1. NOTICE OF FILING
      2. PROPOSED DISCOVERY SCHEDULE
BTL/10/7/03
Attorney No. 90068
STATE OF ILLINOIS
COUNTY OF COOK
)
)
ss.
)
BEFORE THE ILLINOIS POLLUTION
MORRY GABEL, MYRA GABEL,
DONFOREMAN, MARSHA FOREMAN,
KEITH PINSONEAULT and TRACY PINSONEAULT.
TIHIE WEALSUIRE, NC.,
an
ILLINOIS CORPORATION.
Complainant,
vs.
Respondent.
CLERK’S
OFFICE
OCT
o
7
2003
CONTROL BOARDSTATE OF ILLINOIS
Pollution Control Board
)
)
)
)
)
)
)
)
)
)
)
)
No. PCB 03-38
NOTICE OF FILING
Bradley P. Halloran
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center, Suite 11-500
100 West Randolph Street
Chicago, IL 60601
Mitchell S. Feinberg
Chuhak &
Tecson, P.C.
30 South Wacker Drive
Suite 2600
Chicago,IL 60606
THE WEALSHIRE, INC.
I
~
/
~By~2Ash,
Ano~,
Freei?Iman &~Lo~áii,
L.L.C.
PLEASE TAKE NOTICE that on the
/
day of October, 2003, there was filed with the
Illinois
Pollution
Control Board Respondent’s
Proposed Discovery
Schedule, a
copy of which is
attached and herewith served upon you.
Bruce T.
Logan
Ash, Anos, Freedman & Logan, L.L.C.
77 West Washington Street
Chicago, IL 60602
312-346-1389
Attorneys forRespondent
AFFIDAVIT
OF SERVICE
The undersigned, being first duly
sworn on oath, deposes and says that she served the above
and foregoing Notice ofFiling and Proposed Discovery Schedule by mailing a copy to:
Bradley P. Halloran
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
Suite
11-500
100 WestRandolph Street
Chicago, IL 60601
FAX 312-814-3669
Mitchell S. Feinberg
Chuhak&Tecson,P.C.
30 South Wacker Drive
Suite 2600
Chicago, IL 60606
FAX 312-444-9027
and depositing same in the U.S. Mail Chute at 77 West Washington Street, Chicago, Illinois 60602,
at 5:00 P.M.
on October 7, 2003, with proper postage prepaid and by faxing a copy to the numbers
indicated above on October 7, 2003.
Subscribed and sworn to before me
this
I
day~ofOctokr~
2003.
—y:.’~~i~L.
,~
NOTA~Pt~i~~
BTL/1O/6/03
Attorney No.
90068
STATE OF ILLINOIS
)
COUNTY OF COOK
)
ERF~S
OFFICE
OCT
072003
STATE OF ILLINOIS
POLLUTION CONTROL BOARD
STATE OF ILLINOIS
100 W. RANDOLPH STREET, SUITE 11-500
Pollution
Control Board
CHICAGO, ILLINOIS 60601
MORRY GABEL, MYRA GABEL,
)
DONFOREMAN, MARSHA FOREMAN,
)
KEITH PINSONEAULT and TRACY PINSONEAULT.
)
)
Complainant,
)
)
vs.
)
No. PCB 03-38
)
THE WEALSHIRE,
INC., an
)
ILLINOIS CORPORATION.
)
)
Respondent.
)
)
PROPOSED DISCOVERY SCHEDULE
NOW
COMES
the
Respondent,
THE
WBALSHIRE,
INC.,
an
Illinois
Corporation,
and
proposes the following discovery schedule:
1.
Written
discovery,
including
a
production
request
and
interrogatories,
to
be
completed by December
1, 2003;
2.
Depositions
of
the
parties,
including
the
six
(6)
named
Complainants
and
presumably Arnold Goldberg,
President of The Wealshire, Inc., and
Ralph Chapman, the building
manager ofThe Wealshire operation,
to be taken one per week and to be concluded by February
15,
2004;
3.
In order to be timely, the depositions ofthe parties’ opinion/expert witnesses must
be scheduled after Respondent completes modification.
The current modifications in process will
be
completed by the end ofOctober, 2003, but the air conditioning units will not be operable until
June of2004.
We suggest that the initial expertwitnesses’ depositions be taken after a restartofthe
equipment
which
should
come
in
mid-June
of 2004
to
allow
for
testing.
We
propose
the
depositions ofboth Timothy
O’Neill of O’Neill Engineered
Systems,
Inc.
and the Complainants’
expert,
Gregory Zak, be taken prior to
July
1,
2004;
that reply experts be
identified by
July
22,
2004, and theirdepositions completedby August
15,
2004.
4.
It
is possible
during the course ofdiscovery that other witnesses will be identified
by
the parties.
We propose those witnesses be subpoenaed and deposed prior to March
1, 2004.
Bruce T. Logan
Ash, Anos, Freedman & Logan, L.L.C.
77 West Washington Street
Chicago, IL 60602
312-346-1389
Attorneys for Respondent
Respectfully submitted,
THE
L.L.C.
-2-

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