control of Deponent received from or

authored by Bill Scott that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

32 . All documents in the possession or control of Deponent received from or

authored by Ted Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

(815) 431-1501 - Facsimile

george(a)m uelleranderson.co m

6

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637-8514

-

Facsimile

bmeginnes(aDemrslaw.com

---

33

. All documents in the possession or control of Deponent received from or

authored by Bill Cook that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

906-1160

7

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431-1501 - Facsimile

(309) 637-8514-Facsimile

george(Dmuelleranderson.com

b meglnnesCDemrslaw.co m

---

STATE OF ILLINOIS

COUNTY OF PEORIA

Mr. David A . Brown

Black, Black & Brown

101 South Main Street

P .O . Box 381

Morton, Illinois 61550

(309) 266-9680 - Telephone

(309) 266-8301 - Facsimile

dbrown(&,b lackblackbrown .com

Subscribed and sworn to before me

this 31st day of August, 2006 .

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

(815) 431-1501 - Facsimile

george(dmuelleranderson.co m

AFFIDAVIT OF SERVICE & FILING

The undersigned being first duly sworn on oath, states that a copy of the

foregoing NOTICE TO APPEAR FOR DISCOVERY DEPOSITION was served upon the

following persons by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U .S . Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5 :00 p .m ., with all fees thereon fully

prepaid .

Illinois Pollution Control Board

100 W. Randolph, Suite 11-500

Chicago, Illinois 60601

(312) 814-3620 - Telephone

(312) 814-3669 - Facsimile

[ORIGINAL plus FOUR (4)1

Ms. Carol Webb, Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

P.O. Box 19274

Springfield, Illinois 62794-9274

(217) 524-8503 - Telephone

webbcc ipcb. state. il . us

The undersigned further states that a copy of the foregoing NOTICE TO

APPEAR

facsimileFOR

and

DISCOVERY

by enclosing

DEPOSITION

copies of

was

same

served

in separate

upon

envelopes,

the following

addressed

personsas

setby

forth below, and depositing said envelopes in a U .S . Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5:00 p .m., with all fees thereon fully

prepaid .

Mr. Kevin Lyons

Peoria County State's Attorney

324 Main Street, Room #111

Peoria, Illinois 61602

(309) 672-6029 - Facsimile

OFFICIAL SEAL

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

JESSICA M ROCI(EY

S

(309) 637-8514 - Facsimile

NOTARY PUBLIC-STATE OF ILLINOIS

bmeginnes(dlemrslaw.com

MY COIMISSICN EXPIRES O6

• o

0?

---

RECEIVED

CLERK'S

OFFICE

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

SEP 0 5 2006

PEORIA DISPOSAL COMPANY,

Pollution

STATE OF

Control

ILLINOIS

Board

Petitioner,

)

PCB 06-184

v.

)

(Pollution Control Facility Siting Appeal)

PEORIA COUNTY BOARD,

)

Deponent .

)

NOTICE TO APPEAR FOR DISCOVERY DEPOSITION

TO : CAROL TRUMPE, County Board Member

c/o Mr. David A . Brown

Black, Black & Brown

101 South Main Street

P .O. Box 381

Morton, Illinois 61550

You are hereby notified that you are required to appear and testify at a discovery

deposition, on Wednesday, September 13, 2006, at 1 :00 p .m., at the law offices of

Elias, Meginnes, Riffle & Seghetti, P .C., 416 Main Street, Suite 1400, Peoria, IL 61602,

and you are hereby further notified that you are required to produce at the deposition, all

of the documents or tangible things identified in Rider A, attached hereto .

Respectfully submitted,

Peoria Disposal Company, Petitioner

1

INNES and

LER, Its Attorneys

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431-1501 - Facsimile

(309) 837-8514 - Facsimile

oeorae(a)m uelleranderson .com

bmeainnes(&emrslaw .co m

---

RIDER A

1 . All documents in the possession or control of CAROL TRUMPE

("Deponent') referring to the Application that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300

.

2 .

All documents in the possession or control of Deponent referring to Peoria

Disposal Company that were not included in the Record filed with the Pollution Control

Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

3.

All documents in the possession or control of Deponent received from any

member or representative of the Heart of Illinois Sierra Club that were not included in

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300 .

4. All documents in the possession or control of Deponent received from any

member or representative of the organization Peoria Families Against Toxic Waste that

were not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300.

5 . All documents in the possession or control of Deponent received from any

member or representative of the organization Citizens for Our Environment that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300.

6.

All documents in the possession or control of Deponent received from any

member or representative of the organization River Rescue that were not included in

2

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500- Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431-1501

- Facsimile

(309) 637-8514 - Facsimile

geome(dmuelleranderson .co m

bmeginnes(demrslaw.co m

---

the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code

Title 35, Section 107 .300 .

7 . All documents in the possession or control of Deponent portraying the

PDC 1 landfill or any property located within one (1) mile of the PDC 1 landfill that were

not included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300 .

8.

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, considered by the Deponent regarding the Application .

9.

All documents, including, without limitation, notes, drafts, memoranda,

correspondence and transcripts, available to the Deponent in its consideration of the

Application .

10. All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Heart of Illinois Sierra

Club that were not included in the Record filed with the Pollution Control Board pursuant

to Illinois Administrative Code Title 35, Section 107 .300

.

11 . All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the Sierra Club that were not

included in the Record filed with the Pollution Control Board pursuant to Illinois

Administrative Code Title 35, Section 107 .300 .

12 . All documents in the possession or control of Deponent reflecting

membership of any member of the Peoria County Board in the organization Peoria

Families Against Toxic Waste that were not included in the Record filed with the

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431.1500-Telephone

(815) 431-1501 - Facsimile

george(&,muelleranderson.com

3

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637.8514-Facsimile

bmeglnnes(&emrsiaw.com

---

Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section

107 .300.

13 . All documents in the possession or control of Deponent received from or

authored by Citizens for Our Environment that were not included in the Record filed with

the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107 .300.

14 . All documents in the possession or control of Deponent received from or

authored by River Rescue that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

15 .

All documents in the possession or control of Deponent received from or

authored by Tom Edwards that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

16 .

All documents in the possession or control of Deponent received from or

authored by Kim Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

17.

All documents in the possession or control of Deponent received from or

authored by Joyce Blumenshine that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300.

18.

All documents in the possession or control of Deponent received from or

authored by Diane Storey that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

4

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

BRIAN J. MEGiNNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1811

(815) 431-1501 - Facsimile

(309)(309)

637-8514637-6000 -- FacsimileTelephone

george(&m

uelleranderson.co m

bmeginnes(&Demrsiaw.com

---

19.

All documents in the possession or control of Deponent received from or

authored by Jean Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

20. All documents in the possession or control of Deponent received from or

authored by Elmo Roach that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

21 . All documents in the possession or control of Deponent received from or

authored by Amy Schlicksup that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

22 . All documents in the possession or control of Deponent received from or

authored by Cara Rosson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

23 . All documents in the possession or control of Deponent received from or

authored by Tessie Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

24 . All documents in the possession or control of Deponent received from or

authored by Tom Bucklar that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

25 . All documents in the possession or control of Deponent received from or

authored by Mayvis Young that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

5

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(815) 431-1501 - Facsimile

(309) 637-8514

- Facsimile

aeorge(&m uelleranderson .com

bmeglnnes(dlemrslaw.co m

---

26 . All documents in the possession or control of Deponent received from or

authored by Lisa Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .

27 . All documents in the possession or control of Deponent received from or

authored by Peter Offutt that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

28. All documents in the possession or control of Deponent received from or

authored by Cathy Stevenson that were not included in the Record filed with the

Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section

107.300 .

29 . All documents in the possession or control of Deponent received from or

authored by Beth Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

30 . All documents in the possession or control of Deponent received from or

authored by Jeff Akeson that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

31

. All documents in the possession or control of Deponent received from or

authored by Bill Scott that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

32 . All documents in the possession or control of Deponent received from or

authored by Ted Converse that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107 .300.

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

(815) 431-1501

- Facsimile

georgeCa?

m uelleranderson.com

6

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602.1611

(309) 637.6000-Telephone

(309) 637.8514-Facsimile

bmeginnes6Demrslaw.co m

---

33 .

All documents in the possession or control of Deponent received from or

authored by Bill Cook that were not included in the Record filed with the Pollution

Control Board pursuant to Illinois Administrative Code Title 35, Section 107

.300.

906-1159

7

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(815) 431-1501 - Facsimile

(309) 637.8514 - Facsimile

george(d m uelieranderson .co m

bmeginnes(@Demrslaw.com

---

STATE OF ILLINOIS

)

SS

COUNTY OF PEORIA )

AFFIDAVIT OF SERVICE & FILING

The undersigned being first duly sworn on oath, states that a copy of the

foregoing NOTICE TO APPEAR FOR DISCOVERY DEPOSITION was served upon the

following persons by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U .S . Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5

:00 p .m ., with all fees thereon fully

prepaid

.

Illinois Pollution Control Board

100 W. Randolph, Suite 11-500

Chicago, Illinois 60601

(312) 814-3620 -Telephone

(312) 814-3669 - Facsimile

[ORIGINAL plus FOUR(4)]

The undersigned further states that a copy of the foregoing NOTICE TO

APPEAR

facsimileFOR

and

DISCOVERY

by enclosing

DEPOSITION

copies of

was

same

served

in separate

upon

envelopes,

the following

addressed

personsas

setby

forth below, and depositing said envelopes in a U .S. Postal Service mailbox in Peoria,

Illinois, on the 31st day of August, 2006, before 5 :00 p .m., with all fees thereon fully

prepaid .

Mr. David A . Brown

Black, Black & Brown

101 South Main Street

P.O . Box 381

Morton, Illinois 61550

(309) 266-9680 - Telephone

(309) 266-8301 - Facsimile

dbrown@blackblackbrown .com

Subscribed and sworn to before me

this 31st day of August, 2006 .

1 1

A

Nota Public

It ,&_

'w

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431

.1500-Telephone

(815) 431 .1501-Facsimile

george(r)muelleranderson.co m

OFFIc&.j

SEAL

NOTARY

AIYCOAr .1sspp

.6afse

Ms

. Carol Webb, Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

P.O . Box 19274

Springfield, Illinois 62794-9274

(217) 524-8503 - Telephone

webbca,ipcb

.state. il .us

Mr

. Kevin Lyons

Peoria County State's Attorney

324 Main Street, Room #111

Peoria, Illinois 61602

(309) 672-6029 - Facsimile

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637.6000-Telephone

(309) 637-8514 - Facsimile

bmeglnnes@emrslaw.com

---

RECEIVEDCLERKS

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

SEP 0 5 2006

PEORIA DISPOSAL COMPANY,

)

Petitioner,

)

PCB 06-184

v .

)

(Pollution Control Facility Siting Appeal)

PEORIA COUNTY BOARD,

)

Respondent .

)

NOTICE TO APPEAR FOR DISCOVERY DEPOSITION -CONTINUED

TO: RUSSELL HAUPERT, County IT Services

c/o Mr. David A . Brown

Black, Black & Brown

101 South Main Street

P.O . Box 381

Morton, Illinois 61550

You are hereby notified that you are required to appear and testify at a discovery

deposition, previously set for August 25, 2006, and continued by agreement of the

parties and yourself to Wednesday, September 13, 2006, at 11 :00 a .m ., at the law

offices of Elias, Meginnes, Riffle & Seghetti, P.C ., 416 Main Street, Suite 1400, Peoria,

IL 61602, and you are hereby further notified that you are required to produce at the

deposition, all of the documents or tangible things identified in Rider A to the Notice to

Appear previously served upon you in this case .

Respectfully submitted,

Peoria Disposal Company, Petitioner

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431-1500-Telephone

(815) 431-1501 - Facsimile

4eorae(o)m uelleranderson .com

1

Pollution

STATE OF

Control

ILLINOIS

Board

BRIAN

E i

GEOR

NN

d

L

R, Its

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 -Telephone

(309) 637-8514 - Facsimile

bmeginnes(Demrslaw.com

---

STATE OF ILLINOIS

)

COUNTY OF PEORIA

Mr. David A. Brown

Black, Black & Brown

101 South Main Street

P

.O

. Box 381

Morton, Illinois 61550

(309) 266-9680

- Telephone

(309) 266-8301 - Facsimile

d brown 66ilblackbl ackbrown . com

Subscribed and sworn to before me

this

3 1

day of August, 2006 .

SS

Notary Public

GEORGE MUELLER

628 Columbus Street, Suite #204

Ottawa, Illinois 61350

(815) 431 .1500-Telephone

(815) 431 .1501-Facsimile

george(&muelleranderson.com

AFFIDAVIT OF SERVICE & FILING

The undersigned being first duly sworn on oath, states that a copy of the

foregoing NOTICE TO APPEAR FOR DISCOVERY DEPOSITION - CONTINUED was

served upon the following persons by enclosing copies of same in separate envelopes,

addressed as set forth below, and depositing said envelopes in a U

.S. Postal Service

mailbox in Peoria, Illinois, on the

day

of August, 2006, before 5 :00 p.m., with all

fees thereon fully prepaid .

Illinois Pollution Control Board

100 W. Randolph, Suite 11-500

Chicago, Illinois 60601

(312) 814-3620 - Telephone

(312) 814-3669 - Facsimile

[ORIGINAL plus FOUR(4)]

The undersigned further states that a copy of the foregoing NOTICE TO

APPEAR FOR DISCOVERY DEPOSITION was served upon the following persons

by

facsimile and by enclosing copies of same in separate envelopes, addressed as set

forth below, and depositing said envelopes in a U .S . Postal Service mailbox in Peoria,

Illinois, on the day of August, 2006, before 5 :00 p.m.,

with all fees thereon fully

prepaid .

Ms

. Carol Webb, Hearing Officer

Illinois Pollution Control Board

1021 North Grand Avenue East

P .O. Box 19274

Springfield, Illinois 62794-9274

(217) 524-8503 - Telephone

webbcnipcba .state .il.us

Mr. Kevin Lyons

Peoria County State's Attorney

324 Main Street, Room #111

Peoria, Illinois 61602

(309) 672-6029 - Facsimile

OFFICIAL SEAL

JESSICA M ROG(EY

A

MY OWIMISBgw

STATE

t

BRIAN J. MEGINNES

416 Main Street, Suite #1400

Peoria, Illinois 61602-1611

(309) 637-6000 - Telephone

(309) 637-8514-Facsimile

bmeainnes(55emrslaw.com