RECEI~V~!D
BEFORE THE ILLiNOIS POLLUTION
CONTROL BOARD
CLERK’S
OFFICE
APR
25
20C5
PEOPLE
OF THE STATE OF ILLiNOIS,
)
STATE
OF ILLINOIS
omp ainan,
PCB
9698
Pollution
Control Board
)
-
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
)
NOTICE
OF DEPOSITION
REGARDING ATTORNEYS’
FEESg
COSTS AND EXPENSES
The Respondents, 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 VicePresident ofSkokie Valley Asphalt Co., Inc., by
and through their attorney, David S.
O’Neill, herein respectfully, notify you that pursuant to the
provisions of Section 2-1003 ofthe Illinois
Code ofCivil Procedure the following deposition
will be taken forthepurpose ofdiscoverybefore a Notary public atthe time and place specified,
upon interratories to be propounded to said witness orally.
This request upon you
to produce
said individual and the documents listed below:
DEPONENTS
DATE AND TIME
Mr. Mitchell Cohen, Esq. ofthe
June 24, 2005
Illinois
Attorney General’s Office
.
at 9:00 a.m.
Mr.
Bernard Murphy, Esq. ofthe
June 24, 2005
Illinois Attorney General’s Office
at 1:00 p.m.
Any
and
all
documents,
photographs,
reports
and
other tangible
items
identified by
the
deponent
in
response
to
any
Request for Production
shall
be
produced
by the
deponent at
this
—1—
deposition for inspection and query ofthe deponent.
Said deposition
is to be taken at the offices of
Dennis R. O’Neill,
P.C. located at 5487 N. Milwaukee Avenue, Chicago, IL 60630-1249.
David S.
O’Neill
By:
~
On bepaffof the1~Iespondents
April
25,
2005
David S. O’Neill
5487
N. Milwaukee Avenue
Chicago, Illinois 60630-1249
773
792-1333
-2-
CERTIFICATE OF SERVICE
I, the undersigned, certify that I have served the attached
NOTICE OF DEPOSITION
REGARDiNG ATTORNEYS’ FEES,
COSTS AND EXPENSES by hand delivery on April
25, 2005, upon the following party:
Mitchell Cohen
Environmental Bureau
Assistant Attorney General
Illinois Attorney General’s Office
188 W. Randolph, 20th Floor
Chicago, IL
60601
SUBSCRIBED AND SWORN TO ME this
dayof
~~Publi~
NOTARY SEAL
,20~)
OFFICIAL
SEAL
DENNIS
R GNEILL
NOTARY
PUBLIC
-
STATE OF ILLINOIS
MY COMMISSION
EXPIRES:091201O7
RECE~VF~D
CLERK’S
OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
APR 25
2005
STATE OF ILLINOIS
PEOPLE
OF THE
STATE OF
ILLINOIS,
)
Pollution Control Board
-
Complainant,
)
)
PCB 96-98
)
V.
)
Enforcement
)
)
SKOKIE VALLEY ASPHALT, CO., INC.,
)
EDWIN L.
FREDERICK, JR., individually and as
)
owner and President ofSkokie 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 NOTICE OF DEPOSITION REGARDING ATTORNEYS’ FEES,
COSTS AND EXPENSES, a copy ofwhich is hereby served upon you.
/414’
c24~/
-
D~fdS. O’N~ill
April
25,
2005
David S.
O’Neill, Attorney at Law
5487 N. Milwaukee Avenue
Chicago, IL 60630-1249
(773) 792-1333
