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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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