BEFORE THE

ILLINOIS

POLLUTION CONTROL

BOARD

0

LEIcs

OIIE

PEOPLE

OF

THE

STATE

OF

ILLINOIS

)

DEC.

STA

Complainant,

)

oIIutIon

v.

)

PCB

No.

04-0

16

)

(Enforcement)

PACKAGING PERSONIFIED,

Inc.,

)

an

Illinois

Corporation,

)

)

Respondent.

)

NOTICE

OF

DEPOSITION

Via

Facsimile

and

U.S.

Mail

TO:

Paula

Wheeler

Assistant

Attorney

General

Environmental

Bureau

69

West

Washington

Street,

18

th

Floor

Chicago,

Illinois

60602

(312)

814-5388

PLEASE

TAKE

NOTICE

that

on

Wednesday January

7,

2009,

Respondent,

PACKAGING PERSONIFIED,

INC.,

will take

the

discovery

deposition

of

Gary

Styzens.

The

deposition

will

take

place

at

the offices

of the

Illinois

Environmental

Protection

Agency,

1021

N.

Grand

Avenue

East,

Springfield,

Illinois

beginning

at

1:00

p.m.

This

deposition

shall

be

recorded

by

stenographic

means.

Deponent

shall

provide

prior

to

or

at his

deposition

the

documents described

in Rider

A.

Respectfully

submitted,

PACKAGING

PERSONIFIED,

INC.

By:____________

ne

of

Its Attorneys

Dated:

December

12, 2008

Roy

M.

Harsch

Drinker

Biddle

& Reath

LLP

191

North

Wacker

Drive,

Suite

3700

Chicago,

IL

60606

(312)

569-1441

(Phone)

CR01,

25272729.1

---

RIDER

A

Definitions

For

purposes

of

this

notice

of

deposition,

the

term

vldocumentH

is

used

in

the

broadest

sense.

It

refers,

without

limitation,

to

all

written,

printed,

typed,

photostatic,

photographed,

recorded,

or

otherwise

reproduced

communications,

date

compilations,

or

representations

of

every

kind, whether

comprised

of

letters,

words,

numbers,

pictures,

sounds

or

symbols,

whether

prepared

by

manual,

mechanical,

electronic,

magnetic,

photographic,

or

other

means,

as

well

as

audio,

video

or

other

recordings

of

communications,

oral

statements,

conversations,

or

events.

This

definition

includes,

but

is

not

limited

to,

any

and all

of

the

following:

correspondence,

notes,

minutes,

records,

messages,

memoranda,

telephone

memoranda,

diaries,

contracts,

agreements,

invoices,

orders,

acknowledgements,

receipts,

bills,

statements,

appraisals,

reports,

forecasts,

compilations,

schedules,

studies,

summaries,

analyses,

pamphlets,

brochures,

advertisements,

newspaper

clippings,

tables,

tabulations,

financial

statements,

working

papers,

tallies,

maps,

drawings,

diagrams,

pictures,

film,

microfilm,

microfiche,

computer-stored

or

computer-readable

data,

computer

programs,

computer

printouts,

telegrams,

telexes,

telefacsimiles,

tapes,

transcripts,

recordings,

and

all

other

sources

or

formats

from

which

data,

information,

or

communications

can be

obtained.

Documents

to

Be

Produced

A.

The most

comprehensive

and

up-to-date

curriculum

vitae

of

Gary

Styzens;

B.

Any and

all

reports,

letters,

memoranda,

correspondence

or

other

written

documents,

expressly

including

but

not

limited

to

any

drafts,

preliminary

versions

or

revisions

of

the

above,

which

in

any way

set

forth

the

opinions

of

Mr.

Styzens

relating

to

Respondent’s

economic

benefit

calculation;

C.

Any

and all

notes,

memoranda,

reports

or

other

documents,

expressly

including

but

not

limited

to

any

drafts,

preliminary

versions

or

revisions

of

the

above,

prepared

by

Mr.

Styzens

in

connection

with

this

matter;

D. Any and all

reports,

documents,

expressly

including

but

not

limited,

to

any

drafts,

preliminary

versions

or

revisions

of

the

above,

containing

facts

or

data

upon

which

Mr.

Styzens’

opinions,

theories,

conclusions,

or

estimates

are

based;

E. Documents

exhibiting

how

Mr.

Styzens

determined

the

economic

benefit

calculation;

and;

F.

Any

reference

materials

or

other

documents

that

Mr.

Styzens

consulted

in

determining

the

economic

benefit

calculation.

CHOI/

25272729.1

---

CERTIFICATE

OF

SERVICE

I,

Yesenia

Villasenor-Rodriguez,

an

attorney

hereby

certify that

on

December

12,

2008,

a

copy

of

the

foregoing

Notice

of Deposition

was

faxed

and

deposited

in

the

United

States

mail

before

the

hour

of 5:00

p.m.,

postage

prepaid

and

by facsimile

to:

Paula

Wheeler

Assistant

Attorney

General

Environmental

Bureau

69

West

Washington

Street,

18111

Floor

Chicago,

Illinois

60602

(312)

8l45388

LA

Y

enia

Villasenor-Rodriguez

CR01!

25272729.1