BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
Complainant,
)
vs.
)
PCB No. 04-207
(Enforcement
-
Land)
EDWARD
PRUIM and ROBERT PRW
)
Respondents.
PEOPLE OF THE STATE OF
ELINOIS,
)
Complainant,
)
)
VS.
PCB NO. 97-193
(Enforcement
-
Land)
COmMTY
LAWFILL.
CO-Wr\_NY,
(mfisdidated)
INC.,
Respondent.
)
NOTICE OF FILING
TO: Christopher Grant
Environmental Bureau
Assistant Attorney General
188 West Randolph Street
20th Floor
Chicago, Illinois 60601
Bradley
Halloran
Hearing Officer
Illinois Pollution Control Board
100 West Randolph
Suite 11
-500
Chicago, Illinois 60601
PLEASE TAKE NOTICE
that on
JUNE 13, 2006,
the undersigned caused to be
electronically filed with Ms. Dorothy
Gunn, Clerk of the Illinois Pollution Control Board,
100 West Randolph Street, Suite 11-500, Chicago, Illinois 60601, the
Affidavit of
R
Michael
McDermont,
a copy of which is attached and hereby s
Mark A. LaRose
Clarissa C. Grayson
LAROSE
&
BOSCO, LTD.
Attorney No. 37346
200 North
LaSalle Street, Suite 28 10
Chicago, Illinois 606 10
(3 12)
642-44 14
THIS FILING IS SUBMITTED ON RECYCLED PAPER.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 13, 2006
ILLINOIS POLLUTION CONTROL BO
PEOPLE OF THE STATE OF ILLINOIS,
)
Complainant,
1
)
VS.
PCB No. 04-207
(Enforcement
-
Land)
EDWARD PRUIM and ROBERT PRUIM,
)
)
Respondents.
1
PEOPLE OF THE STATE OF ILLINOIS,
)
)
Complainant,
)
vs
.
)
PCB No.
97-193
)
(Enforcement
-
Land)
COMMUNITY LANDFILL COMPANY,
)
(consolidated)
INC.,
)
1
Respondent.
)
AFFIDAVIT OF R MICHAEL McDERMONT
I, R. Michael McDermont, being duly sworn on oath do hereby depose and state as follows:
1.
I am a licensed professional engineer employed by Stabilize, Inc., located in
Springfield, Illinois. I was formerly employed by
Andrews Environmental Engineering, Inc., also
located
in Springfield, Illinois. I have been an engineer for Morris Community Landfill for more
than
18 years. During that time, I have become very familiar with the condition of the site and any
impact that the site has had or may have on the environment.
2.
I am not available to testify in any proceedings during the latter half of September,
2006 or during most of the month of October,
2006.
3.
I am scheduled to be in Israel from September 17
-
27,2006. I have already paid a
deposit of $250.00 against a total cost of $2,552.00.
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 13, 2006
4.
The interim period between September 28 and October 6 will be used to satisfy
various business needs and work
assignments for my clients before embarking on another travel
obligation.
5.
I
am scheduled to be in Mexico on a mission trip for ministering to pastors and local
people from October 6
-1 8,2006. I have already been to Mexico in February 2006, in order to make
preparations for this mission trip
in October and have begun making other preparations to go. Partial
funding of this trip has all ready been secured as the funds are being allocated monthly towards a
total cost of approximately
$1,750.00.
6.
Upon returning
fiom the Mexico trip I will be getting married on October 21,2006
and will be on my honeymoon taking a cruise. The exact destination has not yet been determined
but will involve a cruise departing from Florida. I anticipate that the honeymoon trip will be at least
a week
in length, expending much of the balance of the remainder of the month of October.
The information contained
in this Affidavit is based on my personal knowledge.
If called to do so, I could competently testify to same and
Msh supporting documentation.
R. Michael ~c~ermont,-P.E.
SUBSCRIBED AND SWORN TO
before me this
t"..>.:..:..:..:..f.:.8.:-.:..:..?
.:.
I.'
nFFlCIAL
June, 2006.
::
NO
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 13, 2006
CERTIFICATE OF SERVICE
I, Clarissa C.
Grayson, an attorney hereby certifl that I caused to be served a copy of the
foregoing
Affidavit of
R.
Michael McDermont
by pIacing same in first-class postage prepaid
envelopes and depositin same in the U.S. Mail Box located at 200 North LaSalle Street,
ti?
Chicago, Illinois, this
13
day of
June
2006, addressed as follows:
Christopher Grant
Bradley
Halloran
Environmental Bureau
Hearing Officer
Assistant Attorney General
Illinois Pollution Control Board
188 West Randolph Street
100 West Randolph
20th Floor
Suite 11-500
Chicago, Illinois 60601
Chicago, Illinois 60601
ne of the Attorneys for Responde
Mark
A. LaRose
Clarissa C. Grayson
LAROSE
&
BOSCO, LTD
Attorney No. 3 7346
200 North LaSalle Street
Suite
28 10
Chicago, Illinois 60610
(3 12)
642-441 4
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JUNE 13, 2006
