1. NOTICE OF FILING
      2. CERTIFICATE OF SERVICE
BEFORE THE
ILLINOIS POLLUTION CONTROL BOARD
RECEIVED
CLERK’S OFFICE
PEOPLE OF THE STATE OF ILLINOIS,
)
JUN 02
2005
Complainant,
)
STATE OF ILLINOIS
)
Pollution
Control Board
v.
)
PCB NO.
00-1 04
)
(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.
)
NOTICE OF FILING
To:
Mr.
Jeffrey W. Tock
Mr.
Charles M.
Gering,
Esq.
Harrington, Tack
&
Royse
McDermott, Will
&
Emery
201
W. Springfield Avenue
227 West Monroe Street
Suite 601
Chicago, !L 60606-5096
Champaign, IL 61824-1 550
PLEASE
TAKE
NOTICE that
on
May
27,
2005,
I
mailed
for filing with
the
Clerk of the
Pollution
Control
Board
of the State
of
Illinois,
PROPOSED
REVISED AGREED
DISCOVERY
SCHEDULE FOR COMPLAINANTAND RESPONDENT HIGHLANDS and PROPOSED AGREED
DISCOVERY SCHEDULE
FOR COMPLAINANT AND
RESPONDENT MURPHY FARMS,
INC.,
a
copy of each
is attached hereto and
herewith served
upon you.
Respecifully 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:
~
JANE
E.
McBRIDE
Assistant Attorney General
Environmental Bureau
500
South
Second Street
Springfield,
Illinois 62706
217/782-9031
Dated:
May 27, 2005
CERTIFICATE OF SERVICE
I
hereby certify that
I did
on
May 27, 2005,
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,
PROPOSED
REVISED AGREED
DISCOVERY SCHEDULE
FOR COMPLAINANT AND
RESPONDENT HIGHLANDS
and
PROPOSED AGREED DISCOVERY SCHEDULE
FOR COMPLAINANT AND
RESPONDENT
MURPHY FARMS,
INC.
To:
Mr. Jeffrey W. Tock
Mr. Charles
M.
Gering,
Esq.
Harrington, Tock
&
Royse
McDermott,
Will & Emery
201
W. Springfield Avenue,
Ste. 601
227 West
Monroe Street
P.O.
Box 1550
Chicago,
IL 60606-5096
Champaign,
IL 61824-1 550
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
A copy was also sent by sending through facsimile
at 312-814-3669 and by
First Class
Mail with
postage thereon fully prepaid
To:
Mr.
Brad Halloran,
Hearing Officer
Illinois
Pollution Control
Board
State of Illinois
Center, Ste.
11-500
100 West Randolph
Chicago,
IL 60601
—
~
~
~J~neE.
McBride
Assistant Attorney General
This filing is submitted on recycled paper.
RECEIVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CLERK’S OFFICE
JUN
022005
PEOPLE OF THE STATE
OF ILLINOIS
)
STATE OF ILLINOIS
)
Pollution Control Board
Complainant,
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 NorthCarolina limited
)
liability corporation,
and SMITHFIELD
)
FOODS,
INC., a Virginia corporation).
)
Respondents.
)
PROPOSED
REVISED 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
July 15, 2005
Depositions
completed by all parties
November 15,
2005
All written discovery filed
and served
December
15, 2005
1
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:
~
)~IEE.
MCBRIDE
/~Assistant
Attorney General
500
South
Second Street
Springfield,
Illinois
62706
(217) 782-9031
Dated:
May 27, 2005
2
BEFORE THE ILLINOIS POLLUTION CONTROL BOARDR E C E
IV
ED
CLERK’S OFFICE
PEOPLE OF THE STATE OF ILLINOIS
)
JUN
02
2005
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 MURPHY FARMS, INC.
NOW
COMES the Complainant, PEOPLE
OF THE
STATE OF ILLINOIS,
and
with the
agreement and approval
of the Respondent MURPHY FARMS,
INC.,
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
July
15,
2005
Complainant shall disclose opinion witnesses
and
opinions
July
15, 2005
Respondent Highlands
shall disclose
opinion witnesses
and opinions
August
15,
2005
Depositions
completed
by all parties
November 15,
2005
1
All written discovery filed
and served
December 15, 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:
~.
~
,/IANE
E.
MCBRIDE
Assistant Attorney General
500 South
Second Street
Springfield,
Illinois
62706
(217) 782-9031
Dated: May 27, 2005
2

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