RECCLERK'SEIVED
OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARDSTATE
OCT
OF
2
5 2006
Pollution Control
ILLINOIS
Board
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
V .
SKOKIE VALLEY ASPHALT, CO ., INC .,
EDWIN L. FREDERICK, JR.,
individually and as
owner and President of Skokie Valley Asphalt
Co., Inc., and RICHARD J
. FREDERICK,
individually and as owner and Vice President of
Skokie Valley Asphalt Co
., Inc.,
Respondent
NOTICE OF FILING
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of the Pollution
Control Board the RESPONDENTS' SECOND DEPOSITION NOTICE TO COMPLAINANT
REGARDING COMPLAINANT'S FEE PETITION, a copy of which is hereby served upon you .
~'MDav
o~
ONeill
October 25, 2006
David S . ONeill, Attorney at Law
5487 N . Milwaukee Avenue
Chicago, IL 60630-1249
(773) 792-1333
PCB 96-98
Enforcement
BEFORE THE ILLINOIS POLLUTION CONTROL BOARDRECEIVEDCLERK'S
OFFICE
OCT 2 5 2006
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
Pollution
STATEOFControlControl
Board
)
PCB 96-98
v .
)
Enforcement
SKOKIE VALLEY ASPHALT, CO
., INC .,
)
EDWIN L . FREDERICK, JR ., individually and as )
owner and President of Skokie Valley Asphalt
)
Co., Inc., and RICHARD J. FREDERICK,
)
individually and as owner and Vice President of )
Skokie Valley Asphalt Co ., Inc .,
)
Respondents.
)
RESPONDENTS' SECOND DEPOSITION NOTICE TO
COMPLAINANT REGARDING COMPLAINANT'S FEE PETITION
Please take notice that counsel for the Respondents shall, pursuant to Illinois Supreme
Court Rule 206 and Illinois Pollution Control Board Rule 101 .622, take the discovery deposition
of Mitchell Cohen, Esq. commencing at 2 :00 p .m. on Tuesday November 14, 2006 at 5487 N .
Milwaukee Avenue, Chicago, Illinois . Mr. Cohen is instructed to bring with him documents
relevant to the matter under consideration .
Respectfully submitted,
David S .
eill
David S
. ONeill, Attorney at Law
5487 N . Milwaukee Avenue
Chicago, Illinois 60630-1249
(773) 792-1333
I
NOTARY SEAL
SUBSCRIBED AND SWORN TOME this
day of F?c7D~&t , 20 CK
Notary Publi
CERTIFICATE OF SERVICE
I, the undersigned, certify that I have served the attached RESPONDENTS' SECOND
DEPOSITION NOTICE TO COMPLAINANT REGARDING COMPLAINANT'S FEE
PETITION by hand delivery on October 25, 2006, upon the following party
:
Mitchell Cohen, Esq
and
Mr. Michael Partee, Esq .
Environmental Bureau
Assistant Attorney General
Illinois Attorney General's Office
188 W. Randolph, 20th Floor
Chicago, IL 60601
OFFICIAL SEAL
DENNIS R O'NEILL
NOTARY
MY COk"SSION
PUBLIC
.
EXPIRESSTATE
OF
:09/2oPo7ILLINOIS