RECE~VED

CLERK’S OFFICE

DEC

13

2004

BEFORE THE ILLINOIS POLLUTION CONTROL BOARD

STATE

OF ILLINOIS

Pollution Control Board

PEOPLE OF THE STATE OF ILLINOIS

)

)

Complainant,

)

)

vs.

)

)

Case No.

PCB 03-19 1

COMMUNITY LANDFILL COMPANY, INC.,)

an Illinois corporation, and the CITY OF

)

MORRIS, an Illinois

municipal corporation.

)

)

Respondents.

)

NOTICE OF DISCOVERY DEPOSITION

TO:

See attached Affidavit of Service

On

December

13,

2004,

at

1:00

p.m.,

at

1021

N.

Grand,

Springfield,

Illinois,

the

deposition of Christine

Roque

will

be

taken before a notary public,

on

oral interrogatories for

discovery in this case, and at that time the deponent shall produce all the documents requested on

the attached rider.

Dated:

I ~

,

2004

Respectfully Submitted,

On behalfof the CITY OF MORRIS

By:

Hinshaw &

Culbertson LLP

•

__

Richard S.4~orter

One of Attorneys

HINSHAW & CULBERTSON LLP

100 Park Avenue

P.O.

Box

1389

Rockford, IL

61105-1389

815-490-4900

This document utilized 100

recycled paper products

70432236v1

806289

---

RECE~VED

CLERK’S OFFICE

DEC

13

2004

DEPOSITION RIDER

STATE OF ILLiNOIS

You

are

hereby

instructed

to

bring

with

you,

and

have

present

with

you

~

Board

deposition in this case, the following documents:

1.

All records, documents and other tangible

items received by the deponent for review concerning

this case or any of the deponent’s anticipated testimony, whether or not in fact reviewed.

2.

All

other

records,

documents

or

other

tangible

items

reviewed

or

consulted

by

deponent

in

connection with this lawsuit.

3.

The deponent’s complete filepertaining to this lawsuit.

4.

All Correspondence or other communications received by deponent relative to this lawsuit.

5.

All correspondence Or other communications generatedby the deponent relative to this lawsuit.

6.

All notes (including notations made on records) relative to the deponent’s review and opinions.

7.

All

literature,

standards,

guidelines,

texts,

statute,

regulations,

rules,

policies,

procedures,

protocols and the

like, which deponent

(a)

has consulted in connection with his/her review,

(b)

relies upon, or (c) may otherwise use or referto at trial.

8.

All bills, time records and other billing records pertaining

to deponent’s activities in this lawsuit,

if any.

9.

•

All

reports,

memoranda,

summaries

or

other

writing

(including

drafts)

prepared

by

deponent

relative to this lawsuit.

10.

Deponent’s current curriculum vitae.

11.

Complete

records

reflecting

deponent’s

billings

and

payments

received

for

expert

witness

activities for the preceding five

calendar years, including, but not limited to, review of records,

consultation and testimony for any attorney, if any.

12.

A printout of any and

all

e-mail

or other

electronic

communications between the deponent

and

attorneys for the Illinois Environmental Protection Agency, or anyone acting on their behalf,

or in

anyway concerning this lawsuit or the parties to this lawsuit.

The foregoing requests shall include any computer-stored data, which shall be produced in a form

that is readable by the participants in the deposition.

If any of the above-requested materials are not produced at the deposition, the noticing party may,

athis/her election, (a) continue the deposition to another date, (b) adjourn and complete the deposition at

another time,

(c)

see

court

supervision of the

deposition,

andlor

(d)

seek

other relief from

the

court,

including but not limited to, costs and fees.

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806289

---

AFFIDAVIT OF SERVICE

The undersigned, pursuant to the provisions ofSection

1-109 ofthe Illinois

Code of Civil

Procedure,

hereby

under

penalty of perjury under

the laws of the

United

States of America,

certifies that on December 9, 2004,

she served

a

copy ofthe foregoing upon:

Documents Sent Via Facsimile:

Mr. Christopher Grant

Assistant Attorney General

Environmental Bureau

188 W. Randolph St., 20th Fl.

Chicago, IL

60601

Documents Sent Via Facsimile:

Clarrisa Grayson

LaRose & Bosco, Ltd.

734 N. Wells Street

Chicago, IL 60601

Ms.

Dorothy Gunn, Clerk

Pollution Control Board

100 W. Randolph, Suite 11-500

Chicago, IL 60601

BradleyHalloran

Hearing Officer

Pollution Control Board

100 W. Randolph, Suite

11

Chicago, IL

60601

Via facsimile and regular mail from Rockford, Illinois, addressed

as above.

HINSHAW &

CULBERTSON

100 Park Avenue

P.O. Box

1389

Rockford, IL 61105-1389

(815)

490-4900

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806289