RECEIVED
CLERK’S OFFICE
DEC 13 2004
STATE OF ILLINOIS
Pollution Control Board
OFFICE OF THE ATTORNEY GENERAL
STATE OF ILLINOIS
Lisa Madigan
A’ITORNEY GENERAL
December
9, 2004
The Honorable Dorothy Gunn
Illinois Pollution Control Board
State of Illinois Center
100 West Randolph
Chicago, Illinois 60601
Re:
People v. The Highlands, LLC.,
et
al.
PCB No. 00-1 04
Dear Clerk Gunn:
Enclosed for filing please find the original and ten copies of a NOTICE OF FILING and
PROPOSED AGREED DISCOVERY SCHEDULE FOR COMPLAINANT. AND RESPONDENT.
HIGHLANDS in regard to the above-captioned matter. Please file the original and return a file-
stamped copy of the document to our office in the enclosed self-addressed, stamped envelope.
Thank you for your cooperation and consideration.
Very truly yours,
~
Jane E. McBride
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
(217) 782-9031
JEM/pp
Enclosures
500 South
Second Street,
Springfield, Illinois 62706
•
(217) 782-1090
•
‘ITY: (217) 785-2771
•
Fax: (217) 782-7046
100
West
Randolph Street, Chicago, Illinois 60601
•
(312)
814-3000
• TTY~(312)
814-3374
•
Fax: (312) 814-3806
101)1 I
1,1
\l on C irbond ilL Illinois 62901
(616) ~29 640(1
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RECE~VED
CLERK’S OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD DEC 132004
PEOPLE OF THE STATE OF ILLINOIS,
.
)
STATE OF ILLINOIS
)
.
Pollution Control Board
Complainant,
v.
)
PCB NO. 00-1 04
)
(Enforcement)
THE HIGHLANDS, LLC, an Illinois limited
)
liability corporation, MURPHY FARMS, INC.,
)
a/k/a MURPHY FAMILY FARMS, a North
)
Caroline corporation, and BION
)
TECHNOLOGIES, INC., a Colorado Corp.,
)
Respondents.
NOTICE OF FILING
To:
Mr. Jeffery
W.
Tock
Mr. Charles
M. Gering, Esq.
Harrington, Tock & Royse
McDermott, Will & Emery
201 W. Springfield Ave.
227 West Monroe Street
P.O. Box 1550
Chicago, IL 60606-5096
Champaign, IL 61824-1500
PLEASE TAKE NOTICE that on this date I mailed for filing with the Clerk. of the Pollution
Control Board of the State of Illinois, PROPOSED AGREED DISCOVERY SCHEDULE FOR
COMPLAINANT AND RESPONDENT HIGHLANDS, a copy of which is attached hereto and
herewith served upon you.
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN
Attorney General of the
State of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/Asbestos
Litigation Division
BY:
~
C
~-~JANE E. McBRIDE
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: December 9, 2004
CERTIFICATE OF SERVICE
I hereby certify that I did on December 9, 2004, send by First Class Mail, with postage
thereon fully prepaid, by depositing in a United States Post Office Box a true and correct copy
of the following instruments entitled NOTICE OF FILING and PROPOSED AGREED
DISCOVERY SCHEDULE FOR COMPLAINANT AND RESPONDENT HIGHLANDS
To:
Mr. Jeffery W. Tock
Mr. Charles M. Gering, Esq.
Harrington, Tock & Royse
McDermott, Will & Emery
201 W. Springfield Ave.
227 West Monroe Street
P.O. Box 1550
.
Chicago, IL 60606-5096
Champaign, IL 61824-1500
and the original and ten copies by First Class Mail with postage thereon fully prepaid of the
same foregoing instrument(s):
To:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
State of Illinois Center
Suite .11-500
100 West Randolph
Chicago, Illinois 60601
(Also by Facsimile (312) 814-3669)
A copy was also sent by First Class Mail with postage thereon fully prepaid
To:
Mr. Brad Halloran, Hearing Officer
Illinois Pollution Control Board
Stateof Illinois Center,Ste. 11-500
100 West Randolph
Chicago, IL 60601
(Also by Facsimile (312) 814-3669)
~
,—IANE E. McBRIDE
Assistant Attorney General
Environmental Bureau
This filing is submitted on recycled paper
BEFORE THE ILLINOIS POLLUTION CONTROL BOA
DEC 132004
PEOPLE OF THE STATE OF ILLINOIS
)
) .
STATE OF ILLINOIS
Complainant,
‘
)
Pollution Control Board
V.
)
PCB No~00-104
)
(Enforcement)
THE HIGHLANDS, LLC, an Illinois limited
)
liability corporation, and MURPHY
)
FARMS, INC., (a division of MURPHY-
---~
)
BROWN, LLC, a North Carolina limited
)
liability corporation, and SMITHFIELD
FOODS, INC., a Virginia corporation).
)
Respondents.
PROPOSED AGREED DISCOVERY SCHEDULE FOR
COMPLAINANT AND RESPONDENT HIGHLANDS
NOW COMES the Complainant, PEOPLE OF THE STATE OF ILLINOIS, and with the
agreement and approval of the Respondent THE HIGHLANDS, LLC, hereby submits the
following proposed agreed discovery schedule for the continuing litigation between these two
parties:
All parties submit responses for
all outstanding written discovery
.
February.1.4, 2005
....
Complainant shall disclose opinion witnesses
and opinions
February 14, 2005
Respondent Highlands shall disclose
opinion witnesses and opinions
March 14, 2005
Depositions completed by all parties
June 14, 2005
1
All written discovery filed and served
July 14, 2005
Respectfully submitted,
PEOPLE OF THE STATE OF ILLINOIS
LISA MADIGAN,
Attorney General of the State of Illinois
MATTHEW J. DUNN, Chief
Environmental Enforcement/Asbestos
Litigation Division
BY:
r. ~-~
~
54~NEE. MCBRIDE
Assistant Attorney General
500 South Second Street .
Springfield, Illinois 62706
(217) 782-9031
Dated: August 26, 2004
r
2
