A Sampling of Successes...

Described below are three successes that represent the leadership, detail-oriented, and management skills of Ms. Richardson.  Each litigation matter described demonstrates the extent of her litigation experience gained as lead assistant to chief counsel on complex litigation matters for corporate clients, including administrative and appellate matters.  Details follow below.

• DeKalb County Landfill Expansion:  Complex adjudication before a local decision maker, found in favor of client; decision affirmed by the Illinois Appellate Court.  Gathering of technical factual data, and preparation of primary case and expert witnesses, completed in 9 months.
• Wiillow Hill Landfill:  Expert objector case in opposition of a new facility.  Facility approval denied by local decision maker based on merits presented on behalf of client.  Facts of the case were obtained, strategy developed, and expert case presented, within 90 days.  Decision uncontested.
• Laraway Recycling & Disposal Facility Expansion and Phosphygypsum Remedial Action:  Adjudication of expanded disposal facility which included an environmental remedial action, receiving approval by local decision maker.  Decision affirmed by Illinois Appellate Court.

The DeKalb County Landfill is located in DeKalb, Illinois.  Expansion of the existing municipal solid waste disposal facility would serve as a disposal facility for collar counties of metropolitan Chicago.  CCLLC was hired to lead a team of engineers and scientists for this multi-million dollar project, providing direct assistance to the client and their outside legal counsel.  A multi-volume, 9,000+ page Site Location Application was prepared in nine short months, documenting all engineering design features and calculations, and a 500-acre geologic/hydrogeologic investigation.  In addition, a real estate analysis, solid waste needs evaluation, surrounding area character analysis, traffic impact study, and plan of operation were prepared by expert consultants.  The application was prepared in accordance with Illinois Environmental Protection Act, Section 39.2, relevant parts of Illinois Adm. Code 811 and the DeKalb County site location ordinance.  It was prepared to withstand legal scrutiny by opposing counsel and administrative and appellate courts.
 

The outsourcing structure of CCLLC made it cost-effective to meet client objectives:  working half-time during the initial months of data gathering and engineering design, attending meetings as needed, and sharing essential information electronically or via conference call.  And then, providing full-time onsite involvement for completion of the application.  Responsibilities included review of all expert consultant report documents, and performing detailed consistency reviews of all calculations, analyses, supporting written text and figures, and the engineering design and hydrogeologic plan set, with absolute consistency of data, terminology and presentation legally imperative.  Further, CCLLC provided coordination of scheduling, printing and assembly of all paper documents (required by local rules), and oversight of digital production of copies of the same (also, required by local rules).  All reviews were done in concert with the client and outside legal counsel, setting out litigation strategy throughout all project activities.  Subsequent to filing, CCLLC provided technical and presentation strategy assistance in preparation for a quasi-adjudicatory proceeding; including witness preparation, exhibits preparation, and lead litigation assistance at hearing.  Post-decision, CCLLC assisted legal counsel in the drafting, editing and final preparation of adjudicatory pleadings in support of the local approval, including Findings of Fact/Conclusions of Law, opening and response briefs for administrative appeal before the Illinois Pollution Control Board, and response brief and oral argument preparation before the Illinois Second District Court of Appeals.  Illinois Supreme Court denied objector's Motion for Leave to Appeal.  Ultimately, CCLLC contributed to the effective review, organization and strategy leading to site approval.

This approximate 720-acre greenfield municipal solid waste disposal facility was proposed in Kendall County, Illinois.  CCLLC was hired to lead a team of expert consultants, to review technical details of the proposed facility application and assist outside legal counsel in strategizing  a legal presentation before a quasi-adjudicatory hearing body, as objectors.  Coordination of the complex engineering and hydrogeologic technical review, development of an objector case strategy, and preparation of evidence and witness testimony, had to be completed and ready for presentation within the strict statutorily-defined 90 days.  An intense, strategic preparation was required to accomplish a cost-effective, compelling and persuasive case resulting in a successful outcome of local authority disapproval.  CCLLC's flexible structure allowed for extensive remote participation in all aspects of this complex corporate objector case, and continual coordination with experts located throughout the United States.
 

Extensive review of detailed engineering calculations, hydrogeologic field investigation analysis results and data, and evaluation of traffic, property value, and surrounding land use reports was required. Development of objector strategy, preparation of direct and cross-examination lines of questioning, coordination of evidentiary graphics, and review of statutory and regulatory compliance cases and statutes overlapped all technical review, resulting in an effective objector case, ready for presentation in just 90 days.  CCLLC's diverse experience in both engineering and litigation allowed for an immediate response to the client's stated objective despite the 90-day time period.  CCLLC was able to review technical documents, while also assisting supervising legal counsel, both pre and post-hearing, with technical strategy and discussion, witness preparation (direct and cross), opening statements and closing arguments, post-hearing memoranda and filings. 

This intense, high-stakes legal case required extremely well-coordinated and cost-effective efforts of an expensive team of legal staff, expert technical witnesses, and well-organized trial presentation.  CCLCC's experience and flexibility provided for streamlined activities, successful maintenance of critical path schedules associated with the legal strategy and case preparation, resulting in a cost-effective outcome of local site disapproval. 

The Laraway Recycling and Disposal Facility is located in Will County, Illinois.  The proposed pollution control facility included remediation of approximately 200 acres of two phosphogypsum stacks originating from historic detergent production, development of on-site soil biotreatment, and expansion of a solid waste disposal unit for construction and demolition debris, and non-hazardous special waste.  The unique remedial aspects of this project required careful technical consideration and incorporation into the overall design of the facility, all of which was prepared and presented to seek local site approval.
 

As an experienced technical and litigation outsource services company, CCLLC was hired to provide cost-effective, experienced expertise for technical review and editing of this highly technical project, review of all technical expert reports, coordination and oversight of complex document assembly, and detailed consistency reviews of all documents to withstand the scrutiny of legal objectors and administrative and appellate legal review.  CCLLC managed the coordination of all application documentary evidence, including figures, data tables, calculation and data appendices, design drawings and technical reports.  All activities were coordinated with outside counsel to incorporate legal strategy and maintain client financial objectives.  Post-filing, the knowledge of those technical reviews was utilized to support counsel as lead litigation assistant.  This included all witness preparation, development of direct and cross-examination lines of questioning, consistency of demonstrative and documentary exhibits, opening statements and closing arguments for adjudicative proceedings, and drafting of relevant fact-supported portions of post-hearing pleadings.   CCCLLC's management and coordination efforts contributed significantly in obtaining the desired local approval of this complex remedial development.