PEORIA DISPOSAL COMPANY,
Petitioner,
V .
PEORIA COUNTY BOARD,
Respondent
.
STATE OF ILLINOIS
COUNTY OF PEORIA
Illinois Pollution Control Board
100 W . Randolph, Suite 11-500
Chicago, Illinois 60601
via U.S. Mail from Peoria, IL
[FIVE (5) Copies]
Mr. David A . Brown
Black, Black & Brown
101 South Main Street
P.O. Box 381
Morton, Illinois 61550
via U.S. Mail from Peoria, IL
Subscribed and sworn to before me
this 12th day of October, 2006
.
S
Notary Public
906-1357
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431 .1500-Telephone
(815) 431 .1501-Facsimile
aeome(dm uelleranderson
.com
BEFORE
THE ILLINOIS POLLUTION CONTROL BOARDCTE
K
:S i)ppl'g~
OCT
I
t 2023
SS
CERTIFICATE OF SERVICE
.
OFFICIAL SEAL
"OP"
INUC-STATEOFtuIN013
1MROOMY
W OMMIU10M E%FM:68.134
7
Pollulin'STATE
•'
OFonrrol
ILLIWI)ISL~pgrO
(Pollution Control Facility Siting
Appeal) - 06-184
The undersigned being first duly sworn on oath, states that the original Subpoena for
Deposition was enclosed in an envelope addressed to Tom Edwards, 902 W . Moss Ave
.,
Peoria, Illinois, for service via certified mail restricted delivery postage prepaid (Return Receipt
Requested) and a copy of the Subpoena for Deposition was sent with first class postage fully
prepaid, and each of said envelopes was deposited in the United States Mail at 5
:00 p .m . on
said date.
The undersigned being first duly sworn on oath, states that a copy of the foregoing
Certificate of Service and the attached Subpoena for Deposition was served upon the following
persons as set forth below on the 12th day of October, 2006
:
Mr. Kevin Lyons
Peoria County State's Attorney
324 Main Street, Room #111
Peoria,
via hand
Illinois
delivery
61602
Ms. Carol Webb, Hearing Officer
Illinois Pollution Control Board
1021 North Grand Avenue East
P.O. Box 19274
Springfield, Illinois 62794-9274
via U.S. Mail from Peoria, IL
nan J . Meqinnes
print name)
BRIAN J. MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637.6000-Telephone
(309) 637-8514 - Facsimile
bmeginnes(fdemrslaw.com
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEORIA DISPOSAL COMPANY,
)
Petitioner,
)
PCB 06-184
v.
)
(Pollution Control Facility Siting Appeal)
PEORIA COUNTY BOARD,
)
)
Respondent.
)
SUBPOENA FOR DEPOSITION
TO: Tom Edwards
902 W. Moss Ave
.
Peoria, IL 61606
Pursuant to Section 5(e) of the Environmental Protection Act (415 ILCS 5/5(e) (2002))
and 35 Ill . Adm
. Code 101, Subpart F, you are ordered to attend and give testimony at the
deposition in the above-captioned matter at the law offices of Elias, Meginnes, Riffle & Seghetti,
P
.C., 416 Main Street, Suite 1400, Peoria, IL 61602, on the 24` h
day, October, 2006, at 1 :00 p .m.
You are also ordered to bring with you documents relevant to the matter under consideration and
designated herein, as listed on Rider A hereto .
A check in the amount of $20
.41 is enclosed herewith, pursuant to 705 ILCS §35/4
.3
($20.00
for appearance, plus $0 .20 per mile, for 2 .04 miles, roundtrip) .
Failure to comply with this subpoena will subject you to sanctions under 35 Ill . Adm.
Code 101
.622(g) and 101 .802.
ENTER: October 12, 2006
Dorothy M. Gunn, Clerk
Pollution Control Board
Date : February 13, 2003
1
RIDER A
(Please note that "Document" as used herein means all documents, objects and tangible
things contemplated by the Illinois Code, including every original (and any copy of any original
and any copy which differs in any way from any original) of every writing of every kind or
description, whether handwritten, typed, drawn, sketched, or printed, including, without
limitation, computer-generated or maintained data or reports, books, records, papers, pamphlets,
brochures, circulars, plans, correspondence, emails, communications, telegrams, memoranda,
notes, logs, notebooks, worksheets, reports, lists, analysis, appointment books, diaries, telephone
bills and toll call records, expense reports, commission statements, confirmation statements,
checkbooks, cancelled checks, receipts, contracts, agreements, instruments, assignments,
applications, offers, acceptances, written memorials of oral communications, photographs,
photographic slides or negative films, digital images, digital moving images and film strips to
which Deponent now has or has had access to in the past)
.
I .
All documents in the possession or control of Tom Edwards ("Deponent")
referring to the Application for siting approval filed by Peoria Disposal Company .
2 .
All documents in the possession or control of Deponent referring to Peoria
Disposal Company.
3.
All documents in the possession or control of Deponent received from any
member of the Peoria County Board .
4.
All documents in the possession or control of Deponent received from any person
representing the Peoria County Board.
5 .
All documents in the possession or control of Deponent received from any
employee of the Peoria County Board.
6.
All documents in the possession or control of Deponent sent (via email, U .S. Mail
or any other method) or delivered (via personal delivery or any other method) to any member of
the Peoria County Board .
2
7.
All documents in the possession or control of Deponent sent (via email, U
.S . Mail
or any other method) or delivered (via personal delivery or any other method) to any person
representing the Peoria County Board .
8.
All documents in the possession or control of Deponent sent (via email, U
.S . Mail
or any other method) or delivered (via personal delivery or any other method) to any employee
of the Peoria County Board .
9.
All documents in the possession or control of Deponent received from or authored
by any member or representative of Citizens for Our Environment .
10.
All documents in the possession or control of Deponent received from or authored
by any member or representative of River Rescue
.
11 .
All documents in the possession or control of Deponent received from or authored
by any member or representative of Sierra Club .
12
.
All documents in the possession or control of Deponent received from or authored
by any member or representative of Heart of Illinois Sierra Club .
13
.
All documents in the possession or control of Deponent received from or authored
by any member or representative of Peoria Families Against Toxic Waste
.
14 .
All documents in the possession or control of Deponent received from or authored
by Tom Edwards .
15 .
All documents in the possession or control of Deponent received from or authored
by Kim Converse .
16.
All documents in the possession or control of Deponent received from or authored
by Joyce Blumenshine .
3
17.
All documents in the possession or control of Deponent received from or authored
by Diane Storey .
18.
All documents in the possession or control of Deponent received from or authored
by Jean Roach
.
19.
All documents in the possession or control of Deponent received from or authored
by Elmo Roach.
20.
All documents in the possession or control of Deponent received from or authored
by Amy Schlicksup.
21 .
All documents in the possession or control of Deponent received from or authored
by Cara Rosson .
22.
All documents in the possession or control of Deponent received from or authored
by Tessie Bucklar .
23 .
All documents in the possession or control of Deponent received from or authored
by Tom Bucklar
.
24 .
All documents in the possession or control of Deponent received from or authored
by Mayvis Young .
25 .
All documents in the possession or control of Deponent received from or authored
by Lisa Offutt .
26.
All documents in the possession or control of Deponent received from or authored
by Peter Offutt .
27.
All documents in the possession or control of Deponent received from or authored
by Cathy Stevenson .
4
28 .
All documents in the possession or control of Deponent received from or authored
by Beth Akeson .
29.
All documents in the possession or control of Deponent received from or authored
by Jeff Akeson .
30.
All documents in the possession or control of Deponent received from or authored
by Bill Scott .
31 .
All documents in the possession or control of Deponent received from or authored
by Ted Converse .
32 .
All documents in the possession or control of Deponent received from or authored
by Bill Cook .
906-1262-Tom E .
GEORGE MUELLER
628 Columbus Street, Suite #204
Ottawa, Illinois 61350
(815) 431-1500 - Telephone
(815) 431-1501 -Facsimile
georxe(a), m uelleranderson.co m
BRIAN J MEGINNES
416 Main Street, Suite #1400
Peoria, Illinois 61602-1611
(309) 637-6000-Telephone
(309) 637-8514- Facsimile
hmeginnes(Jemrslaw
. com
5
