THIS FILING SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
KEN BLOUIN, )
)
Complainant, )
)
v. ) PCB No. 05-217
) (Enforcement – Noise)
TNT LOGISTICS NORTH AMERICA )
INC.,
)
)
Respondent. )
NOTICE OF FILING
TO: Ms. Dorothy M. Gunn Bradley P. Halloran, Esq.
Clerk of the Board Hearing Officer
Illinois Pollution Control Board
Illinois Pollution Control Board
100 West Randolph Street
100 West Randolph Street
Suite 11-500 Suite 11-500
Chicago, Illinois 60601
Chicago, Illinois 60601
(VIA ELECTRONIC MAIL)
(VIA FIRST CLASS MAIL)
(PERSONS ON ATTACHED SERVICE LIST)
PLEASE TAKE NOTICE that I have today filed with the Office of the Clerk of
the Illinois Pollution Control Board a
MOTION FOR ENTRY OF RESPONDENT’S
PROPOSED DISCOVERY SCHEDULE
and proposed
DISCOVERY SCHEDULE
,
copies of which are herewith served upon you.
Respectfully submitted,
TNT LOGISTICS NORTH AMERICA INC.,
Respondent,
By: /s/Thomas G. Safley
Dated: December 16, 2005 One of Its Attorneys
Edward W. Dwyer
Thomas G. Safley
HODGE DWYER ZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois 62705-5776
(217) 523-4900
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 16, 2005
CERTIFICATE OF SERVICE
I, Thomas G. Safley, the undersigned, hereby certify that I have served the
attached MOTION FOR ENTRY OF RESPONDENT’S PROPOSED DISCOVERY
SCHEDULE and proposed DISCOVERY SCHEDULE upon:
Ms. Dorothy M. Gunn
Clerk of the Board
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
via electronic mail on December 16, 2005; and upon:
Bradley P. Halloran, Esq.
Hearing Officer
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
Mr. Ken Blouin
6446 Lakeway Drive
Monee, Illinois 60449
by depositing said documents in the United States Mail, postage prepaid, in Springfield,
Illinois on December 16, 2005.
/s/Thomas G. Safley
Thomas G. Safley
TNTL:002/Fil/NOF-COS – Motion and Joint Discovery Schedule - Blouin
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 16, 2005
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
KEN BLOUIN, )
)
Complainant, )
)
v. ) PCB No. 05-217
) (Enforcement – Noise)
TNT LOGISTICS NORTH AMERICA )
INC.,
)
)
Respondent. )
MOTION FOR ENTRY OF
RESPONDENT’S PROPOSED DISCOVERY SCHEDULE
NOW COMES Respondent, TNT LOGISTICS NORTH AMERICA INC.
(“TNT”), by its attorneys, HODGE DWYER ZEMAN, and for its Motion for Entry of
Respondent’s Proposed Discovery Schedule, states as follows:
1. On December 1, 2005, the parties participated in a status conference,
during which the parties agreed to discuss the filing of a joint proposed Discovery
Schedule for the Hearing Officer’s consideration.
2. Counsel for Respondent prepared a draft joint proposed Discovery
Schedule for Complainant’s approval and transmitted the same to Complainant for
review. That proposed Discovery Schedule proposed the same deadlines as set forth in
TNT’s proposed Discovery Schedule filed herewith.
3. Complainant, Ken Blouin, has indicated to the undersigned that rather than
agree to the dates proposed in the enclosed Discovery Schedule, he intends to submit an
alternative proposed Discovery Schedule for the Hearing Officer’s consideration.
4. TNT hereby submits the enclosed Discovery Schedule as its proposal for
the Hearing Officer’s consideration.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 16, 2005
2
WHEREFORE, Respondent, TNT LOGISTICS NORTH AMERICA INC.,
respectfully prays that the Hearing Officer enter its proposed Discovery Schedule filed
herewith and provide it all other relief just and proper in the premises.
Respectfully submitted,
TNT LOGISTICS NORTH AMERICA INC.,
Respondent,
By: /s/Thomas G. Safley
One of Its Attorneys
Dated: December 16, 2005
Edward W. Dwyer
Thomas G. Safley
HODGE DWYER ZEMAN
3150 Roland Avenue
Post Office Box 5776
Springfield, Illinois 62705-5776
(217) 523-4900
TNTL:002/Fil/Blouin Motion for Entry of Discovery Schedule
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 16, 2005
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
KEN BLOUIN, )
)
Complainant, )
)
v. ) PCB No. 05-217
) (Enforcement – Noise)
TNT LOGISTICS NORTH AMERICA )
INC.,
)
)
Respondent. )
DISCOVERY SCHEDULE
This cause comes before the Hearing Officer on submission by the parties of
proposed Discovery Schedules. Having considered the foregoing, and being duly
advised, the Hearing Officer now finds that Respondent’s proposed Discovery Schedule
should be APPROVED, and accordingly, hereby enters the following Discovery
Schedule in this matter:
DATES
TASK
March 1, 2006 All written discovery served and answered.
April 15, 2006 Complainant’s opinion witness(es) and their opinion(s)
disclosed.
June 1, 2006 Respondent’s opinion witness(es) and their opinion(s)
disclosed.
July 1, 2006 Depositions completed.
July 1, 2006 Close of all discovery.
Dated: ___________________ _________________________________
Hearing Officer
Distribution to: Complainant; counsel for Respondent
TNTL:002/Fil/TNT Proposed Discovery Schedule - Blouin
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 16, 2005