ED
    SEP
    112009
    STATE
    OF
    ILLINOIS
    OFFICE
    OF THE
    ATTORNEY
    GENERAL
    OIIUti
    Control
    Board
    STATE
    OF
    ILLINOIS
    Lisa
    Madigan
    ATTORNEY
    GENERAL
    September
    9,
    2009
    John
    T.
    Therriault,
    Assistant
    Clerk
    Illinois
    Pollution
    Control
    Board
    James
    R. Thompson
    Center,
    Ste.
    11-500
    100
    West
    Randolph
    Chicago,
    Illinois
    60601
    Re:
    People
    v. Tate
    and
    Lyle
    PCB
    NO.
    09-107
    Dear
    Clerk:
    Enclosed
    for
    filing
    please
    find
    the
    original
    and
    five copies
    of a Notice
    of
    Filing
    and Joint
    Proposed
    Discovery
    Schedule
    in regard
    to
    the above-captioned
    matter.
    Please
    file the
    originals
    and
    return
    file-stamped
    copies
    to
    me
    in
    the
    enclosed,
    self-addressed
    envelope.
    Thank
    you
    for
    your
    cooperation
    and consideration.
    Very
    truly
    yours,
    Stephen
    . J nasie
    Environmental
    Bureau
    500
    South
    Second
    Street
    Springfield,
    Illinois
    62706
    (217)
    782-9031
    SJJ/pk
    Enclosures
    500 South
    Second
    Street,
    Springfield,
    Illinois
    62706
    • (217) 782-1090
    T’T’Y: (877)
    844-5461
    • Fax:
    (217)
    782-7046
    100 West
    Randolph
    Street,
    Chicago,
    Illinois
    60601 •
    (312)
    814-3000
    TFY: (800)
    964-3013
    • Fax: (312)
    814-3806
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    fl,,rh
    TiBn,,
    2Qhl1
    • (f1S
    2Q..SdO(1
    • 9’T’V.
    (R77
    ic7QO
    (,clu 7O
    d1

    BEFORE
    THE
    ILLINOIS
    POLLUTION
    CONTROL
    BOARD
    PEOPLE
    OF
    THE
    STATE
    OF ILLINOIS,
    )
    LElk’s
    OFFICE
    Complainant,
    )
    SE,
    112009
    STAT6
    OF
    ILLINOIC.
    vs.
    )
    PCB
    No.
    09-1 07
    pollution
    Control
    BOd
    )
    (Enforcement-Air)
    TATE
    AND
    LYLE
    INGREDIENTS
    AMERICAS,
    INC.,
    an
    Illinois
    corporation,
    Respondent.
    NOTICE
    OF FILING
    To
    James
    L
    Curtis
    Jeryl
    Olson
    Elizabeth
    Leifel
    Ash
    Seyfarth
    Shaw
    LLP
    131 South
    Dearborn
    Street,
    Suite
    2400
    Chicago,
    IL 60603-5803
    PLEASE
    TAKE NOTICE
    that on
    this
    date
    I
    mailed
    for
    filing
    with the
    Clerk
    of the Pollution
    Control
    Board
    of the
    State
    of
    Illinois,
    a
    JOINT
    PROPOSED
    DISCOVERY
    SCHEDULE, a copy
    of
    which
    is
    attached
    hereto
    and
    herewith
    served
    upon
    you.
    Respectfully
    submitted,
    PEOPLE
    OF
    THE STATE
    OF
    ILLINOIS
    LISA
    MADIGAN,
    Attorney
    General
    of the
    State
    of
    Illinois
    MATTHEWJ.
    DUNN,
    Chief
    Environmental
    Enforcement/Asbestos
    Litigation
    DivisLen
    1
    BY:________
    sTE’[i1
    .WJANASIE
    Assistant
    Attorney
    General
    Environmental
    Bureau
    500
    South
    Second
    Street
    Springfield,
    Illinois
    62706
    217/782-9031
    Dated:
    September
    9, 2009

    EçEgVE
    CLERK’S
    OFFICE
    CERTIFICATE
    OF SERVICE
    SEP
    11
    2009
    STATE
    OF
    ILLINOIS
    Pollution
    Control
    Board
    I hereby
    certify
    that I did
    on September
    9,
    2009,
    send by
    First
    Class Mail,
    with postage
    thereon
    fully prepaid,
    by
    depositing
    in
    a
    United
    States
    Post
    Office
    Box
    a
    true
    and
    correct copy
    of
    the
    following
    instruments
    entitled NOTICE
    OF
    FILING and
    JOINT PROPOSED
    DISCOVERY
    SCHEDULE
    To:
    James
    L Curtis
    Jeryl
    Olson
    Elizabeth
    Leifel
    Ash
    Seyfarth
    Shaw
    LLP
    131 South
    Dearborn
    Street,
    Suite 2400
    Chicago, IL
    60603-5803
    and
    the
    original
    and
    five
    copies
    by
    First
    Class Mail
    with postage
    thereon
    fully prepaid
    of the
    same foregoing
    instrument(s):
    To:
    Dorothy
    Gunn,
    Clerk
    Illinois
    Pollution
    Control
    Board
    James
    R. Thompson
    Center
    Suite 11-500
    100 West
    Randolph
    Chicago,
    Illinois 60601
    A
    copy
    was also
    sent
    by First Class
    Mail with
    postage
    thereon
    fully prepaid
    to:
    Carol Webb
    Hearing
    Officer
    Illinois
    Pollution Control
    Board
    1021
    North
    Grand
    Avenue
    East
    Springfield,
    IL 62794
    STEPHNJ/JA
    SIE
    Assistant
    Attorney
    General
    This filing
    is submitted
    on recycled
    paper.

    BEFORE
    THE ILLINOIS
    POLLUTION CONTROL
    BOARD
    CLEVD
    PEOPLE OF THE
    STATE OF
    ILLINOIS,
    )
    EP
    )
    12009
    STATE
    OF
    ILLlN’
    Complainant,
    )
    OI(utjon
    Control
    )
    vs.
    )
    PCB
    No.
    2009-107
    )
    (Enforcement
    Air)
    TATE AND
    LYLE
    iNGREDIENTS
    )
    AMERICAS,
    iNC , an Illinois
    corporation,
    )
    )
    Respondent
    )
    JOINT PROPOSED
    DISCOVERY
    SCHEDULE
    NOW COMES Complainant, People
    of
    the State of Illinois,
    by
    attorney,
    LISA
    MADIGAN, Attorney General
    of the State of Illinois, and Respondent, TATE AND LYLE
    INGREDIENTS AMERICAS, INC., pursuant
    to
    the August
    i8,
    2009 Order
    of the
    Hearing
    Officer, and propose and agree to the
    following
    discovery schedule
    in the
    above-captioned matter:
    1.
    Written interrogatories and
    document requests
    shall
    be
    issued
    by
    the
    parties on or before October 15, 2009;
    2.
    All responses to written interrogatories and document requests shall be
    served
    on
    or
    before November 15, 2009;
    3.
    Depositions
    of
    lay or
    fact witness shall
    be
    completed
    on or before
    January
    15, 2010
    4.
    Complainant’s
    written expert witness
    disclosures
    shall be served on or
    before
    February
    15, 2010;
    5.
    Respondent’s written expert witness disclosures shall
    be served on or
    before
    March 15, 2010;
    6.
    Depositions of expert witnesses shall
    be completed
    on
    or
    before April
    i,
    2010;
    7.
    Requests for admission of fact shall
    be served on or
    before
    February 15,
    2010;
    8.
    Dispositive motions
    shall
    be
    filed on or
    before May
    15,
    2010.
    CHi 117772271

    I
    In the
    event there is
    a discovery dispute,
    the Hearing Officer
    may
    adjust
    the
    schedule
    as needed.
    Date://
    9
    By:________________________
    Stephen
    . Janasie
    Environmental
    Bureau
    Assistant Attorney
    General
    500
    South Second
    Street
    Springfield,
    Illinois
    62706
    By:
    mecu:i?
    Elizabeth
    Leifel
    Ash
    Seyfarth
    Shaw LLP
    131
    South
    Dearborn
    Street
    Suite
    2400
    Chicago,
    IL 60603-5803
    Counsel for
    Respondent
    CHI 11777227,1

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