1. THIS FILING SUBMITTED ON RECYCLED PAPER
  1. NOTICE OF FILING
  2. (PERSONS ON ATTACHED SERVICE LIST)
  3. CERTIFICATE OF SERVICE
  4. MOTION FOR ENTRY OF DISCOVERY SCHEDULE
  5. DISCOVERY SCHEDULE
  6. DATES TASK
THIS FILING SUBMITTED ON RECYCLED PAPER
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ROBERT F. KASSELA JR. and
)
KELLIE R. KASSELA,
)
)
Complainant,
)
)
v.
)
PCB No. 06-001
)
(Enforcement – Noise)
TNT LOGISTICS NORTH AMERICA
)
INC.,
)
)
Respondent.
)

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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)

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(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 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 20, 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 20, 2005

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CERTIFICATE OF SERVICE
I, Thomas G. Safley, the undersigned, hereby certify that I have served the
attached MOTION FOR ENTRY OF 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 20, 2005; and upon:
Bradley P. Halloran, Esq.
Hearing Officer
Illinois Pollution Control Board
100 West Randolph Street
Suite 11-500
Chicago, Illinois 60601
Timothy M. Nolan, Esq.
Mary Ann Sullivan, Esq.
53 West Jackson Boulevard
Suite 1137
Chicago, Illinois 60604-3702
by depositing said documents in the United States Mail, postage prepaid, in Springfield,
Illinois on December 20, 2005.
/s/Thomas G. Safley
Thomas G. Safley
TNTL:002/Fil/NOF-COS – Motion and Joint Discovery Schedule - Kassela
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 20, 2005
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ROBERT F. KASSELA JR. and
)
KELLIE R. KASSELA,
)
)
Complainant,
)
)
v.
)
PCB No. 06-001
)
(Enforcement – Noise)
TNT LOGISTICS NORTH AMERICA
)
INC.,
)
)
Respondent.
)

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MOTION FOR ENTRY OF DISCOVERY SCHEDULE
NOW COMES Respondent, TNT LOGISTICS NORTH AMERICA INC., by its
attorneys, HODGE DWYER ZEMAN, and files the parties’ joint proposed Discovery
Schedule, and in support of this filing, states as follows:
1.
On December 1, 2005, the parties participated in a status conference,
during which the parties agreed to develop and file a joint proposed Discovery Schedule
for the Hearing Officer’s consideration.
2.
Counsel for Respondent prepared a draft joint proposed Discovery
Schedule for Complainants’ approval. Counsel for Complainants agreed to the draft, and
a copy of the agreed-upon joint proposed Discovery Schedule is filed herewith.
3.
Complainants, Robert F. Kassela Jr. and Kellie R. Kassela, through their
counsel, have authorized the undersigned to file the parties’ joint proposed Discovery
Schedule for the Hearing Officer’s consideration on behalf of both parties.
4.
The parties acknowledge that this discovery schedule may need to be
revised at a later date in light of Complainants’ Motion for Leave to Amend their
Complaint.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 20, 2005
2
WHEREFORE, Respondent, TNT LOGISTICS NORTH AMERICA INC.,
respectfully prays that the Hearing Officer enter the joint proposed Discovery Schedule
filed herewith.
Respectfully submitted,
TNT LOGISTICS NORTH AMERICA INC.,
Respondent,
By: /s/Thomas G. Safley
One of Its Attorneys
Dated: December 20, 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/Motion for Entry of Discovery Schedule - Kassela
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 20, 2005
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
ROBERT F. KASSELA JR. and
)
KELLIE R. KASSELA,
)
)
Complainant,
)
)
v.
)
PCB No. 06-001
)
(Enforcement – Noise)
TNT LOGISTICS NORTH AMERICA
)
INC.,
)
)
Respondent.
)

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DISCOVERY SCHEDULE
This cause comes before the Hearing Officer on submission by the parties of a
joint proposed Discovery Schedule. Having considered the foregoing, and being duly
advised, the Hearing Officer now finds that such Discovery Schedule should be
APPROVED, and accordingly, hereby enters the following Discovery Schedule in this
matter:

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DATES
TASK
April 1, 2006
All written discovery served and answered.
May 15, 2006
Complainants’ opinion witness(es) and their opinion(s)
disclosed.
July 1, 2006
Respondent’s opinion witness(es) and their opinion(s)
disclosed.
August 1, 2006
Depositions completed.
August 1, 2006
Close of all discovery.
Dated: ___________________
_________________________________
Hearing Officer
Distribution to:
All counsel of record
TNTL:002/Fil/Joint Discovery Schedule - Kassela
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, DECEMBER 20, 2005

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