RECE~VE~
CLERK’S OFFICE
AUG 2 02004
BEFORE THE ILLINOIS POLLUTION CONTROL BOARI1STATE
Folluton
OF
Control
ILLINOIS
Board
COUNTY
OF KANAKEE, COUINTY
BOARD OF KANKAKEE, AND WASTE
MANAGEMENT OF ILLINOIS,
INC.
)
)
)
)
)
)
PCB 03-135
Consolidated Third-Party
Pollution Control Facility
Siting Appeal,
on appeal,
3-03-0924 (3rd Dist.)
TO:
See Attached Service List
NOTICE OF FILING
PLEASE TAKE NOTICE that on the 20th
day of August, 2004,
we filed with the Illinois
Pollution Control Board, the attached document entitled: WATSON’S RESPONSE OBJECTING
V.
CITY OF KANKAKEE,
)
Petitioner,
)
PCB 03-125
PCB 03-133
PCB 03-134
Respondents,
MERLIN KARLOCK,
Petitioner,
)
v.
)
)
COUNTY OF KANAKEE, COUINTY
)
BOARD OF KANKAKEE, AND WASTE
)
MANAGEMENT OF ILLINOIS, INC.
)
Respondents,
)
MICHAEL WATSON,
)
Petitioner,
)
v.
)
)
COUNTY OF KANAKEE, COUINTY
)
BOARD OF KANKAKEE, AND WASTE
)
MANAGEMENT OF ILLiNOIS, NC.
)
Respondents,
~)
KEITH RIJNYON,
)
Petitioner,
)
v.
)
)
COUNTY OF KANAKEE, COUINTY
)
BOARD OF KANKAKEE, AND WASTE
)
MANAGEMENT OF ILLINOIS, INC.
)
Respondents,
)
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TO WMII’S MOTION FOR RELIEF FROM JUDGMENT, a
copy of which is hereby served
upon you.
Intervener, Michael Watson
By:______________
One of his attorneys
Jennifer J. Sackett Pohlenz
Erin S. Keane
QUERREY & HARROW, LTD.
175 West Jackson Boulevard, Suite 1600
Chicago, Illinois 60604
(312) 540-7000
PROOF OF SERVICE
Karen
Gryczan, a
non-attorney, on oath,
certifies that she served the foregoing
Notice of
Filing, and document
set
forth herein, on the attorneys named on the attached
service list
via
U.S. Mail at 175
W. Jackson Blvd., Chicago, Illinois this
20th day
ofAugust,
2004, before the hour of
5:00
p.m.
/
x
Under penalties as provided by law pursuant to
IL, REV. STAT. CHAP 110 SEC 1-109 1 certif~,r
that the statements set forth herein are true and correct.
Dorothy Gunn
Illinois Pollution Control Board
Clerk’s Office
James R. Thompson Center
Ste. 11-500
100 W. Randolph Street
Chicago, IL 60601
One Original and 9
copies
Kenneth A. Leshen
One Dearborn Square
Suite
550
Kankakee, IL 60901
Via U.S. Mail
Patricia O’Dell
1242 Arrowhead Drive
Bourbonnais, IL 60914
Via U.S.
Mail
L. Patrick Power
956
N. Fifth Avenue
Kankakee, IL 60901
Via
U.S. Mail
Bradley Halloran
Illinois Pollution Control Board
Clerk’s Office
James R. Thompson Center, Ste. 11-500
100W. Randolph Street
Chicago, IL 60601
Via Hand Delivery
Charles Heiston
Hinshaw & Culbertson
100 Park Avenue
P.O. Box 1389
Rockford, IL 61105-1389
Via U.S. Mail
Donald Moran
Pederson & Houpt
161 N. Clark Street, Suite 3100
Chicago, IL 60601-1149
Via U.S. Mail
Elizabeth S. Harvey, Esq.
Swanson, Martin & Bell
One IBM Plaza, Suite 2900
330 N. Wabash
Chicago, IL 60611
Via U.S.
Mail
Christopher W. Bohien
200 E. Court Street, Suite 502
P.O. Box 1787
Kankakee, IL 60901
Via U.S. Mail
Kenneth A. Bleyer
Attorney at Law
923 W. Gordon Terrace #3
Chicago, IL 606 13-2013
Via U.S. Mail
Keith Runyon
1165 Plum Creek Drive
Bourbonnais, IL 60914
Via U.S. Mail
Leland Milk
6903 S. Route
45-52
Chebanse, IL 60922-5153
Via U.S. Mail
George Mueller, P.C.
501 State Street
Ottawa, IL 61350
Via U.S. Mail
Document #: 951345 vi
CLERK’S OFFICE
AUG 2 0 200k
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
STATE OF ILLINOIS
Pollution Control Board
WASTE MANAGEMENT OF
)
ILLINOIS, NC., A Delaware
)
Corporation,
)
)
Docket Number:
PCB 04-186
Petitioner,
)
(Pollution Control Facility
vs.
)
Siting Appeal)
)
COUNTYBOARD OF KANKAKEE,
)
)
Respondent.
)
NOTICE OF FILING
TO:
See Attached Service List
PLEASE TAKE NOTICE that on the
20th
day of August, 2004,
we filed with the Illinois
Pollution Control Board, the attacheddocument entitled:
WATSON’S RESPONSE OBJECTING
To WMI1’S
MOTION FOR RELIEF FROM JUDGMENT, a
copy of which is hereby served
upon you.
Intervener, Michael Watson
By:___________
One of hi at orneys
Jennifer J. Sackett Pohlenz
Erin S. Keane
QUERREY & HARROW, LTD.
175 West Jackson Boulevard, Suite 1600
Chicago, Illinois 60604
(312) 540-7000
PROOF OF SERVICE
Karen Gryczan, a non-attorney, on oath, certifies that she served the foregoing
Notice of Filing, and document set forth herein, on the attor eys named on the attached
service list
via
U.S. Mail
at 175 W. Jackson Blvd., Chicago, linois this
20th
day of August,
2004, before the hour of 5:00 p.m.
x
Under penalties as provided by law pursuant to
IL. REV. STAT. CHAP 110 SEC 1-109 1 certiFy
that the statements set forth herein are
true
and correct.
Dorothy Gunn
Illinois Pollution Control Board
Cl,erk’s Office
James R. Thompson Center
Ste. 11-500
100 W. Randolph Street
Chicago, IL 60601
One Original and 9 copies
Patricia O’Dell
1242 Arrowhead Drive
Bourbonnais, IL 60914
Via U.S. Mail
Kenneth A. Leshen
One Dearborn Square
Suite 550
Kankakee, IL 60901
Via U.S.
Mail
L. Patrick Power
956 N. Fifth Avenue
Kankakee, IL 60901
Via U.S.
Mail
Bradley Halloran
Illinois Pollution Control Board
Clerk’s Office
James R. Thompson Center, Ste. 11-500
100 W. Randolph Street
Chicago, IL 60601
Via Hand Delivery
Charles Helston
Hinshaw & Culbertson
100 Park Avenue
P.O. Box 1389
Rockford, IL 61105-1389
Via U.S. Mail
Donald Moran
Pederson & Houpt
161 N. Clark Street, Suite 3100
Chicago, IL 60601-1149
Via
U.S. Mail
Elizabeth S. Harvey, Esq.
Swanson, Martin & Bell
One IBM Plaza, Suite 2900
330 N. Wabash
Chicago, IL 60611
Via U.S. Mail
Christopher W. Bohlen
200 E. Court Street, Suite 502
P.O. Box 1787
Kankakee, IL 60901
Via U.S. Mail
Kenneth A. Bleyer
Attorney at Law
923 W. Gordon Terrace #3
Chicago, IL 60613-2013
Via U.S. Mail
Keith Runyon
1165 Plum Creek Drive
Bourbonnais, IL 60914
Via U.S. Mail
Leland Milk
6903 S. Route
45-52
Chebanse, IL 60922-5153
Via
U.S. Mail
George Mueller, P.C.
501 State Street
Ottawa, IL 61350
Via U.S.
Mail
Document
#:
951345 vi
Respondents,
)
MERLIN KARLOCK,
)
Petitioner,
)
v.
)
)
COUNTY~OFKANAKEE, COUINTY
)
BOARD
OF KANKAKEE,
AND WASTE
)
MANAGEMENT OF ILLINOIS, INC.
)
Respondents,
)
MICHAEL WATSON,
)
Petitioner,
)
v.
)
)
COUNTY OF KANAKEE, COUINTY
)
BOARD OF KANKAKEE, AND WASTE
)
MANAGEMENT OF ILLINOIS, INC.
)
Respondents,
)
KEITH RUNYON,
)
Petitioner,
)
v.
)
)
COUNTY OF KANAKEE, COUINTY
)
BOARD OF KANKAKEE, AND WASTE
)
MANAGEMENT OF ILLINOIS, INC.
)
-
Respondents,
)
WATSON’S RESPONSE OBJECTING TO
WMII’S MOTION FOR RELIEF FROM JUDGMENT
NOW COMES Michael Watson, by and through his attorneys at Querrey & Harrow, Ltd.
and in response to Waste Management ofIllinois, Inc.’s Motion for Relief from Judgment sets
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CITY OF KANKAKEE,
Petitioner,
)
v.
)
)
COUNTY OF KANAKEE, COUINTY
)
BOARD OF KANKAKEE, AND WASTE
)
MANAGEMENT OF ILLINOIS, INC.
)
RECE~VED
CLERK’S OFFICE
AU6 20200k
STATE OF ILLINOIS
poUutiofl COfltt0t Board
PCB 03-125
PCB 03-133
PCB 03-134
PCB 03-135
Consolidated Third-Party
Pollution Control Facility
Siting Appeal,
on appeal,
3-03-0924 (3rd Dist.)
for the following objections:
1.
Waste Management ofIllinois, Inc. (WMII) states in its Notice ofFiling that it
flled, with the Illinois Pollution Control Board a Motion for Relief from Judgment. Such Motion
was not received by Querrey & Harrow, Ltd. until August 11, 2004. The Motion seeks, without
specifying what type, “relief’ from the Illinois Pollution Control Board’s (Board) August 7, 2003
Order which vacated the decision ofthe Kankakee County Board (County Board) to approve
WMII’s landfill expansion. The Board vacated the County Board’s approval based on the fact
that the County Board lackedjurisdiction, since WMII failed to follow the statutory requirements
forproviding pre-fihing notice to Brenda Keller, an adjacent landowner as shown on authentic
tax records.
2.
WMII seeks unspecified “relief’ from that judgment based on its assertion that a
County Board member’s recent testimony in a separate appeal, PCB 04-186, allegedly
contradicts portions ofRobert Keller’s testimony. WMII seeks this unspecified “relief’ pursuant
to Section 101 .904(b)(l) of the Board’s Rules. WMII’s Motion should be denied, as the Board
has no jurisdiction over this matter (since WMII has appealed the Board’s decision, which appeal
is still pending); the County Board member’s testimony on which WMII relies is nothing more
than suspect, at best, hearsay; and, even if the Board were to consider,
in arguendo,
WMII’ s
assertions, WMII clearly fails to meet the requirements for relief from judgment.
3.
In the interest ofefficiency, as respects the jurisdictional and hearsay arguments
raised herein, Watson adopts, repeats and incorporates the Board’s Response in Opposition to the
Motion for Stay ofAppeal which was filed by WMII in the Third District Appellate Court. A
true and correct copy of the Board’s Response is attached as
Exhibit A
hereto.
2
Printed
on
Recycled Paper
4.
In addition to those arguments correctly raised by the Board in its Response to the
appeal Motion brought by WMII, even if the Board were to consider WMII’s Motion under
Section 101 .904(b)(1), WMII fails to meet the elements for any relief from judgment. WMII
argues that Section 101.904(b) relief requires the elements of735 ILCS 5/2-1402 to be met.
Assuming,
in arguendo,
that is the appropriate standard to apply (which only for purposes ofthis
Response will not be contested), WMII fails to meet it.
5.
As the Illinois Supreme Court long ago observed, “It cannot be the practice of
courts to allow important matters to go to trial, and because one party is not satisfied with the
results ofit, let him go out and try to get facts which will enable him to do better at another trial,
and rely upon such after-ascertained matters as a basis for a new trial.”
Pritchett v. Steinker
Trucking Co.,
40 Ill. 2d 510, 512-513 (S.Ct. 1968),
citing, Chicago andAlton Railroad Co. v.
Raidy,
203 Ill. 310, 317.
6.
WMII has the burden ofproofto show the Board, among the other elements of
Section 1402, that the evidence it presents in support ofits Motion is “so conclusive” that it
would probably change the outcome. WMII has not only has failed to show the Board
“evidence” (opposed to hearsay), it also has failed to identify how the deposition ofthe subject
County Board member is “conclusive.”
7.
WMII presents no evidence to show that the subject County Board member’s
testimony would change
the result
if considered by the Board. If the “result” to which WMII
refers (since WMII fails to identify what relief it seeks) is the Board’s decision, WMII is
incorrect, as there were several other substantive issues raised during the Board’s review of the
County Board’s approval that would likely result in the Board reversing the decision of the
3
Printed on Recycled Paper
County Board. Although WMII attempts to highlight that jurisdiction was the “sole” issue on
which the Board vacated the County Board’s decision, as if there were not other issues in that
appeal, that emphasis falls flat. The Board did not need to make findings and a decision with
respect to the numerous other issues briefed by the parties, as the jurisdictional issue took
precedence and any other findings ofthe Board in a decision based on jurisdiction would be
dicta.
As such, if somehow, the Board’s decision on the jurisdictional issue were to be reversed,
the numerous other issues briefed would have to be decided and WMII has not shown how the
outcome is likely (in fact it is unlikely) to be any different.
8.
Ifthe “result” to which WMII refers is a new local hearing, WMII is again
incorrect. Since the County Board subsequently denied what WMII has asserted to be the same
or essentially the same application for siting, the result, as shown, will not be different if a “new
trial” or, in this case, new hearing, is granted. Thus, even if WMII were successful on its
Motion, reversing the Board’s decision on jurisdiction, and defeating all other arguments in the
petitioners’ briefs (none ofwhich should occur), the “end game” which WMII seeks to replay
will and has proven to not likely change the current result, as WMII’s re-filed application now on
review in Case No. 04-186, was denied by the County Board.
9.
Likewise, WMII presents no evidence that is “conclusive.” Without even looking
outside ofthe subject County Board member’s transcript attached to WMII”s Motion, there are a
host of inconsistencies and inaccuracies within her own statements that should call into question
her veracity.
10.
Additionally, WMII fails to show how, with due diligence, this could not have
been discovered during or prior to (during the discovery phase of) the Board’s hearing. WMII
4
Printed on Recycled Paper
attempts to circumvent this obvious fault in its Motion by asking the Board to put blinders on
and look only to the time frame ofthe local hearing. WMII had every opportunity to conduct
discovery into the notice issues being reviewed by the Board in PCB 03-125, 133, 134 and 135,
and choose not to. It could have taken the subject County Board member’s deposition at that
time; it could have drafted written discovery regarding notice for the parties, including the
County, to answer; it could have subpoenaed other potential witnesses, such as Kirt Stevens (the
houseguest ofthe Kellers), but, it simply choose to do none ofthese things.
11.
Further, WMII fails to show how the subject County Board member’s testimony
is “material to issues,” since whether or not there was a posting is immaterial to the Board’s
August 7, 2003 Order.
12.
Finally, WMJI fails to show how the subject County Board member’s testimony is
anything other that cumulative. Even on the irrelevant issue ofwhether there was a posting,
which appears to be the “essence” of WMII’s Motion, there is already differing evidence in the
record. Certainly if discovery were re-opened additional testimony would be taken that would
contradict the subject County Board member’s allegations and, on information and belief some
already has, under the guise ofPCB 04-186 without the parties to PCB 03-125, 133, 134 and 135
noticed or present (to which Watson objects), that WMII has chosen not to show the Board, and
which contradicts the subject County Board member’s allegations.
13.
Therefore, first and foremost, WMII’s Motion should be denied, as the Board
does not have jurisdiction over this matter. However, even if the Board were to consider WMII’s
Motion, the Motion comes woefully short ofWMII’s burden and fails to meet almost every
element required under a 735 ILCS 5/2-1402 review.
5
Printed on RecycledPaper
WHEREFORE, Michael Watson respectfully request the Illinois Pollution Control Board
deny WMII’s Motion and forwhatever additional relief the Board deems appropriate.
Dated: August 20, 2004
Respectfully submitted,
PETITIONER MICHAEL WATSON
By:
______________
One ofhis attorneys
Jennifer J. Sackett Pohlenz
Querrey & Harrow, Ltd.
175 W. Jackson Blvd., Suite 1600
Chicago, Illinois 60604
Phone: (312) 540-7540
6
Printed on Recycled Paper
No. 3.030924
IN THE
APPELLATE COURT OF ILLINOIS
THIRD JUDICIAL DISTRICT
WASTE MANAGEMENT OF
) Petition for Review of an Order of the
ILLINOIS, INC., a Delaware
) Illinois Pollution Control Board,
corporation,
) PCB 03-125, 03.133, 03-134 & 0~3-i35
)
Petitioner,
)
)
v.
)
ILLINOIS POLLUTION CONTROL
)
BOARD, COUNTYOFKANKAKEE,
)
COUNTY BOARD OF KANKAKEE,
)
CITY OF EANKAKEE, MERLIN
)
KARLOCK, KEITH RUNYON, and
)
MICHAEL WATSON,
)
)
Respondents.
RESPONSE IN OPPOSITION OF
THE ILLINOIS POLLUTION CONTROL BOARD
TO THE MOTION FOR STAY OF APPEAL AND
INSTANTER
REMAND
FOR PRESENTATION QF
NEWLY DISCOVERED EVIDENCE TO THE BOARD
Respondent, ILLINOIS POLLUTION CONTROL
BOARD,
through its
attorney, LISA MADIGAN, Attorney General of Illinois, responds in opposition to
Petitioner’s “Motion for Stay ofAppeal and
Instanter
Remand” and states the
following:
1. In its August 7, 2003 frnaI decision, the Board vacated the Kankakee
County Board’s January 31, 2003 decision granting Waste Management of flhinois,
Inc.’s application for expansion of its existing pollution control facility. The
—1—
Petitioner filed a petition for review, seeking this Court’s review of that
determination.
2. Petitioner has now filed a motion to stay its appeal, requesting that the
Court remand the matter to the Board. It has contemporaneously filed a motion
with the Board asking the Board to grant relief from the Board’s judgment that the
County Board of Kankakee lacked jurisdiction to review the siting application.
3. The Board lacks jurisdiction to rule on the motion currently pending
before it; “It is fundamental that the proper filing of a notice of appeal causes the
jurisdiction of the appellate court to attach
instanter
and deprives the trial court of
jurisdiction to modify its judgment or to rule on matters of substance which are the
subject of appeal.”
Cairv
~‘.
Sukkar,
167 Ill. App. 3d 941, 521 N.E.2d 1292, 1294
(4th
Dist. 1988) (citing
Montgomery Ward & Co. v. Wetzel,
98 Ill. App. 3d 243, 423
N.E.2d 1170 (1~Dist. 1981)). This Court is the proper venue to address the
substance of the motions.
4. Nevertheless, the Board respectfully submits that remand is
inappropriate for two distinct reasons.
5. First, the new evidence that the Petitioner submits warrants remand is
clearly hearsay, and the Petitioner has offered no applicable exceptions to the
hearsay rule that would warrant the Board’s consideration of that evidence.
6. Second, the new evidence is not relevant. The gist of petitioner’s motion is
that the new evidence indicates that Brenda Keller was aware ofa posted notice of
Petitioner’s siting application, and that this would persuade the Board to change its
-2-
final decision in this matter. Petitioner misconstrues the rationale and findings in
the Board’s decision.
7. The Board found that, under Section 39.2 (b) of the Environmental
Protection Act (415 ILCS 5/3,9.2 (2002)), service on property owners specified in the
section “must be effectuated using certified mail return receipt or personal service.”
(H. CL vol. 10, pp. 001547-1564, 1561.) The Board further found that Mrs. Keller
was not served via certified mail and was not served persona.Uy. (slip op at 16.)
Consequently, the Board found that the statutory notice requirements were not
met.
8. The Board’s decision in this case specifically addressed the issue of
“posting” notice and found that such notice was inadequate under the statute.
Specifically, the Board ruled:
Waste Management argues that both “posting” notice and notice by
regular
mail
was sufficient notice of an impending landfill siting
application. However, the Act envisions two and only two types of
service: personal or certified mail return receipt requested. Therefore,
the attempts by Waste Management to serve property owners by
methods such as sending notice of an application by regular mail and
“posting” notice are not authorized by the plain language of Section
39.2(b) ofthe Act. 415 ILCS 5/39.2(b) (2002). Waste Management
cites one case (~recne)on the issue ofposting notice as a means of
service; however, the United States Supreme Court found in Greene
that posting a notice was insufficient even though the statute at issue
specifically allowed for posting. The Board has reviewed the case law
and can find no case where posting notice was adequate in place of
personal service except pursuant to specific statutory language. There
tire statutes which allow for notice to be posted,
See
65 ILOS 5/ 11-
19.2-4, 5/11-31.1-land 735 ILCS 5/9-104 and 5/9-107 (2002). However,
the plain language of Section 39.2(b) of the Act (415 ILCS 5/39.2(b)
(2002)) does not allow for posting ofnotice. Therefbre, the Board finds
that “posting” notice is not sufficient to meet the notice requirements
-3-
of Section 39~2(b)of the Act (415 ILCS 5/39.2(b) (2002)), and notice by
regular mail is insufficient based on the plain language of Section
39.2(b)
of the Act. 415 ILCS 5/39.2(b) (2002). (R. CL vol. 10, pp.
001547-1564, 1562.)
9. Therefore, even ifthe “newly discovered evidence” was true and
admissible, the evidence would not alter the Board’s decision in the underlying case.
10. Following its discussion ofthe adequacy of “posting notice”, the Board
addressed arguments based on dicta in one ofits prior cases concerning whether
notice requirements could be met through “constructive notice”. The Board
distinguished this case from its prior cases, all ofwhich involved the mailing of
notice. (R. CL vol. 10, pp. 001547.1564, 1563.) Here, the Board specifically found
that mailing a certified letter to Brenda Keller’s husband “was not sufficient to find
constructive notice” on Brenda. (R. CL vol. 10, pp. 001547-1564, 1564.) Given the
Board’s finding that statutory notice requirements to a landowner could be met only
through personal service or service by certified mail, return receipt requested, the
Board’s discussion of its prior “constructive notice” cases and dicta is mere
surplusage. Constructive notice is not contained within the plain wording of
Section 39,2.
11. The issue ofwhat Section 39.2 of the Act requires is squarely before this
Court. The issues have been fully briefed by both Petitioner (see Briefof Petitioner
pages 18.19) and the Board (See Brief of Respondent pages 29-30). Therefore,
granting Petitioner’s motion would unnecessarily delay the ultimate resolution of
this proceeding.
-4-
12. For these reasons, the Board respectfully requests that this Court deny
petitioner’s motion for stay and remand of this cause to the Board, Instead, in the
interests of both judicial and administrative economy, the Board urges this Court to
schedule oral argument and proceed to rendering its decision in this appeal.
Respectfully submitted,
LISA MADIGAN
Attorney General
State of Illinois
BY:_________
~JERALD S. POST for
~“KAREN
J.
DIMOND
Assistant Attorney General
100 West Randolph Street
1 2th Floor
Chicago, Illinois 60601
(312) 814-2274
STATE OF ILLINOIS
)
COUNTY OF C 0 0 K
SS.
PROOF
OF
SERVICE
The undersigned, being first duly sworn upon oath, deposes and states that a
copy of the foregoing Response in Opposition of the Illinois Pollution Control Board
to the Petitioners’ Motion for Stay of Appeal and Instanter Remand for Presentation
of Newly Discovered Evidence was served upon each ofthe below-named parties on
August .3, 2004, by depositing such copies in the United States mail at 100 West
Randolph Street, Chicago, illinois, 60601 in envelopes bearing sufficient postage.
Donald Moran
Pedersen & Houpt
161. North Clark Street, Suite 3100
Chicago, IL 60601
Edward Smith
Kankakee County State’s Attorney
Kankakee County Administration Bldg.
189 East Court Street
Kankakee, IL 60901
Charles F. Heisten
Hinshaw & Culbertson
100 Park Avenue
P.O. Box
1389
Rockford., IL 6 1105-1389
Keith Runyon
1165 Plum Creek Drive, Unit 0
Boui’bonnais, IL 60914
Kenneth A. Leshen
One Dearborn Square, Suite 550
Kankakee. IL 60901
L.
Patrick Power, Esq.
956 North Fifth Avenue
Kankakee, IL 60901
SUBSQ~JBEDand ~TORN to before me
this 1~day ofAu~u~t,2
F
Ø1’AI.
SEAL
~ ThQMASINA JEFFERS
~flQ7A~Y
FU8UC, STATE
OF IWNOIS
MISSION EXP ES
6.7~2oO1
George Mueller
Attorney at Law
501 State Street
Ottawa, IL 61350
Jennifer J. Sackett Pohlenz
Querrey & Harrow, Ltd.
175 West Jackson Street, Suite 1600
Chicago, IL 60604
Elizabeth S. Harvey
Swanson, Martin & Bell
One IBM Plaza, Suite 2900
330 North Wabash Street
Chicago, IL 60611
Leland Milk
6903 South Route 45-52
Chebanse, IL 60922
Patricia O’Dell
1242 Arrowhead Drive
Bourbonnais, IL 60914
TOTAL P.a7
