RECEIVED
CLERK'S
OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
AUG 2 3 2006
STATE OF ILLINOIS
PEORIA DISPOSAL COMPANY,
)
Petitioner,
)
PCB 06-184
v .
)
(Pollution Control Facility Siting Appeal)
PEORIA COUNTY BOARD,
)
Respondent.
)
NOTICE TO APPEAR FOR DISCOVERY DEPOSITION
TO : RUSSELL HAUPERT, County IT Services
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 25, 2006, at 9 :00 a.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
Pollutlon Control Board
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431 .1500-Telephone
(815) 431-1501 - Facsimile
george(&.muelleranderson.com
I
to e
.
11
BRIAN J . MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637.6000-Telephone
(309) 637-8514 - Facsimile
bmeginnes(alemrslaw.com
RECEIVED
CLERK'S OFFICE
AILIG 2 3 2006
Pollution
STATE OFControl
ILLINOIS
Board
1 .
All documents in the possession or control of RUSSELL HAUPERT
("Deponent") that set forth or pertain to the process or procedure by which documents
are posted on the website maintained by Peoria County (
http ://www.co.peoria
.il .u s) .
2 .
All documents in the possession or control of Deponent that set forth or
pertain to the process or procedure by which documents were and are posted on the
website maintained by Peoria County ( http://www
.co.peoria .il.u s)
pertaining to the
Application filed by Peoria Disposal Company
.
3.
All documents in the possession or control of Deponent that set forth or
pertain to the creation or dedication of a section of the website maintained by Peoria
County (http://www.co
.peoria .il .us)
dedicated to matters concerning the Application filed
by Peoria Disposal Company .
4.
All email and other correspondence in the possession or control of
Deponent between Deponent and Karen Raithel concerning Peoria Disposal Company
.
5 .
All email and other correspondence in the possession or control of
Deponent between Deponent and Karen Raithel concerning the Application filed by
Peoria Disposal Company, or the section of the website maintained by Peoria County
( http://www.co .peoria .il
.u s) dedicated thereto .
6 .
All email and other correspondence in the possession or control of
Deponent between Deponent and Megan Fulara concerning Peoria Disposal Company
.
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431 .1500- Telephone
(815) 431-1501 - Facsimile
george(a7muelleranderson .com
RIDER A
2
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637.6000-Telephone
(309) 637-8514 - Facsimile
bmeginnesc emrslaw .co m
7 .
All email and other correspondence in the
possession or control of
Deponent between Deponent and Megan Fulara concerning the Application filed by
Peoria Disposal Company, or the section of the website maintained by Peoria County
(http ://www .co .peoria .il.u s ) dedicated thereto .
8.
All email and other correspondence in the possession or control of
Deponent between Deponent and Patrick Urich concerning Peoria Disposal Company
.
9.
All email and other correspondence in the possession or control of
Deponent between Deponent and Patrick Urich concerning the Application filed by
Peoria Disposal Company, or the section of the website maintained by Peoria County
(http ://www .co .peoria .il.u s
) dedicated thereto .
10 . All email and other correspondence in the possession or control of
Deponent between Deponent and any agent, representative or employee of Peoria
County concerning Peoria Disposal Company
.
11 .
All email and other correspondence in the possession or control of
Deponent between Deponent and any agent, representative or employee of Peoria
County concerning the Application filed by Peoria Disposal Company, or the section of
the website maintained by Peoria County (
http://www .co .peoria .il .us) dedicated thereto .
12 .
All email and other correspondence in the possession or control of
Deponent between Deponent and any person concerning Peoria Disposal Company
.
13 .
All email and other correspondence in the possession or control of
Deponent between Deponent and any person concerning the Application filed by Peoria
GEORGE MUELLER
628 Columbus
Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500- Telephone
(815) 431.1501-Facsimile
george(d muelleranderson .co m
3
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000 -Telephone
(309) 637.8514-Facsimile
bmeginnes(a emrslaw.co m
Disposal Company, or the section of the
website maintained by Peoria County
( http ://www .co .peoria .il .us) dedicated thereto .
14 .
All documents in the possession or control of 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 .
15 .
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 .
16 .
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.
17 .
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.
18.
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 .
19.
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
george(a).mueileranderson .com
4
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637.6000-Telephone
(309) 637-8514-Facsimile
bmeginnes(de
mrsiaw. com
20 .
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 .
21 .
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 .
22 . 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 .
23 .
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 .
24 .
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 .
25 .
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
georgeCo)muelleranderson .co m
5
BRIAN J.
MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000-Telephone
(309) 637.8514-Facsimile
bmeginnes(g .emrslaw .co
m
26 . 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 .
27
. 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
.
28 . 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.
29 .
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.
30 .
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
.
31 .
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
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 .co m
bmeginnes(a).emrslaw .com
the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section
107
.300.
32 .
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.
33 .
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.
34 . 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.
35 .
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 .
36 .
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.
37 .
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 .
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500-Telephone
(815) 431-1501 - Facsimile
george a(a).muelleranderson .com
7
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000 - Telephone
(309) 637-8514-Facsimile
bmeginnes(i emrslaw.co m
38 . 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 .
39 . 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 .
40. 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.
41 . 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 .
42 . 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 .
43 .
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 .
906-1117
8
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(aDmuelleranderson.com
bmeginnes(olemrslaw.com
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 21st day of August, 2006, before 5
:00 p .m., with all fees thereon fully
prepaid .
Illinois Pollution Control Board
100 W
. Randolph, Suite 11-500
Chicago, Illinois 60601
(312) 814-3620 - Telephone
(312) 814-3669 - Facsimile
[ORIGINAL plus FOUR(4)]
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 21st 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(o) blackblackbrown
.co m
Subscribed and sworn to before me
this 21st day of August, 2006
.
J\J,
A
C
nk '-/
otary Public
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431
.1500-Telephone
(815) 431
.1501-Facsimile
george(a)m uelleranderson .co m
Jct
OFFI(K$EAL
NOTARY
WYCOAMiI$Ipp-M
O
:Sty,
Ms. Carol Webb, Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
P.O . Box 19274
Springfield, Illinois 62794-9274
(217) 524-8503 - Telephone
webbc(aipcb .state .il.u s
Mr. Kevin Lyons
Peoria County State's Attorney
324 Main Street, Room #111
Peoria, Illinois 61602
(309) 672-6029 -
Facsimile
eginnes
(print name)
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000 - Telephone
(309) 637 .8514-Facsimile
bmeginnes(dDemrslaw.co m
RECEIVEDCLERK'S
OFFICE
AUG 2 3 2006
STATE OF 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: KAREN RAITHEL, County Solid Waste Manager
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 25, 2006, at 10
:00 a.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
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
GEORGE
Ottawa,
628 Columbus
Illinois
MUELLERStreet,
61350Suite
#204
(815)
george(dmuelleranderson(815)
431-1501
431-1500-Telephone-
Facsimile.cam
1
BRIAN J. MEGINNES
416
Peoria,
Main
Illinois
Street,
61602-1611Suite
#1400
bmeginnes((309)
(309) 637-8514-Facsimile637-6000-Telephonedemrslaw
.co m
RecEE IIVED
CLERK'S OFFICE
AUG
2
1 . All documents in the possession or control of KAREN
Pollution
STATE
RAITHEL
OF
Control
ILLINOIS
Board
("Deponent") that set forth or pertain to the process or procedure by which documents
are posted on the website maintained by Peoria County ( h ttp ://www.co.peoria .il.u s) .
2 . All documents in the possession or control of Deponent that set forth or
pertain to the process or procedure by which documents were and are posted on the
website maintained by Peoria County ( http ://www.co .peoria .il .u s) pertaining to the
Application filed by Peoria Disposal Company .
3 .
All documents in the possession or control of Deponent that set forth or
pertain to the creation or dedication of a section of the website maintained by Peoria
County (http://www.co .peoria, i l .u s) dedicated to matters concerning the Application filed
by Peoria Disposal Company
.
4 .
All email and other correspondence in the possession or control of
Deponent between Deponent and Russell Haupert concerning Peoria Disposal
Company .
5. All email and other correspondence in the possession or control of
Deponent between Deponent and Russell Haupert concerning the Application filed by
Peoria Disposal Company, or the section of the website maintained by Peoria County
(h ttp ://www.co.peoria .il.u s) dedicated thereto .
6.
All email and other correspondence in the possession or control of
Deponent between Deponent and Megan Fulara concerning Peoria Disposal Company .
RIDER A
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500-Telephone
(815) 431-1501 - Facsimile
george(, m uelleranderson.co
m
2
BRIAN J
. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000 - Telephone
(309) 637-6514-Facsimile
bmeginnes(a),emrstaw .co m
7 . All
email and other correspondence in the possession or control of
Deponent between Deponent and Megan Fulara concerning the Application filed by
Peoria Disposal Company, or the section of the website maintained by Peoria County
(http://www.co .peoria .il .u s) dedicated thereto .
8 .
All email and other correspondence in the possession or control of
Deponent between Deponent and Patrick Urich concerning Peoria Disposal Company .
9. All email and other correspondence in the possession or control of
Deponent between Deponent and Patrick Urich concerning the Application filed by
Peoria Disposal Company, or the section of the website maintained by Peoria County
(h ttp ://www.co .peoria .il .us) dedicated thereto .
10 . All email and other correspondence in the possession or control of
Deponent between Deponent and any agent, representative or employee of Peoria
County concerning Peoria Disposal Company .
11
.
All email and other correspondence in the possession or control of
Deponent between Deponent and any agent, representative or employee of Peoria
County concerning the Application filed by Peoria Disposal Company, or the section of
the website maintained by Peoria County ( http ://www.co.peoria .il.us) dedicated thereto .
12 .
All email and other correspondence in the possession or control of
Deponent between Deponent and any person concerning Peoria Disposal Company .
13 .
All email and other correspondence in the possession or control of
Deponent between Deponent and any person concerning the Application filed by Peoria
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500- Telephone
(815) 431-1501 - Facsimile
george(am uelleranderson.co m
3
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637.6000-Telephone
(309) 637-8514-Facsimile
bmeginnes(a),emrslaw.co m
Disposal Company, or the section of the website maintained
by Peoria County
(http ://www .co .peoria .il.u s)
dedicated thereto .
14.
All documents in the possession or control of 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.
15.
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
.
16.
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.
17. 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 .
18 .
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 .
19.
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 .
4
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(q?m uelleranderson .com
bmeginnes(a emrslaw.co m
20 .
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.
21 .
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 .
22 .
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 .
23 . 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
.
24 .
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 .
25 .
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
george(OJmuelleranderson.com
5
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000-Telephone
(309) 637-8514 -Facsimile
bmeginnes(Nemrslaw.com
26 .
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
.
27.
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
.
28 .
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.
29 .
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.
30.
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 .
31
.
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(a?m uelleranderson .co m
6
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000-Telephone
(309) 637.8514-Facsimile
bmeginnes(demrslaw
.com
the Pollution Control Board pursuant to Illinois Administrative Code Title 35, Section
107 .300.
32
.
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 .
33.
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 .
34 .
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.
35 .
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
.
36 .
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.
37
.
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 .
7
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)muelleranderson .com
bmeginnes(? emrslaw.co m
38 .
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.
39 .
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 .
40 .
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.
41 . 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 .
42 . 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 .
43. 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.
906-1118
8
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500-Telephone
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61802.1611
(309) 637-6000-Telephone
(815) 431-1501
- Facsimile
(309) 637.8514-Facsimile
george(a) m uelleranderson .com
bmeginnes(d?emrslaw .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 21st 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 21st 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.blackblackbrown .com
Subscribed and sworn to before me
this 21st day of August, 2006 .
Public
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431.1500-Telephone
(815) 431.1501-Facsimile
george(dm uelleranderson .co m
Mr . Kevin Lyons
Peoria County State's Attorney
324 Main Street, Room #111
Peoria, Illinois 61602
(309) 672-6029 - Facsimile
BRIAN J. MEGINNES
6 Main Street, Suite #1400
oria, Illinois 61602-1611
09) 637-6000 - Telephone
9) 637.8514-Facsimile
innes
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
webbc(a-, ipcb .state . il.us
