RECEIVED
CLERK’S
OFFICE
Carolyn K. Gerwin
705
South Locust Street
JUL
Z
9
2003
Pontiac IL
61764
(815)842-2486
STATE OF ILLiNOiS
d
PoUutIofl Control Boar
July 23,
2003
Pollution Control Board
Attn:
Clerk
100 West Randolph Street
James R.
Thompson Center, Suite 11-500
Chicago, illinois
60601-3218
Re:
CALE v.
American Disposal Services. No. PCB 03-236:
Addendum to
Memorandum in Opposition to Motion to DismissPetition forReview: Motion
for Designation ofLead Counsel
Dear Sir:
Please find enclosed forfiling one original and nine copies ofPetitioner Citizen
Against Landfill Expansion’s (1) Exhibit D to Petitioner’s Memorandum in Opposition to
Applicant’s Motion to Dismiss (Statement ofBarb
Christensen), which was inadvertently
omitted from the original filing;
and
(2) Motion for Designation ofLead Counsel.
Thank
you.
Yours truly,
Carolyn K. Gerwin
Counsel forPetitioner
Cc:
Counsel ofRecord (w/enc)
(1~-f,
T~
RECEIVED
CLERK’S OFF!CE
JUL
2 92003
STATE OF ILLINOIS
To Whom
it may concern,
Pollution
Control Board
I
am part of a local group of Livingston
County residents called Citizens Against
the
Landfill
Expansion.
We
were
represented
by
Carolyn
Gerwin,
Doris
Burnside, Julie Russow, Barb Christensen and others at the siting hearing for the
Livingston
Landfill held Mar.lOth thru
the 14th
.
2003.
We are appealing the approval by the Livingston County Board for the expansion
of the landfill.
Sincerely,
~
~-/q
-
,~‘~igned
Name
Date
Printed Name
/D~
S.
~
~T
Street
~yJ2~
,~/
7~ 2ZZ-~
City and State
Witnessed by:~
~
é
Date
BEFORE THE ILLINOIS
RECEIVED
POLLUTION CONTROL BOARD
CI.FPK’S
OFFICE
JUL
292003
Citizens Against Landfill Expansion,
)
Petitioners
STATE OF ILLINOIS
)
Pollution
Control Board
V.
)
)
American Disposal Services ofIllinois, Inc.
)
No. PCB 03-236
Respondent,
)
)
and
)
)
Livingston County Board, Livingston County,
)
Illinois. Respondent
MOTION FOR DESIGNATION OF LEAD COUNSEL BY RESPONDENTS
Citizens Against Landfill Expansion, an unincorporated association ofresidents of
Livingston County (hereinafter “CALE”), has petitioned forreview oflocal siting ofa 50
million cubic yard expansion ofthe Livingston Landfill in Pontiac,
Illinois.
Two sets of
counsel have appeared on behalfofRespondent American Disposal Services ofIllinois,
Inc. (“Applicant”)
(namely, George Mueller, P.C., and Douglas Lee ofEhrmann,
Gehibach, Badger & Lee) and two other sets ofcounsel have appeared on behalfof
Respondent Livingston County Board
(C. Thomas Blakeman of Strong, Blakeman &
Schrock and Larry M. Clark, Attorney at Law).
Petitioner CALE hereby requests that the
Hearing Officer order Respondents to designate lead counsel.
The multiplicity of
appearances by Petitioners’ counsel is an undue hardship to CALE with regard to
copying and postage, especially in light ofthe potentially bulky exhibits in this matter.
If
Respondents wish to have the benefit ofmultiple sets ofcounsel in this matter,
Respondents should bear the extraburden associated with such multiple representations.
Respectfully submitted,
Carolyn K.~ierwin, Attorney at Law
Counsel for Citizens Against Landfill Expansion
Carolyn K. Gerwin
Attorney at Law
705
South Locust Street
Pontiac, Illinois 61764
(815)
842-2486
CERTIFICATE OF SERVICE
I hereby certify that I have served the foregoing Motion forDesignation ofLead
Counsel as follows:
On July33’, 2003, I mailed one original and 9 copies thereofto the Illinois
Pollution Control Board, by U.S. Mail, return receipt requested and postage prepaid, to:
illinois Pollution Control Board:
Pollution Control Board
Attn:
Clerk
100 West Randolph Street
James R.
Thompson Center, Suite 11-500
Chicago, illinois 60601-3218
On July~,4,2003, I sent a true and
correct copy thereofby U.S.
Mail to:
Douglas E. Lee
Ehrmann, Gehibach, Badger & Lee
215 E. First Street, Suite
100
P.O. Box
447
Dixon, Illinois 61021
C. Thomas
Blakeman
Strong, Blakeman &
Schrock
307 West Washington Street
Pontiac,
illinois 61764
George Mueller, P.C.
Attorney at Law
501
State Street
Ottawa,1L61350
LariyM. Clark
Suite 200
700 North Lake Street
Mundelein IL 60060
2