BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEORIA DISPOSAL COMPANY,
)
Petitioner,
)
PCB 06-184
v.
)
(Pollution Control Facility Siting Appeal)
PEORIA COUNTY BOARD,
)
Respondent
.
)
NOTICE TO APPEAR FOR DISCOVERY DEPOSITION
TO : MEGAN FULARA, Deputy Peoria County Clerk
c/o Mr
. David A
. Brown
Black, Black & Brown
101 South Main Street
P .O. Box 381
Morton, Illinois 61550
You are hereby notified that you are required to appear and testify at a discovery
deposition, on Friday, August 18, 2006, at 2
:00 p .m., at the law offices of Elias,
Meginnes, Riffle & Seghetti, P.C .,
416 Main Street, Suite 1400, Peoria, IL 61602, and
you are hereby further notified that you are required to produce at the deposition, all of
the documents or tangible things identified in Rider A, attached hereto
.
Respectfully submitted,
Peoria Disposal Company, Petitioner
GEORGE MUELLER
828 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500- Telephone
(815) 431-1501 - Facsimile
george(dm uelleranderson .com
1
REC EIVIE
D
AUG 1
4
2006
Pollution
STATE OF
Control
ILLINOIS
Board
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000-Telephone
(309) 637.8514-Facsimile
bmeoinnes(a?emrslaw .com
RECEIVEDCLERK'S
OFFICE
AUG 1 4 2006
RIDER A
Pollution
STATE OF
Control
ILLINOIS
Board
1 .
All documents in the possession or control of MEGAN FULARA
("Deponent") setting forth or pertaining to the process or procedure by which the Record
filed with the Pollution Control Board pursuant to Illinois Administrative Code Title 35,
Section 107 .300, was compiled .
2.
All documents in the possession or control of Deponent pertaining to the
process or procedure by which the Record was kept by the Peoria County Clerk .
3.
All documents in the possession or control of Deponent referring to the
Application that were not included in the Record filed with the Pollution Control Board
pursuant to Illinois Administrative Code Title 35, Section 107 .300.
4 . Any document in the possession or control of Deponent received or
created by any member of the Peoria County Board referring to the Application that was
not included in the Record filed with the Pollution Control Board pursuant to Illinois
Administrative Code Title 35, Section 107 .300 .
5 .
All documents in the possession or control of Deponent referring to Peoria
Disposal Company that were not included in the Record filed with the Pollution Control
Board pursuant to Illinois Administrative Code Title 35, Section 107 .300 .
6 .
All documents in the possession or control of Deponent received from any
member or representative of the Heart of Illinois Sierra Club that were not included in
the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code
Title 35, Section 107 .300.
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500- Telephone
(815) 431-1501 - Facsimile
peorpe(almuelleranderson.com
2
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000 - Telephone
(309) 637.8514-Facsimile
bmeginnes(ahemrslaw.com
7 .
All documents in the possession or control of Deponent received from any
member or representative of the organization Peoria Families Against Toxic Waste that
were not included in the Record filed with the Pollution Control Board pursuant to Illinois
Administrative Code Title 35, Section 107
.300.
8 .
All documents in the possession or control of Deponent received from any
member or representative of the organization Citizens for Our Environment that were
not included in the Record filed with the Pollution Control Board pursuant to Illinois
Administrative Code Title 35, Section 107 .300 .
9 .
All documents in the possession or control of Deponent received from any
member or representative of the organization River Rescue that were not included in
the Record filed with the Pollution Control Board pursuant to Illinois Administrative Code
Title 35, Section 107 .300 .
10.
All documents in the possession or control of Deponent portraying the
PDC 1 landfill or any property located within one (1) mile of the PDC 1 landfill that were
not included in the Record filed with the Pollution Control Board pursuant to Illinois
Administrative Code Title 35, Section 107 .300 .
11 .
All documents in the possession or control of Deponent, including, without
limitation, notes, drafts, memoranda, correspondence and transcripts, considered by the
Peoria County Board regarding the Application .
12
. All documents in the possession or control of Deponent, including, without
limitation, notes, drafts, memoranda, correspondence and transcripts, available to the
Peoria County Board in its consideration of the Application
.
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431.1500-Telephone
(815) 431-1501 -Facsimile
aeorge(cDmuelleranderson.com
3
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637.6000-Telephone
(309) 637-8514 - Facsimile
bmeginnes(giemrslaw.com
13. All documents in the possession or control of Deponent, including, without
limitation, notes, drafts, memoranda, correspondence and transcripts, considered by the
staff of the Peoria County Board regarding the Application
.
14 .
All documents in the possession or control of Deponent, including, without
limitation, notes, drafts, memoranda, correspondence and transcripts, available to the
staff of the Peoria County Board in their consideration of the Application
.
15 .
All documents in the possession or control of Deponent reflecting
membership of any member of the Peoria County Board in the Heart of Illinois Sierra
Club that were not included in the Record filed with the Pollution Control Board pursuant
to Illinois Administrative Code Title 35, Section 107 .300.
16 .
All documents in the possession or control of Deponent reflecting
membership of any member of the Peoria County Board in the Sierra Club that were not
included in the Record filed with the Pollution Control Board pursuant to Illinois
Administrative Code Title 35, Section 107
.300.
17 . All documents in the possession or control of Deponent reflecting
membership of any member of the Peoria County Board in the organization Peoria
Families Against Toxic Waste that were not included in the Record filed with the
Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section
107 .300.
18.
All documents in the possession or control of Deponent received from or
authored by Citizens for Our Environment that were not included in the Record filed with
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500- Telephone
(815) 431-1501 - Facsimile
george(Wmnuelleranderson .com
4
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-5000-Telephone
(309) 637-8514 - Facsimile
bmeginnes(&emrslaw.com
the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section
107 .300 .
19 . All documents in the possession or control of Deponent received from or
authored by River Rescue that were not included in the Record filed with the Pollution
Control Board pursuant to Illinois Administrative Code Title 35, Section 107.300
.
20 . All documents in the possession or control of Deponent received from or
authored by Tom Edwards that were not included in the Record filed with the Pollution
Control Board pursuant to Illinois Administrative Code Title 35, Section 107
.300.
21 .
All documents in the possession or control of Deponent received from or
authored by Kim Converse that were not included in the Record filed with the Pollution
Control Board pursuant to Illinois Administrative Code Title 35, Section 107.300
.
22 .
All documents in the possession or control of Deponent received from or
authored by Joyce Blumenshine that were not included in the Record filed with the
Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section
107 .300.
23
. All documents in the possession or control of Deponent received from or
authored by Diane Storey that were not included in the Record filed with the Pollution
Control Board pursuant to Illinois Administrative Code Title 35, Section 107
.300 .
24
. All documents in the possession or control of Deponent received from or
authored by Jean Roach that were not included in the Record filed with the Pollution
Control Board pursuant to Illinois Administrative Code Title 35, Section 107
.300 .
5
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500-Telephone
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000 - Telephone
(815) 431-1501 - Facsimile
(309) 637-8514 - Facsimile
georae(mmuelleranderson
.com
bmeainnes(a), emrslaw.co m
25.
All documents in the possession or control of Deponent received from or
authored by Amy Schlicksup that were not included in the Record filed with the Pollution
Control Board pursuant to Illinois Administrative Code Title 35, Section 107
.300 .
26 . All documents in the possession or control of Deponent received from or
authored by Cara Rosson that were not included in the Record filed with the Pollution
Control Board pursuant to Illinois Administrative Code Title 35, Section 107
.300 .
27 .
All documents in the possession or control of Deponent received from or
authored by Tessie Bucklar that were not included in the Record filed with the Pollution
Control Board pursuant to Illinois Administrative Code Title 35, Section 107.300
.
28 .
All documents in the possession or control of Deponent received from or
authored by Mayvis Young that were not included in the Record filed with the Pollution
Control Board pursuant to Illinois Administrative Code Title 35, Section 107
.300 .
29 .
All documents in the possession or control of Deponent received from or
authored by Lisa Offutt that were not included in the Record filed with the Pollution
Control Board pursuant to Illinois Administrative Code Title 35, Section 107
.300 .
30.
All documents in the possession or control of Deponent received from or
authored by Peter Offutt that were not included in the Record filed with the Pollution
Control Board pursuant to Illinois Administrative Code Title 35, Section 107
.300.
906-1068
6
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431.1500-Telephone
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637.6000-Telephone
(815) 431-1501 -Facsimile
(309) 637.8514-Facsimile
george(a) m uelleranderson .com
bmeginnes(ahemrslaw .co
m
STATE OF ILLINOIS
)
SS
COUNTY OF PEORIA )
AFFIDAVIT OF SERVICE & FILING
The undersigned being first duly sworn on oath, states that a copy of the
foregoing NOTICE TO APPEAR FOR DISCOVERY DEPOSITION was served upon the
following persons by enclosing copies of same in separate envelopes, addressed as set
forth below, and depositing said envelopes in a U
.S
. Postal Service mailbox in Peoria,
Illinois, on the 9th day of August, 2006, before 5
:00 p .m
., with all fees thereon fully
prepaid .
The undersigned further states that a copy of the foregoing NOTICE TO
APPEAR FOR DISCOVERY DEPOSITION was served upon the following persons
by
facsimile
and by enclosing copies of same in separate envelopes, addressed as set
forth below, and depositing said envelopes in a U
.S
. Postal Service mailbox in Peoria,
Illinois, on the 9th day of August, 2006, before 5
:00 p .m
., with all fees thereon fully
prepaid .
Mr. David A . Brown
Black, Black & Brown
101 South Main Street
P.O . Box 381
Morton, Illinois 61550
(309) 266-9680 -
Telephone
(309) 266-8301 - Facsimile
dbrown(a'Dblackblackbrown
.com
Subscribed and sworn to before me
this 8th day of August, 2006
.
-Ak
.!- . "I1:
L
GEORGE MUELLER
628 Columbus
Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500 - Telephone
(815) 431 .1501-Facsimile
aeorge(dmuelleranderson.com
OFFCKwA
JfBSICAMROCKEY
NOTARY PI*UC-SLATE OF 4uNOIS
MY OOIMIIl$ION EXPIRES
:
06.13-07
Mr. Kevin Lyons
Peoria County State's Attorney
324 Main Street, Room #111
Peoria, Illinois 61602
(309) 672-6029
- Facsimile
BRIAN J. MEGINNES
416 Main Street, Suite
#1400
Peoria, Illinois 61602-1611
(309) 637-6000 - Telephone
(309) 637-8514 - Facsimile
bmeginnes(a).emrslaw.com
Illinois Pollution Control Board
100 W
. Randolph, Suite 11-500
Chicago, Illinois 60601
Ms
. Carol Webb, Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
(312) 814-3620
- Telephone
P .O. Box 19274
(312) 814-3669 - Facsimile
Springfield, Illinois 62794-9274
[ORIGINAL Plus FOUR
(4)]
(217) 524-8503
- Telephone
webbcnipcba
.state.il .us
