RECEIVED
CLERK’S OFFICE
OCT 032005
STATE OF ILLINOIS
Pollution Control Board
OFFICE OF THE AFFORNEY GENERAL
STATE OF ILLINOIS
Lisa Madigan
AFII)RNEY GENERAL
September 29, 2005
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 at
PCB No. 00-1 04
Dear Clerk Gunn:
Enclosed for filing please find the original and five copies of a NOTICE OF SERVICE OF
DISCOVERY DOCUMENTS 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,
22_~
cr~
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 • TTY: (217) 785-2771 • Fax: (217) 782-7046
100 West Randolph Street, Chicago, Illinois 60601 • (312) 814-3000 • ‘flY: (312) 814-3374 • Fax: (312) 814-3806
1001 East Main, Carhondale, Illinois 62901 • (618) 529-6400 • TTY: (618) 529-6403 • Fax: (618) 529-6416
RECEIVED
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
CLERK’S OFFICE
PEOPLE OF THE STATE OF ILLINOIS,
)
STATE
OCT
OF
032005
ILLINOIS
Complainant,
)
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 SERVICE OF DISCOVERY DOCUMENTS
To:
Dorothy M. Gunn
Brad Halloran
Clerk of the Board
Hearing Officer
Illinois Pollution Control Board
Illinois Pollution Control Board
State of Illinois Center, Suite 5-11
State of Illinois Center, Suite 5-11
100 West Randolph Street
100 West Randolph Street
Chicago, IL 60601
Chicago, IL 60601
PLEASE TAKE NOTICE that I have today served on the Respondent, MURHPY FARMS,
INC., do Charles M. Gering, McDermott, Will & Emery, 227 West Monroe Street, Chicago, IL 60606-
5096, the following discovery documents in the above-referenced matter.
1.
COMPLAINANT’S FIRST SUPPLEMENTAL RESPONSE TO RESPONDENT
MURPHY FARMS, INC.’S FIRST REQUEST FOR PRODUCTION.
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:
~
~
~—JANE E. McBRIDE
Assistant Attorney General
Environmental Bureau
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: September 29, 2005
CERTIFICATE OF SERVICE
I hereby certify that I did on September 29, 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 SERVICE OF DISCOVERY DOCUMENTS and
COMPLAINANT’S FIRST SUPPLEMENTAL RESPONSE TO RESPONDENT MURPHY FARMS,
INC.’S FIRST REQUEST FOR PRODUCTION
To:
Charles M. Gering
McDermott, Will & Emery
227 West Monroe Street
Chicago, IL 60606-5096
and the original and five copies of the NOTICE OF SERVICE OF DISCOVERY DOCUMENTS was
sent by First Class Mail with postage thereon fully prepaid
To:
Dorothy Gunn, Clerk
Illinois Pollution Control Board
State of Illinois Center
Suite 11-500
100 West Randolph
Chicago, IL 60601
A copy of the NOTICE was also sent 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
Mr. Jeffrey W. Tock
Harrington, Took & Royse
201 W. Springfield Avenue
Suite 601
Champaign, IL 61 824-1550
y _;vI,-.(
~.Ai1ceE. McBride
r Assistant Attorney General
This filing is submitted on recycled paper.
