CEVE
BEFORE
THE
ILLINOIS
CLERK’S
OFFICE
POLLUTION
CONTROL
BOARD
DEC
6
2008
STATE
OF
ILLINOIS
IN
THE
MATTER
OF
)
POllution
Control
Board
)
JOSEPH
&
VICTORIA
MORRISSEY,
)
)
Complainants,
)
)
v.
)
PCB
09-10
)
GEOFF
PAHIOS
and ALPINE
)
AUTOMOTIVE,
)
)
Respondents.
)
NOTICE
OF
FILING
To:
Joseph
&
Victoria
Morrissey
Illinois
Pollution
Control
Board
32
S.
Chestnut
Court
James
R.
Thompson
Center,
#11-500
Hawthorn
Woods,
Illinois
60047
100
W.
Randolph
St.
Chicago,
Illinois
60601
I,
Bruce A.
Slivnick,
state
that
I have
served
a true
copy of
this Certificate
of Service
and
Plaintiff’s
Notice
to Produce,
Request
for
Production,
and Interrogatories
upon
the
party
to
whom
it
is
directed
by
mailing
the same
in
a
properly
addressed,
stamped
envelope,
sealed,
postage
prepaid
and
depositing
same
in
the
U.S.
Mail
box
at 707 Lake
Cook
Road,
Deerfield,
Illinois,
before
5:00
p.m.,
on
this 28th
day
of November
2008.
Bruce
A.
Slivnick
Attorney
At Law
707
Lake
Cook
Road,
Suite
316
Deerfield,
Illinois
60015
(847)
714-0503
Attorney
Number
6181410
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
IN
THE
MATTER
OF:
)
DEC
0120
OF
ILLINOIS
JOSEPH
&
VICTORIA
MORRISSEY,
)
fltrol
Board
)
Complainants,
)
)
v.
)
PCB
09-10
)
GEOFF
PAHIOS
and
ALPINE
)
AUTOMOTIVE,
)
)
Respondents.
)
REOUEST
FOR
PRODUCTION
To:
Joseph
&
Victoria
Morrissey
32
S.
Chestnut
Court
Hawthorn
Woods,
Illinois
60047
Pursuant
to
Supreme
Court
Rules
201(k)
and
214,
you
are
hereby
requested
to
produce
at
the Law
Offices
of
Bruce
A. Slivnick
and/or
Paul
J. Oleksak,
the
attorneys
for
the
Respondents,
within
28
days,
for inspection,
copying,
reproduction
and
photographing,
the following
(together
with
any
transcripts,
reports,
memoranda,
or
recordings
purporting
to reflect
but
not
to
evaluate
the
same):
DEFINITIONS
AND
INSTRUCTIONS
A.
Any
reference
to
a corporation,
municipal
corporation,
partnership,
association,
person
or
other
entity
shall
also
include,
where
applicable,
elected
officials,
appointed
officials,
subsidiaries,
departments,
member
of
appointed
boards,
officers,
directors,
employees,
accountants,
agents
and/or
other
representatives.
B.
The
term
“document”
means
any
writing,
graphic
matter
or
other
tangible
thing,
whether
printed,
recorded,
produced
by
any
process,
or
written
or
produced by
hand,
including
but
not
limited
to
video
tapes;
CD
ROMs;
DVDs;
computer
stored
videos;
visual
and/or
audio
representations
of
an occurrence
kept
in
any
form
whatsoever;
canceled
checks;
account
statements;
accounting
summaries
or
reports;
ledgers;
letters;
reports;
other
written
communications;
correspondence;
telegrams;
memoranda;
summaries;
records
of
oral
conversations;
original
or
preliminary
notes;
diaries;
calendars;
analyses;
projections;
work
papers;
photographs;
tape
recordings;
computer
hard
drives
or disks;
E-Mail;
statistical
statements;
notebooks;
minutes
or
records
of
meetings;
minutes
or
records
of
conference
lists
or
persons attending
meetings
or
conferences;
notes,
reports
and/or
summaries
of
investigations;
opinions
or
reports
of consultants;
appraisals;
evaluations;
records;
summaries
of
negotiations,
contracts,
invoices,
receipts
and
canceled
checks;
including preliminary
drafis
or
revisions
or
copies
of
any
of
the
foregoing
if
the
copy
is
in
any
way
different
from
the
original
now
in
your
possession,
custody
or
control
of
your
counsel,
independent public
accountants,
evaluation
consultants, agents,
employees,
and/or
people
acting
of
on
your
behalf.
As
used
herein
“control”
means
actual
possession,
constructive
possession,
beneficial
ownership,
power
and
ability
to
obtain
any
document.
C.
If a
“document”
has
been
prepared
in
several
copies, or additional
copies
have
been
made
and
the
copies
are
not
identical
(of
by
reason
of
subsequent modifications
of the
copy
by
additions
or
notations,
or other
modifications,
are
no
longer
identical),
each
non-identical
copy
is
a separate
document.
D.
The
words
“and”
as
well
as
“or”
shall
be
construed either
disjunctively
or
conjunctively
as
necessary
to
bring
within
the
scope
of
this
set
of requests
any
information
which
might
otherwise
be
construed
as outside
their
scope.
E.
The
term
“relate
or relating
to”
or
“in connection
with”
shall
mean
consist
of,
refer
to,
or
to
be
in
any
way
logically
or
factually
connected
with
the
matter
discussed,
whether
directly
or
indirectly.
F.
Whenever appropriate
herein
the
singular
form
of
a
word
shall
be
interpreted
as
the
plural
form.
G.
The
term
“communication”
means
any
transmission
of words
or
thoughts
between
or
among
two
or
more
persons
and
includes,
but
is
not
limited
to
spoken
words,
conversations,
inquiries,
understandings,
agreements,
meetings,
conferences,
discussions, talks
and
reports,
which
transmitted
in
person
or
by
any
electronic
device
such
as
telephone,
facsimile
or
radio,
and
documents
as
defined
above.
H.
The
term
“meeting”
and
“meetings”
shall
mean
any
coincidence
of
presence,
whether
by
chance
or
prearranged,
formal
or
informal
in connection
with
some
other
activity.
I.
In
the event
that
the
address
of
a
place
includes
the
improper
municipality
in which the
location is
located,
the
request shall
be
treated
as if
the
proper
municipality
was
referred
to.
Eg.
“Hawthorn
Woods”
instead
of
“Lake
Zurich”.
J.
The
term
“witness”
means
any
person
who
has
personal
knowledge
of
the
facts,
allegations
or
other
person
or entity
that
otherwise
be
called
upon
to testify during
the
trial
on
the
Complaint.
PRODUCTION
REOUEST
(1)
The
statement
of
any
party
to
some
person
or
entity
other
than
his
attorney
or
insurer,
including
that
of
the
plaintiff(s),
which
is
in your
possession
or
control,
directly
or
indirectly.
(2)
The
statement
of any
other
witness,
except
parties
to
this
action,
non-treating
experts
and/or
other
participants
who
may
yet have
been
named
as
a
party
because
of the
alleged
noise
pollution.
(3)
All
photographs,
slides
or motion
pictures,
video
and/or
audio
recordings,
taken
to
record
the
alleged
noise
pollution
complained
of
in
the complaint
and/or
the
locations
involved
in the
complaint.
(4)
All
data
as
to the
physical
or
mental
condition
of
the plaintiff(s)
prior
to or
subsequent
to
the
alleged
noise
pollution
and
which
are
claimed
to
have
been
caused
by
or
exacerbated
by
said
noise
pollution
including
but not
limited
to
medical
reports
documenting
such claimed
injuries.
(5)
A list
giving
the
names,
addresses
and
specialties
of
all
opinion
witnesses
(other
than
non-treating,
purely
consultant
experts
who
are
not
testify
at
the
trial),
omitting
all persons
already
listed
above.
(6)
The
results
of
any
test,
experiment,
or
other
scientific
study
from
which
you
reasonably
anticipate
you
will
attempt
to
introduce
into evidence
in
a trial
of
this cause.
(7)
The
results
of
any
and
all
investigations
of the
alleged
incidents
(noise
pollution)
made
the
basis
of
this
Complaint
(other
than
those
privileged
by
law).
If
you
are
claiming
privilege
as
to
any
investigation,
based
on its
allegedly
being
done
in anticipation
of
litigation,
describe
specifically
what
you
are relying
on to
establish
that
you
had
reason
to
believe
the
litigation
would
ensue,
including
what
overt
acts
or
statements
were
made
by
Complainants
or
someone
acting
on behalf
of
Complainants.
(8)
Copies
of
any
complaints,
inquiries,
police
reports,
or
any
other
type
of
documentation
presented
to
a local
(municipal
or
county),
state
and/or
federal
authority
relative
to
the noise
pollution
complained
of
including
but
not limited
to
minutes
of
zoning
board,
and/or
municipality
village
board
meetings;
correspondence
with
municipal
(village,
county,
state
and/or
federal
authorities
relating
to
the
alleged
noise
pollution.
(9)
Copies
of
any complaints,
inquiries,
police
reports,
or
any
other
type
of
documentation
presented
to
a local
(municipal
or
county),
state
and/or
federal
authority
relative
to
the noise
pollution
complained
of
including
but
not limited
to
minutes
of
zoning
board,
and/or
municipality village
board
meetings;
correspondence
with
municipal
(village,
county,
state
and/or
federal
authorities
relating
to the
zoning
application
for
the
Respondents’,
property.
(10)
Copies
of
any
complaints,
inquiries, police
reports,
or any
other
type
of
documentation presented
to a
local
(municipal
or county),
state
andJor
federal
authority
relative
to
the
noise
pollution
complained
of including
but
not
limited
to
minutes
of
zoning
board,
and/or
municipality
village
board
meetings;
correspondence
with
municipal
(village,
county,
state
and/or
federal
authorities
relating
to
the
noise
pollution
processed
against
property
neighboring
the
Respondent’s property
and/or
in
the vicinity
of Respondents’
property.
(11)
Any
documentation
supporting
the
Complainants’
allegations
that
the
noise
pollution
complained
emanated
from
the
Respondent’s
property
rather
than
property
neighboring
the
Respondents’
property
and/or
in the
vicinity
of
Respondents’
property.
(12)
Any
and all
documents pertaining
to
any
inspection
of
the premises
involved
in
this complaint,
within
6
months
before
or after
the
time
frames
involved
in
this
complaint.
(13)
Any
and
all
documents
otherwise
supporting
and/or
refuting
the
Complainants
allegations.
(14)
Any
and
all
documents
that the
Complainants
intend
to introduce
during
the
trial
on
the
Complaint.
(15)
The
reports
of any
opinions
witness
identified
under
Illinois
Supreme
Court
Rule
213.
(16)
Copies
of
all
documents
referred
to or
which
related
to
the
Complainants’
Answers
to
Interrogatories.
The
word
“party”
shall,
if an
individual,
also include
members
of
his
immediate
family,
and
shall,
if
a
corporation,
include,
directors,
foremen
and
managing
agents.
By:_________
Attorneys
for
Respondents
Paul
J.
Oleksak
Attorney
At
Law
100 Atkinson Road,
Suite
11 OF
Grayslake, Illinois
60030
(847)
543-9000
Attorney
Number
Bruce
A.
Slivnick
Attorney
At
Law
707
Lake
Cook
Road,
Suite
316
Deerfield, Illinois
60015
(847)
714-0503
Attorney
Number
6181410
BEFORE
THE
ILLINOIS
EVE
POLLUTION
CONTROL
BOARD
CLERK’S
OFFICE
DEC
01
20
IN
THE
MATTER
OF:
)
POll
tT
JOSEPH
&
VICTORIA
MORRISSEY,
)
)
Complainants,
)
)
v.
)
PCB
09-10
)
GEOFF
PAHIOS
and
ALPINE
)
AUTOMOTIVE,
)
)
Respondents.
)
NOTICE
TO
PRODUCE
To:
Joseph
&
Victoria
Morrissey
32
S.
Chestnut
Court
Hawthorn
Woods,
Illinois
60047
Pursuant
to
Supreme
Court
Rules
213(e),
220,
237
and
Sec.
2-1102
of
the
Illinois
Code
of
Civil
Procedure,
you
are hereby
notified
to
produce
at the
commencement
of
either
trial
and/or
evidentiary
hearing
of
this
case,
prior
to
the
commencement
of said
evidentiary
hearing:
1.
The
full
name
and
complete
last
known
address
of
every
witness
to the
occurrences
complained
of.
2.
The
full
name
and
complete
last
known
address
of
all
other
persons
who
have
knowledge
of
the
matters
pleaded
or
of relevant
facts,
including
the
special
field
of
each
expert.
3.
All
statements
of
any
party
to
some
person
or
entity
other
than
his
attorney
or
insurer, including
that
of
the
Complainants
and/or
Respondents,
which
is in
your
possession
or
control, directly
or
indirectly.
4.
The
statement
of
any
other
witness.
5.
All
photographs,
slides
or motion
pictures,
audio
and/or
video
tape
taken
of the
alleged
occurrences
or
physical
objects
involved,
or
the
scene
of
the
alleged
occurrence.
6.
All
data
as
to
the
physical
or
mental
condition
of
the
plaintiff
prior
to
or
subsequent
to
the
alleged
occurrences,
including,
inter
alia,
to
medical
reports
documenting
such
injuries
either
caused
by
or
exascerbated
by
the
noise
pollution
involved.
7.
A
list
giving
the
names,
addresses
and
specialties
of all
persons Complainants
will
call
to testif’
at
any
evidentiary
hearing.
9.
Complainants,
Joseph
Morrissey
and
Victoria
Morrissey.
The
word
“party”
shall,
if
an
individual,
also
include
members
of his
immediate family,
and
shall,
if
a
corporation,
include,
directors,
foremen
and
managing
agents.
Paul
J.
Oleksak
Attorney
At
Law
100
Atkinson Road,
Suite
11 OF
Grayslake,
Illinois
60030
(847)
543-9000
Attorney
Number
Bruce
A.
Slivnick
Attorney
At
Law
707
Lake
Cook
Road,
Suite
316
Deerfield, Illinois
60015
(847)
714-0503
Attorney Number
6181410
Attorneys
for
Respondents
BEFORE
THE
ILLINOIS
POLLUTION
CONTROL
BOARD
IN
THE
MATTER
OF:
)
)
JOSEPH
&
VICTORIA
MORRISSEY,
)
)
Complainants,
)
)
v.
)
PCB
09-10
)
GEOFF
PAHIOS
and
ALPINE
)
AUTOMOTIVE,
)
)
Respondents.
)
INTERROGATORIES
To:
Joseph
&
Victoria
Morrissey
32
S.
Chestnut
Court
Hawthorn
Woods, Illinois
60047
Respondents,
GEOFF
PAHIOS
and
ALPINE
AUTOMOTIVE,
INC.,
by
and
through
their
attorneys,
Paul
J.
Oleksak
and
Bruce
A.
Slivnick
serve
the
following
interrogatories
on
the
Complainants,
JOSEPH
MORRIS
SEY
and
VICTORIA
MORRIS
SEY,
to
be
answered
under
oath
within
28
days:
1.
State
the
name
of
the
Complainants
answering
and,
if
different,
give
the
full
name
and
address
of the
individual
signing
the
answers,
and
the
capacity
in
which
said
person
is
signing
the
answers.
ANSWER:
2.
State
the
full
name
and
address
of
each
person
who
witnessed
or
claims
to
have
witnessed
the
occurrences
(alleged noise
pollution)
alleged
in
the
Complaint.
ANSWER:
3.
State
the
full
name
and
address
of each
person
not
named (in
Answer
to
Interrogatory
Number 2)
above
who
was
present
or
claims
to
have
knowledge
of
the
noise
pollution
complained
of
in
the
Complainants
complaint.
ANSWER:
4.
The
dates
and
times
of any
and/or
all
occurrences
of
the
noise
pollution
complained
of in
the
Complainants’
Complaint.
ANSWER:
6.
Were
any
photographs,
slides
or
motion
pictures,
video
and/or
audio
recordings
taken
of
the
scene
of
the
occurrence
or
of
the
persons
involved?
If
so,
state
the
date
or
dates
and
times
on
which
such
photographs
were
taken,
the
subjects
thereof,
who
took
said
photographs
and
who
has
custody
of
them
at
the
present
time.
ANSWER:
7.
Do
you
or
your
attorneys
have
any
statements
from
any
witness
or
party
other
than
yourself or,
if
a
corporation,
of anyone
other
than
an
officer,
director,
managing
agent
or
foreman?
If
so,
state:
(a)
The
name
and
address
of
each
such
party
or
witness;
(1)
The
date
of
each
of
said
statements;
(c)
Whether
such
statement
is typewritten,
handwritten
or
oral,
or
by
court
reporter,
and
state the
name
and
address
of
the
person
who
typewrote,
hand-wrote
or
was
the
court
reporter.
(d)
The
name,
address,
employer
and
occupation
of the
person
who
took
the
statement
an
in
whose
possession
the
statement
is
as
of
this
date.
ANSWER:
8.
List
the
names
and
addresses
of
all other
persons
(other than
yourself
and
person
heretofore listed or specifically
excluded)
who
have
knowledge
or
information
relating
to
facts
of
said
occurrences
of
noise
pollution
and/or
of
the
injuries and
damages
following therefrom.
ANSWER:
9.
State
all
facts
and/or
which
support
your
allegations
in
Paragraph
5
of
the
Complainants’
Complaint
for
the
violations
of the
above
stated
laws:
(a)
415
ILCS
5/24
(b)
35
Ill.
Admin
Code
Section
900.102
(c)
35
Ill.
Admin
Code
Section
901.102a
(d)
35
Ill.
Admin
Code
Section
901
.102b
(e)
35
Ill.
Admin
Code
Section
901.104;
and
(f)
Any
other
statute
or
administrative
regulation
you
allege
to
have
been
violated.
ANSWER:
10.
State
all
facts
and/or
which
support
your
allegations
in
Paragraph
6
of
the
Complainants’
Complaint
for
the
following
being
a nuisance:
(a)
24
Hour
Towing;
(b)
Truck/Auto
Repair;
(c)
Ventilation
Fan;
(d)
Engine
Noise;
and/or
(e)
Any
other
allegations
that
Respondent’s
activities
constitute
a
nuisance.
ANSWER:
10.
State
all facts
and/or
which
support
your
allegations
in
Paragraph
6 of
the Complainants’
Complaint
for
the
following
being
a violation
of
existing
noise
laws:
(a)
24 Hour
Towing;
(b) Truck/Auto
Repair;
(c)
Ventilation
Fan;
(d)
Engine
Noise;
and/or
(e) Any
other
allegations
that
Respondent’s
activities
constitute
a
violation
of
existing
noise
laws.
ANSWER:
11.
State
all
facts
and/or
which
support
your
allegations
in Paragraph
7 of the
Complainants’
Complaint
relative
to
the
duration
and
frequency
of the
alleged
pollution.
(a)
24 Hour
Towing;
(b)
Truck/Auto
Repair;
(c)
Ventilation
Fan;
(d)
Engine
Noise;
and/or
(e)
Any other
allegations
that Respondent’s
activities
constitute
a violation
of
existing
noise
laws.
12.
State
all
facts
and/or
which
support
your
allegations
in Paragraph
8
of
the Complainants’
Complaint relative
to the
effects
that
you
believe
that
the
alleged
pollution
has
had
on the
following:
(a)
Loss
of
Sleep
and/or
awaken
at early
hours(stating
dates
and
times)
(b)
Dates
and
Times
for
irritating
and
infuriating
noise;
(c)
Drop
in
Property
Value;
(d)
Emotional
Health
and
Well
being
(including
any
medical
reports)
(e)
Limitation
on
use
of outdoor property
(including
specific
dates
and
times);
and/or
(e)
Any
other
allegations
that
of
bad
effects
believed
to
be caused
by
the
alleged
pollution.
13.
Have
you
or
anyone
on
your
behalf
(including
any
expert)
conducted
any
test,
experiment,
and/or
scientific
study
from
which,
or the
results
of which,
you
will
attempt
to
introduce
into
evidence
in
a
trial
of
this
cause?
If so,
state:
(a)
The
name
of the
person
and/or
entity
conducting
said
test(s)
(b)
The
date
and
times
of
each
said
test(s)
(c)
The
results
of
each
of
said
test(s)
(d)
The
name
address
and
telephone
number
of all
individuals
and/or
entities
having
copies
of
the
results
of
said
tests.
ANSWER:
14.
Please
describe
fully
any
and
all
investigations
of the
incidents
(noise
pollution)
made
the
basis
of
this
Complaint
(other
than
those
privileged
by
law)
including
who
conducted
the
investigation,
when
the
investigation
was
conducted
and
the results,
findings
or conclusions
of
said
investigation.
If
you
are
claiming
privilege
as to
any
investigation,
based
on
its
allegedly
being
done
in anticipation
of
litigation,
describe
specifically
what
you
are
relying
on
to
establish
that
you
had
reason
to
believe
the litigation
would
ensue,
including
what
overt
acts
or
statements
were
made
by
plaintiff
or someone
acting
on
behalf
of
plaintiff.
ANSWER:
15.
With
respect
to
any
complaints,
inquiries,
police
reports,
or
any
other
type
of inquiry
presented
to
a
local
(municipal
or
county),
state
and/or
federal
authority
relative
to
the
noise
pollution
complained
of
including
but
not
limited
to
Village
zoning
board,
and/or
municipality
village
board;
correspondence
with
municipal
(village,
county,
state
and/or
federal
authorities
relating
to
the
alleged
noise
pollution
with
respect
to
each
such
inquiry
state
as
follows:
(a)
The
date(s)
of
said
complaints,
inquiries,
police
reports
or other
referral
to
the
governmental
entity;
(b)
The
names,
addresses
and
telephone
numbers
of the
specific
person(s)
and
that
you
dealt
with
respect
to
said
inquiry;
(c)
The
dates
of
any
meetings
with
any
officials
with
respect
to
said
inquiry
and
the
names,
addresses
and
telephone
numbers
of
person(s)
present
during
said
meeting;
(d)
The
names,
addresses
and
telephone
numbers
of
any
persons
that
joined
with
the
Complainants
in
making
the
inquiry;
(e)
The
results
of
said
inquiry
by
the
governmental
entity
and
any
recommendations
made
by
said
entity
to
the
Complainants,
the
Respondents,
and/or
other
persons
joining
in
said
inquiry.
ANSWER:
16.
With
respect
to
any
complaints,
inquiries,
police
reports,
or
any
other
type
of
inquiry
presented
to
a
local
(municipal
or
county),
state
anclJor
federal
authority
relative
to
the
noise
pollution
complained
of
including
but
not
limited
to
Village
zoning
board,
and/or
municipality
village
board;
correspondence
with
municipal
(village,
county,
state
and/or
federal
authorities
relating
to
the
zoning
application
made
to
the
Village of
Lake
Zurich
for the
Respondents’
property
with
respect
to
each
such
inquiry
state
as
follows:
(a)
The
date(s)
of
said
complaints,
inquiries,
police
reports
or
other
referral
to
the
governmental
entity;
(b)
The
names,
addresses
and
telephone
numbers
of
the
specific
person(s)
and
that
you
dealt
with
respect
to
said
inquiry;
(c)
The
dates
of
any
meetings
with
any
officials
with
respect
to
said
inquiry
and the
names,
addresses
and
telephone
numbers
of
person(s)
present
during
said
meeting;
(d)
The
names,
addresses
and
telephone
numbers
of
any
persons
that
joined
with
the
Complainants
in making
the
inquiry;
(e)
The
results
of
said
inquiry
by
the governmental
entity
and
any
recommendations
made
by
said
entity
to
the
Complainants,
the
Respondents,
and/or
other
persons
joining
in
said
inquiry.
ANSWER:
17.
With
respect
to
any
complaints,
inquiries,
police
reports,
or
any
other
type
of inquiry
presented
to
a
local
(municipal
or
county),
state
and/or
federal
authority
relative
to
the noise
pollution complained
of
including
but
not
limited
to
Village
zoning
board,
and/or
municipality
village
board;
correspondence
with
municipal
(village,
county,
state
and/or
federal
authorities
relating
to
alleged
noise
pollution
emanating
from
property
neighboring
the
Respondents’
property and/or
in the
vicinity
of
Respondents’
property
with
respect
to
each
such
inquiry
state
as
follows:
(a)
The
date(s)
of
said
complaints,
inquiries,
police
reports
or other
referral
to
the
governmental
entity;
(b)
The
names, addresses
and
telephone
numbers
of
the
specific
person(s)
and
that
you
dealt
with
respect
to
said
inquiry;
(c)
The
dates
of
any
meetings
with
any
officials
with
respect
to
said
inquiry
and
the
names,
addresses
and
telephone
numbers
of
person(s)
present
during
said
meeting;
(d)
The
names,
addresses
and
telephone
numbers
of any
persons
that
joined
with
the
Complainants
in
making
the
inquiry;
(e)
The
results
of
said
inquiry
by
the
governmental
entity
and
any
recommendations
made
by
said
entity
to
the
Complainants,
the
Respondents,
and/or
other
persons
joining
in
said
inquiry.
18.
If
Complainant(s),
or
any
agent
has
given
a
statement
to anyone other
than
defendant’s
attorney
with
respect
to
either
the
incidents
in question
and/or
the
damages
complained
of
by
the
Complainants,
please
state
the
name,
address,
and
telephone
number
of
the
person
to
whom
such
statement
was
given,
the
date
on
which
the
statement
was
given, the
substance
of
such
statement
and
whether
such
statement
was
a
written
or
oral
statement.
ANSWER:
19.
Have
you
(or
anyone
acting
on
your
behalf)
had
any
conversations
with
any
person
at
any
time
or
overhear
any
statements
made
by
any
person
at
any
time
with
regard
to the
manner
in
which the
incidents
complained
of
occurred?
If
so,
please
state
the
following:
(a)
Date(s)
of
such
conversations
and/or statements;
(b)
Place
of
such
conversations
and/or
statements;
(c)
Names,
addresses
and
telephone
numbers
of
all
persons
present
for
the
conversations
and/or
statements;
(d)
Matters
and/or
things
stated
and/or
discussed
by
said
persons
(e)
Whether
the
conversation
was
oral
and
if
so,
was
it
recorded
or
transcribed
or
was
the
statement
in
writing;
and/or
(f)
The
name,
address
and
telephone
number
of
each
person
that
has
possession
of the
statement or
recording
if
it was
written,
recorded
and/or
transcribed.
ANSWER:
20.
State
in detail
each
factual
observation
or finding
and
each
conclusion
drawn
based
upon
defendant’s
inspection
of the
area,
measurement
of
noise
level,
and/or
other
observations
relating
to the
source
of
any
alleged
noise
pollution.
ANSWER:
21.
State
the
name,
address
and
occupation
of
each individual
who
has
inspected,
measured
the
noise
levels
or
tested
the
area
in
question
relative
to noise
or
who
has performed
any
simulation
studies,
experiments,
or
other
tests
of
any kind
relevant
to this
Complaint
and
describe
each
such
inspection,
measurement,
test,
simulation,
and/or
study.
ANSWER:
22.
Pursuant
to
the
Illinois
Supreme
Court’s
revised
Rule
213,
furnish
the
identities
and
addresses
of
witnesses
who
will
testify
at
trial,
and
provide
the
following
information:
a)
Lay
Witnesses.
Please
identify
the
subjects
on
which
the
witness
will
testify;
b)
Independent
Expert
Witnesses.
Please
identify
the
subjects
on
which
the witness
will
testify
and
the
opinions
you
expect
to
elicit.
c)
Controlled
Expert
Witnesses.
Please
identify
the
following:
(i)
the
subject
matter
on
which
the
witness
will
testify;
(ii)
the
conclusions
and
opinions
of
the
witness
and
bases
therefor;
(iii)
the
qualifications
of the
witness;
and
(iv)
any
reports
prepared
by
the
witness
about
the
case.
ANSWER:
Paul
J.
Oleksak
Attorney
At
Law
100
Atkinson
Road,
Suite
11
OF
Grayslake, Illinois
60030
(847)
543-9000
Attorney
Number
Bruce
A.
Slivnick
Attorney
At
Law
707
Lake
Cook
Road,
Suite
316
Deerfield, Illinois
60015
(847)
714-0503
Attorney
Number
6181410
Attorneys for
Respondents
