ESH:psvr 46417-7AREFORE THELAND AND LAI.GS COMPANY.
The County Board cites Section
103J22(c) of the Board's proceduralnrles in support of its position.
As the Board
noted in another siting appeal, Illinois does not require a petitioner to plead all factsspecifically in the petition, but to set out ultimate facts which support his cause of action.
Irl.
To require all facts to be pled in the petition for revierv would
negate the value of discovery, which is on-going in this case under the hearing officer'sscheduling directions.
Respectfu Ily submi tted,
LAND AND LAKES COMPANY6.Elizabeth S. HarveyMcKenna, Storer, Rolve, White & Farrug200 N. LaSalle Street, Suite...
Allowed
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