BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS,
)
by
LISA MADIGAN, Attorney
)
General
of the State of Illinois,
)
)
Complainant,
)
)
-vs-
)
)
)
EDWARD PRUIM, an individual, and
)
ROBERT PRUIM, an individual,
)
)
Respondents.
)
---------------)
)
)
PEOPLE OF THE STATE OF ILLINOIS,
)
by
LISA MADIGAN,
Attorney)
General of the State of Illinois,
)
)
Complainant,
)
)
-vs-
)
)
COMMUNITY LANDFILL COMPANY, INC.,
)
)
Respondent.
)
PCB No. 04-207
PCB No. 97-193
(Consolidated)
.
(Enforcement)
to: Mr. Mark La Rose, Ms. Clarissa Cutler
La Rose
&
Bosco
200
N. La Salle Street, #28 I0
Chicago, Illinois 60601
Mr. Bradley P. Halloran
Hearing Officer
Illinois Pollution Control Board
100
W. Randolph, #2001
Chicago,
IL 60601
NOTICE OF ELECTRONIC FILING
PLEASE TAKE NOTICE that we have today, November 17,2008, filed with the Office
of the Clerk of the Illinois Pollution Control Board, by electronic filing, Complainant's Response
to the Respondents' Motions in Limine
No.1, 2, and 3, a copy of which is attached and herewith
served upon you.
Electronic Filing - Received, Clerk's Office, November 17, 2008
BY:
PEOPLE OF THE STATE OF ILLINOIS
ex rei.
LISA MADIGAN
Attorney General
of the
State
Illinois
RISTOPHER GRANT
ssistant Attorney General
Environmental Bureau
69
W. Washington St., #1800
Chicago,
IL 60602
(312) 814-5388
Electronic Filing - Received, Clerk's Office, November 17, 2008
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Community Landfill Company, Inc.
EDWARD PRUIM, an individual, and
ROBERT PRUIM, an individual,
PEOPLE OF THE STATE OF ILLINOIS,
by LISA MADIGAN, Attorney
General
of the State of Illinois,
PCB No. 04-207
PCB No. 97-193
(Consolidated)
(Enforcement)
-vs-
-vs-
Respondent.
Complainant,
Respondents.
Complainant,
PEOPLE OF THE STATE OF ILLINOIS,
)
by LISA MADIGAN, Attorney
)
General
of the State of Illinois,
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COMPLAINANT'S RESPONSE TO RESPONDENTS' MOTION IN LIMINE NO.1
NOW COMES Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General
of the State of Illinois, and hereby responds to Respondents'
EDWARD
PRUIM, ROBERT PRUIM, AND COMMUNITY LANDFILL COMPANY'S
Motion in Limine No.1.
Electronic Filing - Received, Clerk's Office, November 17, 2008
I.
THE STATE DOES NOT INTEND TO IMPEACH THE PRUIM DEFENDANTS
WITH EVIDENCE OF PRIOR CONVICTIONS
The State agrees that evidence of prior convictions may not be used to impeach credibility
after a period
of 10 years from release from incarceration, and that Defendants Robert Pruim and
Edward Pruim were released from incarceration more than
10 years before hearing in this matter.
However, Respondents either misunderstand the intended use
of the disclosed materials, or are
attempting to extend the rule to bar otherwise admissible evidence.
On October 6, 2008, the undersigned sent copies
of certain documents to opposing
counsel. Included were certified copies
of post-conviction court filings from
People v. Edward
Pruim, Robert Pruim, and Thomas
0
'Connor,
93 CR 682.
In
this case, Edward Pruim and
Robert Pruim plead guilty to certain felony counts brought by the United States. However,
neither the fact
of the criminal convictions nor the underlying details are necessary to the State's
case, or its proposed use
of the documents.
The records to be used by the State
(if necessary) will establish the following:
1) Edward Pruim agreed to pay a fine in the amount of $1 ,250,000 on April 18, 1994;
2) Robert Pruim agreed to pay a fine in the amount of $1 ,250,000 on September 24, 1994;
3) Edward and Robert Pruim failed to pay the fines on the agreed dates;
4) The United States filed motions to incarcerate Edward and Robert Pruim for failure
to
pay the agreed fines;
5) The fines were paid, and the United States filed a satisfaction
ofjudgment on July 12,
1995.
Although
in its October 6, 2008 letter, the undersigned characterized the use of these
documents as
'forimpeachment', they would actually be used, if at all, in the State's case in
2
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Electronic Filing - Received, Clerk's Office, November 17, 2008
rebuttal. Specifically,
if
Edward Pruim and Robert Pruim deny the above, the State will seek to
enter these certified court documents to rebut their testimony. The State has no intention
of
using the prior felony convictions to impeach the Pruim's overall credibility as witnesses.
II. THE EVIDENCE IS HIGHLY RELEVANT
With other evidence, the State will show that the Pruims had knowledge of the limited
remaining capacity at the Morris Community Landfill in 1994, and that the Landfill would
become overfilled during that year. The State will show that the Landfill became overcapacity
during 1994, but that the Pruims continued to accept waste at the Landfill for another two years.
The fact that the Pruims were facing possible incarceration during this period for failing
to pay a total fine
of $2,500,000.00 is highly relevant to this case.
It
will help prove both
personal involvement, i.e., continuation
of operation to help satisfy a judgment and therefore
avoid incarceration, as well as an intentional violation for the purpose
of attorney fees and costs.
III. THE EVIDENCE IS NOT BARRED BY ILLINOIS LAW
As noted, the State does not intend to raise details of the underlying criminal conviction.
The purpose
of the plea agreement is merely to show the underlying debt. For that reason, and
to avoid any possible prejudice, the State is willing to enter a stipulation to the above-noted facts
in lieu
of entering the certified copies. However, even if the documents provide details of the
underlying criminal convictions, the evidence should not be excluded.
Impeaching a witness with a prior conviction is meant to affect the credibility
of the
witness testimony.
People
v.
Naylor,
229 Ill. 2d 584, 598-599 (2008). However, a conviction
may be used for any other purpose
if relevant to any matter in the case. Evidence of past crimes
which do not relate to testimonial credibility may be admitted
if they are relevant for some
3
Electronic Filing - Received, Clerk's Office, November 17, 2008
purpose other than impeachment.
People v. Williams,
161 Ill. 2d 1, at 38 (1994).
In our case, the facts relating to the unpaid fine, threat of incarceration for nonpayment,
and subsequent satisfaction of the debt will be used, if at all, for rebuttal. The evidence will only
be used
if Edward and/or Robert Pruim deny these contentions on direct examination. There
can be no question that the facts are clearly established by certified court records, and the State is
willing to enter into a satisfactory stipulation to avoid even the hint
of prejudice.
WHEREFORE, Complaint respectfully requests that the Hearing Officer deny
Respondents Motion in Limine
No.1.
Respectfully Submitted,
By:~~k
(j:HRISTOPHER GRANT
JENNIFER VAN WIE
Assistant Attorneys General
Environmental Bureau
69 W. Washington St.,
18
th
FIr.
Chicago, Illinois 60602
(312) 814-5388
(312) 814-0609
4
Electronic Filing - Received, Clerk's Office, November 17, 2008
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Community Landfill Company, Inc.
EDWARD PRUIM, an individual, and
ROBERT PRUIM, an individual,
PEOPLE OF THE STATE OF ILLINOIS,
by LISA MADIGAN, Attorney
General of the State of Illinois,
PCB No. 04-207
PCB No. 97-193
(Consolidated)
(Enforcement)
-vs-
-vs-
Respondent.
Respondents.
Complainant,
Complainant,
PEOPLE OF THE STATE OF ILLINOIS,
)
by LISA MADIGAN, Attorney
)
General
of the State of Illinois,
)
)
)
)
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COMPLAINANT'S RESPONSE TO RESPONDENTS' MOTION IN LIMINE NO.2
NOW COMES Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General
of the State of Illinois, and hereby responds to Respondents'
EDWARD
PRUIM, ROBERT PRUIM, AND COMMUNITY LANDFILL COMPANY'S
Motion
in Limine No.2.
Electronic Filing - Received, Clerk's Office, November 17, 2008
I.
JOHN ENGER WAS PROPERLY DISCLOSED
1.
Respondents seek to exclude the testimony of witness John Enger, City Clerk of
the City of Morris. At the latest, Mr. Enger was disclosed eighty nine days ago. His testimony
will simply relate to authentication
of city documents. The documents were originally made
available to the Respondents in
People
v.
Community Landfill Co. and City ofMorris,
PCB 03-
191, and were provided again to Respondents on October 6, 2008, well before the deadline set by
the Hearing Officer in this case. Mr. Enger was deposed in PCB 03-191 on March 2, 2004.
Counsel for Respondents were present at that time.
2.
Respondents claim that "the parties have propounded numerous discovery
requests". However, they fail to mention that no written discovery was conducted by the
Respondents after 2003, not even after Robert Pruim and Edward Pruim were added in case No.
PCB 04-207. Instead, the Respondents sought two extensions
of the hearing date, in 2006 and
early this year. Therefore, it has been five years since any discovery was promulgated by the
Respondents whatsoever.
3.
Respondents raised the identical issue in their earlier objection to the testimony of
Gary Styzens. In that case, the Hearing Officer allowed for a continuation of hearing to allow for
additional depositions. Although Mr. Styzens was subsequently deposed, at no time did the
Respondents indicate any interest in deposing Mr. Enger. This is not surprising: they are fully
and completely aware
of the subject matter of his limited testimony. However, they cannot now
claim unfair surprise.
4.
The August 20, 2008 witness list submittal provided more than sufficient
information to supplement the 2003 interrogatory responses. Given the Respondents extensive
2
Electronic Filing - Received, Clerk's Office, November 17, 2008
knowledge of both Mr. Enger and of his limited testimony regarding the City of Morris records,
there
is no basis for excluding his testimony.
WHEREFORE, Complaint respectfully requests that the Hearing Officer deny
Respondents Motion in Limine
No.2.
Respectfully Submitted,
BY:
!l=HRISTOPHER GRANT
uJENNIFER VAN WIE
Assistant Attorneys General
Environmental Bureau
69
W. Washington St., 18
th
FIr.
Chicago, Illinois 60602
(312) 814-5388
(312) 814-0609
3
Electronic Filing - Received, Clerk's Office, November 17, 2008
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
Community Landfill Company, Inc.
EDWARD PRUIM, an individual, and
ROBERT PRUIM, an individual,
PEOPLE OF THE STATE OF ILLINOIS,
by LISA MADIGAN, Attorney
General
of the State of Illinois,
PCB No. 04-207
PCB No. 97-193
(Consolidated)
(Enforcement)
-vs-
-vs-
Respondent.
Respondents.
Complainant,
Complainant,
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
PEOPLE OF THE STATE OF ILLINOIS,
)
by LISA MADIGAN, Attorney
)
General
of the State of Illinois,
)
)
)
)
)
)
)
)
)
)
)
)
COMPLAINANT'S RESPONSE TO RESPONDENTS' MOTION IN LIMINE NO.3
NOW COMES Complainant, PEOPLE OF THE STATE OF ILLINOIS, by LISA
MADIGAN, Attorney General
of the State of Illinois, and hereby responds to Respondents'
EDWARD PRUIM , ROBERT PRUIM, AND COMMUNITY LANDFILL
COMPANY'S
Motion in Limine No.3.
-----------------------------------------~
Electronic Filing - Received, Clerk's Office, November 17, 2008
I.
ALL INSPECTION REPORTS WERE PRODUCED TO RESPONDENTS
1.
Respondents also seek to prevent the State from introducing eight inspection
reports, based on five year old discovery responses. However, all documents were made
available for inspection and copying in 2003, when Respondent CLC last conducted written
discovery!. The inspection reports were properly listed on Complainant's August 20, 2008
disclosure.
2.
The records related to this case number in the thousands of pages. In response to
Respondent
CLC's Request for Production of Documents, the files were made available at
Complainant's offices five years ago. Counsel Clarissa Cutler subsequently reviewed several
bankers boxes
of documents and selected certain documents for copying. Respondents cannot
now claim
in good faith that they were not given access to all inspection reports.
3.
Moreover, Illinois EPA Bureau
of Land routinely mails copies of these reports to
the regulated entity soon after inspection. In the limited time available to respond to this Motion
in Limine, Complainant was able to locate transmittal letters for five of the challenged dates
(Exhibit A). The letters show that inspection reports were routinely provided to the Respondents
years ago.
4.
The Respondents had a full and complete opportunity to view all records, were
provided with copies
of the inspection reports soon after inspection, and were notified the
documents would be used at trial eighty-nine days ago. There is no basis whatsoever for
excluding this relevant evidence.
IRespondents Edward Pruim and Robert Pruim never submitted written discovery
requests. Between 2003 and the recent deposition
of Gary Styzens, neither CLC nor the Pruims
sought to depose any State witnesses.
2
Electronic Filing - Received, Clerk's Office, November 17, 2008
WHEREFORE, Complaint respectfully requests that the Hearing Officer deny
Respondents Motion in Limine
No.3.
Respectfully Submitted,
BY:
---+\------W
RISTOPHER GRANT
JENNIFER VAN WIE
Assistant Attorneys General
. Environmental Bureau
69
W. Washington St., 18
th
FIr.
Chicago, Illinois 60602
(312) 814-5388
(312) 814-0609
3
Electronic Filing - Received, Clerk's Office, November 17, 2008
ILLINOIS ENVlRONtv1ENTAL PROTECTION AGENCY
1701 SOLITI I FIR5T
ST~EET,
M.... n\uoD.
ILLI"
J1~
flU
15:1
THO\\,\~
V.
SJ.;INNER. DIRECTOR
.....,
708/338-7900
708/338-7752
(Faxi
Apl'il
26.2000
City of Morris
Attn: Robert T. Feeney
320 Wauponsee Street
ivlorris. IL 60450
Re: LPC #063060000
I-Grundy County
Community Landfill
Compliance File
Dear Mr. Feeney:
On April 17, 2000. an inspection
of the above referenced site was conducted by Mark Relzlaffrepresenting
the Illinois Environmental Protection Agency. The purpose of this inspection was to determine your
facility's compliance with the applicable requirements of the Illinois Environmental Protection Act and 35
Illinois Administrative
Code Parts 807-815 and all applicable permits. for your information a copy of this
inspection report is enclosed.
Should
YOt; hzve any questions concerning this inspection. please contact Mark RetzlafT at 708/338-7900.
Sincerely.
Clifford Gould. Regional Manager
. Field Operations Section
Bureau
of Land
CG:MR:dfa:CL.1
Enclosure(s)
.JiJ;,:
2
2,
200n
bce:
Regional File
Maywood
file
•
-.
p ....
p.nll""~
EXHIBIT
IA
Electronic Filing - Received, Clerk's Office, November 17, 2008
State of Illinois
:
ENVIRONMENTAL PROTECTION AGENCY
:\1ary A. Gade, Director
708/338-7900
708/338.7473
December I. 1998
Community Landfill, Inc.
Attn:
Mr. Robert Pruim
13710
S. Kostner Avenue
Crestwood, IL 60445
Re:
LPC #0630600001 -- Grundy County
Morris/Community Landfill
Compliance File
Dear Mr. Pruim;
1701 First Avenue, Maywood, IL 60153
On November 19, 1998, your facility was inspected by Warren Weritz of the Illinois
Environmental Protection Agency. The purpose of this inspection was to determine your
facility's compliance with the Illinois Environmental Protection Act
and 35 Illinois
Administrative Code Part 807..
At the time of the inspection, apparent violation(s) found in
previous inspection(s) conducted on March 5, 1997 and July 28, 1998 were again observed.
For your information, a copy
of this inspection report is enclosed. Should you have any
questions regarding this inspection, please contact Warren Weritz at 708/338-7900.
Sincerely,
a~.Jl~
Clifford Gould,
Regional Manager
Field Operations Section
Bureau
of Land
CG:dfa:CLI
Enclosure
bbc: Division File
Region File
Compliance Unit
Printed on Recycled Pacer
RECEl'VEO
MAR
08 1999
!C.t"h-
UWC
Electronic Filing - Received, Clerk's Office, November 17, 2008
~
State of fllinois
~
ENVIRONMENTAL PROTECTION AGENCY
Mary A. Gade,
Diredor
217/785-8604
Fax: 217/524-1991
TDD: 217/782-9143
August 29, 1996
o
Community Landfill. Inc.
Attn: Robert Pruim
13701 South Kostner Avenue
Crestwood. IL 60445
Re: LPC #0630600001
-- Grundy County
Morris/Community Landfill. Inc.
Compliance File
Dear
Mr. Pruim:
2200 Churchill Road, Springfield, It 62794-9276
On July 11. 1996 an inspection of the above reterenced site was conducted by Warren Weritz
representing the Illinois Environmental Protection Agency.
The purpose ofthis inspection was to
determine the
site's compliance with the [Illinois] Environmental Protection Act and 35 Illinois
Administrative Code. Subtitle G.
Enclosed is a copy
of the inspection report for your information. No violations were noted at the
time
of this inspection.
Should
you have any questions regarding this inspection, please call Mr. Weritz at 708/338-7900.
Sincerely.
Field
D~:~e[
Operations Section
Division
of Land Pollution Control
Bureau
of Land
DJ:JH:gm
Enclosure
.' ..•..•.. _
... _----
bc: Division File
D. Virgin - Compliance
Maywood Region
Electronic Filing - Received, Clerk's Office, November 17, 2008
Mary
A.
Gade, Director
217/785-8604
Fax: 217/524-1991
December 14, 1995
Community Landfill, Inc.
Attn:
Ed Pruim
4330 West 137th Place
Crestwood, IL
60445
2200 Churchill
Roa~
Springfield, IL 62794-9276
Re:
LPC # 0630600001 -- Grundy County
Morris/Community Landfill
Compliance File
Dear Mr. Pruim:
On November 7, 1995, an inspection
of the above referenced
sit~
was conducted by Warren
Weritz representing
the Il1inois Environmental Protection Agency.
The purpose of this
inspection was to detennine the site'scompliance with the Illinois Environmental Protection Act
and 35 Illinois Administrative Code, Subtitle G, Part 807: "Solid Waste" regulations and Part
809:
"Spt:dal Waste Hauling" regulations.
.
No violations were noted at the time of this inspection.
Should you have any questions regarding
this
inspection, please do not hesitate to contact Mr.
Weritz at 708/338-7900.
Sincerely,
Glenn D. Savage, Manager
Field Operations Section
Division
of Land Pollution Control
Bureau
of Land
GDS:JH:gm
Attaclunent
bce: Division File
Deanne Virgin/Compliance
~aywood
Regional Office
SCREE}~ED
n~r.
2 n 1995
---,
DJH
\
Electronic Filing - Received, Clerk's Office, November 17, 2008
.::-
I'~
~Ntf;~ONME~~~~ROTECTION
AGENCY
Mary A. Cade, Director
2200 Churchill Road, Springfiel
l
', It
62794.9276
ADMINISTRATIVE WARNING NOTICE
BROUGHT BY THE ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
IN THE MATTER OF:
MORRIS/COMMUNITY LANDFILL
)
)
)
0630600001 -- GRUNDY COUNTY
MORRIS/COMMUNITY LANDFILL
COMPLIANCE FI LE
FACTS
On May 26, 1994, an inspection of your facility was conducted by Harren Werltz
representing the Illinois Environmental Protection Agency (hereinafter
"IEPA"). This inspection was conducted in accordance with Sections 4(c) and
4(d) of the Illino's Env'ronmental Protection Act (Act): 415 ILCS 5/4 (c) and
(d) (1992). The purpose of this inspection was to determine your compliance
with the
Illinois Environmental Protection Act and 35 Illinois Administrative
Code, Subtitle G. Part 807: "Solid Haste" regulations and Part 809: "Special
Haste Hauling" regulations.
The attached inspection report specifies the date and time of the inspection
along with other relevant information.
Items numbered one (1) through
forty-four (44)
represent requirements established by the Illinois
Environmental Protection Act and/or 35 Illin01s Admin1strat've Code. Subtitle
G. Parts 807 and 809. At the time of the Inspection, apparent violations were
1dentlfied. These specific apparent v101ation(s) are identified with an "X"
on the attached inspection report.
REQUIRED RESPONSE
You must submit, in writing, within fifteen days of the date of this letter.
the reasons for the apparent violat10n(s) noted in the attached inspection
report. Also, please describe
in detail the corrective action, which has
been, or will be, taken to rectify the apparent vlolat1on(s) noted in the
inspection
report. please reference the IEPA designated facility number and
facility name assigned above on any correspondence concerning this matter.
CORRECTIVE ACTION REQUIRED
IF YOU WISH TO AVOIP FURTHER ADMINISTRATIVE
OR CIVIL ENFORCEMENT. YOU MUST INITIATE THE
fOLLOHING CORRECTIVE ACTIONS:
Printed on Recycled PIPer
l_
Electronic Filing - Received, Clerk's Office, November 17, 2008
,, .
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Page 2
1. In reference to Line 1 of the attached inspection report, the inspectIon
revealed the
following condltion(s) which constitutes violation(s) of your
permit:
a)
Condition 9: Any modification of the facility shall be the subject
of an application for supplemental permit. Actual compostlng
locatIon
conflIcts with the applIcation location found In Attachment
2 of the
application permit. Refer to Condition 9 of Permit No.
1990-048-DE/OP.
b)
Condition 10: Permittee shall notIfy the Agency of changes of
InformatIon submitted to the Agency concerning the permit
application.
Windrow configuration and spacing changes were not
submitted
to the Agency.
Either supply the Agency with the requIred notices and supplemental permIts or
comply with the plans of your permit applIcation. You have a compliance
deadline
of August 24, 1994.
A re-inspection will be conducted by Agency personnel to verify compliance.
POTENTIAL SANCTIONS
If-tnt-[eguirements specifIed in this Administrative Warning Notice are not
satisfied and the attached inspection report alleges violations subject to the
administrative citation process, pursuant to 415 ILCS 5/31.1 (1992), this
Agency may, WITHOUT FURTHER NOTICE, cause an administrative citation to be
filed with the Pollution Control Board. Please be advised that each and every
finding of an admInIstrative citation violatIon requires a mandatory fIne of
$500.00 per
violation. Notwithstanding the fact that an administrative
citation may be fIled, you are expected to respond to this Notice in order to
describ~
the steps you have or will take to correct all of the violations
noted in the inspection report and to outline a proposal for action to insure
that the alleged violations will not occur again.
You are further advised that noncompliance with the requirements of the
Illinois Environmental' Protection Act and rules and regulations adopted
thereunder
may also result in the following:
1. The filing of an enforcement action with the Pollution Control Board
pursuant to 415 ILCS 5/1
J1~.
(1992), and in particular, 415 ILCS
5/31
(1992); or
2. The filIng of a civil action In circuit court pursuant to 415 ILCS 5/42
(1992).
Potential sanctions for the legal
actions descrIbed above may include, but are
not
limited to: Assessment of civil penalties In accordance with 415 ILCS
5/42 (1992). which provides for a maximum civil penalty of not to exceed
$50,000.00 for said
violation, and an additional civIl penalty of not to
exceed $10,000.00 for each day during which the violation continues, an order
to cease
and desist from further violations, requ\red remedIal action, posting
of a
security instrument to assure correction of an adjudicated violation, and
restraining and injunctive orders.
Electronic Filing - Received, Clerk's Office, November 17, 2008
',.
';)~
( .'
..
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: '.
Page 3
GENERAL INFORMATION
Your written response and two copies of all documents submitted In response to
th1s letter should be sent to:
Deanne Virgin
Comp 11 ance Unit
Bureau of Land
#24
Illin01s Environmental Protection Agency
2200 Churchill Road
Post Office Box 19276
Springfield, Illinois 62794-9276
Should you have any questions concerning this Administrative Warning Notice.
or
need further assistance, contact Harren Weritz at 708/338-7900.
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
By:
Glenn D. Savage, Jr',. Mana r
Field Operations Section
Division of Land Pollution Control
Bureau of Land
Date:
CERTIFIED MAIL #
t{
3
S
0
q~
YSLf
GDS:HFH:DV:rlc/I062w;29-31
bee: Division File
Haywood Region
Warren Heritz
Deanne Virgin
Community Landfill. Inc.
4330 West 137th Place
Crestwood.
Illin01s 60445
Electronic Filing - Received, Clerk's Office, November 17, 2008
CERTIFICATE OF SERVICE
I, CHRISTOPHER GRANT, an attorney, do certify that I caused to be served this 17th
day
of November, 2008, the foregoing Response to the Respondents Motions in Limine 1, 2
and 3, and Notice
of Filing, upon the persons listed on said Notice by placing same in an
envelope bearing sufficient postage with the United States Postal Service located at 100 W.
Randolph, Chicago Illinois.
CHRISTOPHER GRANT
Electronic Filing - Received, Clerk's Office, November 17, 2008
