REC~~VED
CLERK’S OFFICE
DEC-9 2003
STATE OF ILLINOIS
Pollution Control Board
OFFICE OF THE ATTORNEY GENERAL
STATE OF ILLINOIS
Lisa Madigan
ATTORNEY GENERAL
December 5, 2003
The Honorable Dorothy Gunn
Illinois Pollution Control Board
State of Illinois Center
100 West Randolph
Chicago, Illinois 60601
Re:
People v. The Highlands, LLC.,
et
al.
PCB No. 00-1 04
Dear Clerk Gunn:
Enclosed for filing please find the original and ten copies of a NOTICE OF FILING and
PROPOSED AGREED DISCOVERY SCHEDULE FOR COMPLAINANT AND RESPONDENT
HIGHLANDS in regard to the above-captioned matter. Please file the original and return a file-
stamped copy of the document to our office in the enclosed self-addressed, stamped envelope.
Thank you for your cooperation and consideration.
Very truly yours,
~
Jane E. McBride
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
(217) 782-9031
J EM/pp
Enclosures
500 South
Second Street,
Springfield, Illinois 62706 • (217) 782-1090 •
TTY:
(217) 785-2771 • Fax: (217) 782-7046
100
West
Randolph
Street,
Chicago, Illinois
6060!
• (312) 814-3000 • TTY: (312) 814-3374 •
Fax: (312) 814-3806
1001 East Nl~in,Carbondale, Illinois 62901
•
(618) 529—640(1
•
1’~1Y:(61$)
529—6403
• Fax:
(618) 529-6416
PEOPLE OF THE STATE OF ILLINOIS,
Complainant,
CLERK’S OFFICE
THE HIGHLANDS, LLC, an Illinois limited
liability corporation, MURPHY FARMS, INC.,
a/k/a MURPHY FAMILY FARMS, a North
Caroline corporation, and BION
TECHNOLOGIES, INC., a Colorado Corp.,
Respondents.
PCB NO. 00-1 04
(Enforcement)
NOTICE OF FILING
To:
Mr. Jeffery W. Tock
Harrington, Tock & Royse
201 W. Springfield Ave.
P.O. Box 1550
Champaign, IL 61824-1500
Mr. Charles M. Gering, Esq.
McDermott, Will & Emery
227 West Monroe Street
Chicago, IL 60606-5096
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk of the Pollution
Control Board of the State of Illinois, PROPOSED AGREED DISCOVERY SCHEDULE FOR
COMPLAINANT AND RESPONDENT HIGHLANDS, a copy of which is attached hereto and
herewith served upon you.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN
Attorney General of the
State of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/Asbestos
Litigation Division
Of Counsel
Jane E. McBride
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: December 5, 2003
BY:
THOMAS DAVIS, Chief
Assistant Attorney General
Environmental Bureau
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
DEC - 92003
V.
STATE OF ILLINOIS
Pollution Control Board
)
)
)
)
)
)
CERTIFICATE OF SERVICE
I hereby certify that I did on December 5, 2003, send by First Class Mail, with postage
thereon fully prepaid, by depositing in a United States Post Office Box a true and correct copy
of the following instruments entitled NOTICE OF FILING and PROPOSED AGREED
DISCOVERY SCHEDULE FOR COMPLAINANT AND RESPONDENT HIGHLANDS
To:
Mr. Jeffery W. Tock
Harrington, Tock & Royse
201 W. Springfield Ave.
P.O. Box 1550
Champaign, IL 61824-1500
Mr. Charles M. Gering, Esq.
McDermott, Will & Emery
227 West Monroe Street
Chicago, IL 60606-5096
and the original and ten copies by First Class Mail with postage thereon fully prepaid of the
same foregoing instrument(s):
To:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
State of Illinois Center
Suite 11-500
100 West Randolph
Chicago, Illinois 60601
(Also by Facsimile (312) 814-3669)
A copy was also sent by First Class Mail with postage thereon fully prepaid
To:
Mr. Brad Halloran, Hearing Officer
Illinois Pollution Control Board
State of Illinois Center, Ste. 11-500
100 West Randolph
Chicago, IL 60601
(Also by Facsimile (312) 814-3669)
Of Counsel
JANE E. McBRIDE
Assistant Attorney General
Thomas Davis, Chief
Assistant Attorney General
Environmental Bureau
This filing is submitted on recycled paper.
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
DEC - 9 2003
PEOPLE OF THE STATE OF ILLINOIS
)
STATE OF ILLINOIS
)
Pollution Control Board
Complainant,
V.
)
PCB No. 00-104
)
(Enforcement)
THE HIGHLANDS, LLC, an Illinois limited
)
liability corporation, and MURPHY
)
FARMS, INC., (a division of MURPHY-
)
BROWN, LLC, a North Carolina limited
)
liability corporation, and SMITHFIELD
)
FOODS, INC., a Virginia corporation).
)
Respondents.
PROPOSED AGREED DISCOVERY SCHEDULE FOR
COMPLAINANT AND RESPONDENT HIGHLANDS
NOW COMES the Complainant, PEOPLE OF THE STATE OF ILLINOIS, and
Respondent THE HIGHLANDS, LLC and submit the following proposed agreed discovery
schedule for the continuing litigation between these two parties:
All parties submit responses for
all outstanding written discovery
March 1, 2004
Complainant shall disclose opinion witnesses
and opinions
March 1, 2004
Respondent Highlands shall disclose
opinion witnesses and opinions
April 1, 2004
Depositions completed by all parties
July 1, 2004
1
F.
04~0~2
12/04/03 TRTJ 16:37
FAX
3528707
DEC—03—2003 WED 03:b8 I’ll
ENVIRONNENThL
All
written
discoveryfiled and served
EARRINCT0~~0~K&R0y~
August
1,2004
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGANI
Attorney General of the
State
of Illinois
MATTHEW J, DUNN,
Chief
Environmental Enforcement/Asbestos
Litigation
Division
BY;
~
-~
E E~
MCBRIDE
Assistant
Attorney
General
500 South Second Street
Springfield,
Illinois 62706
(217)782-9031
Dated:
December-~-2OO3
/~2./L//6
3
THE
BY;
Harrington Took & Royse
201 W SprIngfield Ave.
Suite 601
P0
Box 1550
Champaign, IL
61824-1550
Date:
TOCK
The Highlands