RE
    CE
    J V £
    £*‘
    BEFORE THE ILLINOIS POLLUTION CONTROL BOA~P~R1IS
    OFRCE
    PEOPLE OF THE STATE OF ILLINOIS,
    )
    SEP
    1
    5
    2003
    Petitioner,
    )
    STATE OF ILLINOIS
    )
    Pollution
    Control Board
    )
    PCB 97-2
    )
    Enforcement
    JERSEY SANITATION CORPORATION,
    )
    )
    Respondent.
    )
    NOTICE OF FILING
    AND
    PROOF OF SERVICE
    The undersigned
    certifies that an
    original
    and
    nine copies
    of Respondent’s
    Witness
    List
    were served upon the Clerk of the illinois Pollution
    Control Board,
    and one copy
    was served
    upon
    the following party of record and the Hearing Officer in this
    cause
    by
    enclosing same
    in
    envelopes
    addressed to:
    Dorothy Gunn, Clerk
    Carol Sudman, Hearing Officer
    illinois Pollution Control Board
    Pollution Control Board
    James R. Thompson Center
    600 South Second Street, Ste. 402
    100 W. Randolph St., Suite 11-500
    Springfield, IL
    62704
    Chicago, IL
    60601
    Jane McBride
    Attorney General’s Office
    Environmental Bureau
    500 South Second Street
    Springfield,
    Illinois 62706
    with postage fully prepaid, jip~4by depositing
    said
    envelopes
    in
    a
    U.S.
    Post
    Office Mail Box
    in
    Springfield, Illinois on the L/fiday ofSeptember,
    2003.
    HEDINGER LAW OFFICE
    2601 South Fifth Street
    Springfield, IL 62703
    (217)
    523-2753
    phone
    (217)
    523-4366
    fax
    ThisPleading is being sub,nitted on recycledpaper.
    •RECEIVED
    CLERK’S
    OFFICE
    BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
    SEP
    152003
    PEOPLE OF THE STATE OF ILLINOIS,
    )
    )
    STATE OF IWNOIS
    Petitioner,
    Pollution Control Board
    )
    v.
    )
    PCB 97-2
    )
    Enforcement
    JERSEY SANITATION CORPORATION,
    )
    Respondent.
    WITNESS LIST
    NOW COMES Respondent, JERSEY SANITATION CORPORATION, through its
    undersigned attorney,
    and hereby submits its witness list for the September 26, 2003 hearing.
    1.
    Rich Johnson
    Assistant Regional Manager, Bureau ofLand
    Illinois Environmental Protection Agency
    1021 North Grand Avenue East
    P.O. Box 19276
    Springfield, IL 62794-9276
    Mr. Johnson will appear as an adversewitness and will testify regarding all matters
    concerning the Jersey Sanitation Landfill, including inspections, site history, permit
    background, all violations alleged by
    Complainant, and conversations with Respondent’s
    employees and agents.
    2.
    Pam Shourd, President
    Jersey Sanitation Corporation
    24257
    Old Barn Ln
    Jerseyville, Illinois 62052
    Ms. Shourd will testify regarding all matters concerning Jersey Sanitation Landfill,
    including inspections, site history, permit background, all violations alleged by Complainant,
    challenges to those alleged violations, conversations with Complainant’s employees and
    agents including discussions of financial assurance, and facts and circumstances bearing
    upon the amount of any penalty to be issued
    in this case.
    3.
    Tracey Kelsey
    Heneghen & Associates
    830 S. State St.
    P.O. Box 86
    •
    Jerseyville, IL 62052-0086
    Mr. Kelsey will testify concerning all matters relating to survey issues.
    4.
    Andy Rathsack or designated agent ofAndrews Environmental Engineering, Inc.
    3535 Mayflower St.
    Springfield, IL 62707
    Mr. Rathsack ora designated agentofAndrews Environmental Engineering, Inc.
    will testify relating to the history and background of the Jersey Sanitation Landfill, the
    permitting history and background ofthe Jersey Sanitation Landfill, matters pertaining to
    surveys and boundary control, and the history and permitting requirements and industry
    standards during the relevant time frame ofclosure/post-closure of this landfill.
    Respectfully submitted,
    Jersey Sanitation Corporation,
    •
    Respondent,
    By its attorney,
    •
    HEDINGER LAW OFFICE
    By________
    ~tepJ~n
    F. Hedmger
    /
    Hedinger Law Office
    2601 S. Fifth St.
    Springfield, IL 62703
    (217) 523-2753 phone
    (217) 523-4366 fax

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