RECEIVED
BEFORE THE ILLINOIS POLLUTION CONTROL
BOARD
SEP
1 12006
STATE OF ILLINOIS
PEORIA DISPOSAL COMPANY,
)
Pollution Control Board
Petitioner,
)
PCB 06-184
v .
)
(Pollution Control Facility Siting Appeal)
)
PEORIA COUNTY BOARD,
)
Deponent .
)
NOTICE TOAPPEAR
FOR DISCOVERY DEPOSITION
TO : THOMAS O'NEILL, County Board Member
do 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 27, 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
aeorge(dmuelleranderson.com
1
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637.6000-Telephone
(309) 637-8514 - Facsimile
bmeginnes(demrslaw.com
RECEIVEDCLERK'S
OFFICE
SEP 1 12006
STATE OF ILLINOIS
1 .
All documents in the possession or control of THOI i
tit11L'el Boas
("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
RIDER A
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
oeorge(almaelleranderson.com
bmeglnnes@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
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
geome@@Dmuelleranderson .com
b
meglnneslatemrslaw.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 61602-1611
(309) 637-6000 - Telephone
(815) 431-1501 - Facsimile
(309) 637-8514
- Facsimile
g
eome@muelleranderson
.com
bmecinnes(& 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(dmuelleranderson.com
5
BRIAN J
. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 81602-1611
(309) 637-6000-Telephone
(309) 637-8514 - Facsimile
bmeginnes(demrslaw.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.
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500-Telephone
(815) 431-1501 - Facsimile
george(&jnuelleranderson.com
6
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637.6000-Telephone
(309) 637.8514-Facsimile
bmeginnes@
.emrslaw.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.
906-1184
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(e)muelleranderson .com
bmeginnes(&emrsiaw.com
STATE OF ILLINOIS
)
SS
COUNTY OF PEORIA )
AFFIDAVIT OFSERVICE & 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 7th day of September, 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 7th day of September, 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(a-)blackblackbrown.com
Subscribed and sworn to before me
this 7th day of September, 2006 .
I
OFPICIAI SEAL
JESSICAM RONNEY
NOTARYFUat-$TATEOFkLM1011
MYor11011WW:OS
1317
4F
BRIAN
W
q~
., k
S
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000 - Telephone
(309) 637-8514 - Facsimile
bme-ainnes(o).emrslaw.com
Br
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500-Telephone
(815) 431-1501 - Facsimile
oeoroe(d muelleranderson .com
Mr. Kevin Lyons
Peoria County State's Attorney
324 Main Street, Room #111
Peoria, Illinois 61602
(309) 672-6029 - Facsimile
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)1
(217) 524-8503 - Telephone
webbcnipcba .state .il .us
RECEIVEDCLERK'S
OFFICE
SEP
1
12006
PEORIA DISPOSAL COMPANY,
STATE OF ILLINOIS
)
Pollution Control Boaro
Petitioner,
)
PCB 06-184
V .
)
(Pollution Control Facility Siting Appeal)
PEORIA COUNTY BOARD,
)
Deponent .
)
NOTICE TOAPPEAR FOR DISCOVERY DEPOSITION
TO :
ELDON POLHEMUS, 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 3 :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
GIN
a d
ER, Its
I
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
bmeginnes(Demrslaw .com
RECEIVEDCLERK'S
OFFICE
SEP
1
12006
STATE OF
~
ILLINOIS
1 .
All documents in the possession or control of ELDON POLHEMUgtrol8oard
("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
RIDER A
GEORGE MUELLER
628 Columbus Street, Suite #204
Otfawa, 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(& m uelleranderson.com
bmeglnnes(etemrslaw.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 61350
(815) 431
.1500-Telephone
(815) 431-1501 - Facsimile
aeorge(Winuelleranderson .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) 637.6000-Telephone
(309) 637.8514-Facsimile
bmeaInnes(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.
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 61602-1611
(309)
637-6000
- Telephone
(615) 431-1501 - Facsimile
(309)
637-8514
- Facsimile
a eorae6D.mueileranderson.co m
bmealnnes(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
aeorge(Mmuelieranderson .com
5
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000 - Telephone
(309) 637-8514-Facsimile
bmeoinnes(&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(g.muelleranderson.com
6
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000 - Telephone
(309) 637-8514-Facsimile
bmeglnnes(Memrslaw .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.
906-1183
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
aeorge69mueileranderson
.co m
bmeglnnescTemrslaw .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 7th day of September, 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 7th day of September, 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(c, b lackblackbrown .com
Subscribed and sworn to before me
this 7th day of September, 2006 .
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500-Telephone
(815) 431-1501 -
Facsimile
aeorge(amuelleranderson.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@iocb.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
bmeainnes(demrslaw.com
