BEFORE

THE

ILLINOIS

POLLUTION

CONTROL

BOARD

PEOPLE

OF THE

STATE

OF

ILLINOIS

)

Complainant,

)

IAN

2

v.

)

PCB

No.

04-016

ir%

‘ILLINO,

)

(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

21,

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:

January

12,

2009

Roy

M.

Harsch

Drinker

Biddle

&

Reath

LLP

191 North Wacker

Drive,

Suite

3700

Chicago,

IL

60606

(312)

569-1441

(Phone)

(312)

569-3441

(Facsmile)

---

RIDER

A

Definitions

For

purposes

of

this

notice

of

deposition,

the

term

“document”

is

used

in

the

broadest

sense.

It

refers,

without

limitation,

to all

written,

printed,

typed, photostatic,

photographed,

recorded,

or

othenvise

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

or

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

or

relied

upon

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;

including

capital

and

operational

costs

used

in

his

report,

and

how

such

was

determined;

F.

Any

correspondence

to

and

from

Mr.

Styzens, including

other

employers

at

the

IEPA,

or

Attorney

General’s

Office,

or

any

other

person

or

entity

regarding

Mr.

Styzens

economic

benefit

calculation;

G.

All

reference

materials,

and

supporting

documents

containing

information

that

Mr.

Styzens

utilized

in

determining

the

economic

benefit calculation.

---

CERTIFICATE

OF

SERVICE

I,

Yesenia

Villasenor-Rodriguez,

an

attorney

hereby

certify

that

on January

12,

2009,

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,

l8t1

Floor

Chicago,

Illinois

60602

(312)814-5388

enia

Villasenor-Rodrig

z

CHOI/

25272729.3