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IN THE CIRCUIT COURT OF THE NINETEENTH JUDICIAL CIRCUIT, LAKE COUNTY, ILLINOIS THE DEPARTMENT OF TRANSPORTATION OF THE STATE OF ILLINOIS, FOR AND ON BEHALF OF THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff, v. ERLENBORN ENTERPRISES LIMITED PARTNERSHIP, AN ILLINOIS LIMITED PARTNERSHIP; and UNKNOWN OWNERS and NON-RECORD CLAIMANTS, generally, Defendants. Case No. 16ED36 Condemnation Parcel: 1LC0027A, 1LC0027B, 1LC0027TE-A, 1LC0027TE-B, 1LC0027TE-C Job No. R-91-026-13 JURY DEMAND PUBLICATION NOTICE The requisite Affidavit for Service by Publication having been filed, notice is hereby given to you, ERLENBORN ENTERPRISES LIMITED PARTNERSHIP, an Illinois limited Partnership; and UNKNOWN OWNERS and NON-RECORD CLAIMANTS, in this cause, that the Illinois Department of Transportation has filed its Complaint for Condemnation in the Circuit Court of the Nineteenth Judicial Circuit in Lake County, Illinois, for condemnation pursuant to the eminent domain laws of the State of Illinois, of the lands and premises in the Complaint situated in Lake County, State of Illinois, attached as Exhibits A through E. EXHIBIT A Route: U.S. Route 45 Section: Millburn Bypass County: Lake Job No.: R-91-026-13 Parcel No.:1LC0027A Sta. 165+12.29 To 171+85.64 PIN: 02-25-400-012 That part of the Southeast Quarter of Section 25, Township 46 North, Range 10 East of the Third Principal Meridian, in Lake County, Illinois, bearings and distances based on the Illinois State Plane Coordinate System, East Zone, NAD83 (2011 Adjustment), with a combined factor of 0.9998952584, described as follows: commencing at the Northeast Corner of the South 6.67 Chains of said Southeast Quarter; thence North 89 Degrees 32 Minutes 09 Seconds West along the North Line of said 6.67 Chains (Line also known as the north Line of the South 20 acres of that part of the South Half of the Southeast Quarter of said Section 25 which lies Westerly of the Center of a Road [U.S. Route 45]), a distance of 795.23 feet to Center of said Road for the Point of Beginning; thence continuing North 89 Degrees 32 Minutes 09 Seconds West along said North Line, a distance of 334.45 feet; thence North 02 Degrees 59 Minutes 59 Seconds West, a distance of 20.41 feet; thence North 11 Degrees 10 Minutes 48 Seconds West, a distance of 521.92 feet to a point of curvature; thence Northerly along a curve concave Easterly, having a Radius of 13,202.75 feet and a 64.11 foot chord, bearing North 11 Degrees 02 Minutes 27 Seconds West, for an arc length of 64.11 feet to a LIne 1, 612.73 feet South of and parallel with the North Line of said Southeast Quarter; thence South 89 Degrees 37 Minutes 31 Seconds East along said Line, a distance of 148.79 feet to said Center of Road; thence Southeasterly along said Center of Road the following two (2) courses: (1) thence Southeasterly along a curve concave Northeasterly, having a Radius of 2,291.89 feet and a 147.45 chord, bearing South 25 Degrees 23 Minutes 37 Seconds East, for an arc length of 147.47 feet to a point of tangency; (2) thence South 27 Degrees 03 Minutes 36 Seconds East, a distance of 520.88 feet to the Point of Beginning. Said parcel containing 3.251 acres, more or less, of which 0.911 acres, more or less, was previously dedicated or used for highway purposes. EXHIBIT B Route: U.S. Route 45 Section: Millburn Bypass County: Lake Job No.: R-91-026-13 Parcel No.:1LC0027B Sta. 173+39.83 To 177+98.30 PIN: 02-25-400-012 That part of the Southeast Quarter of Section 25, Township 46 North, Range 10 East of the Third Principal Meridian, in Lake County, Illinois, bearings and distances based on the Illinois State Plane Coordinate System, East Zone, NAD83 (2011 Adjustment), with a combined factor of 0.9998952584, described as follows: commencing at the Northeast Corner of the South 6.67 Chains of said Southeast Quarter; thence North 89 Degrees 32 Minutes 09 Seconds West along the North Line of said 6.67 Chains (Line also known as the north Line of the South 20 acres of that part of the South Half of the Southeast Quarter of said Section 25 which lies Westerly of the Center of a Road [U.S. Route 45]), a distance of 1,129.68 feet; thence North 02 Degrees 59 Minutes 59 Seconds West, a distance of 20.41 feet; thence North 11 Degrees 10 Minutes 48 Seconds West, a distance of 521.92 feet to a point of curvature; thence Northerly along a curve concave Easterly, having a Radius of 13,202.75 feet and a 64.11 foot chord, bearing North 11 Degrees 02 Minutes 27 Seconds West, for an arc length of 64.11 feet to a Line 1,612.73 feet South of and parallel with the North Line of said Southeast Quarter; thence South 89 Degrees 37 Minutes 31 Seconds West along said Line, a distance of 461.12 feet; thence North 00 Degrees 42 Minutes 33 Seconds West, a distance of 150.15 feet; thence North 87 Degrees 59 Minutes 12 Seconds East, a distance of 421.84 feet to the Point of Beginning; thence Northerly along a curve concave Easterly, having a Radius of 13, 212.75 feet and a 93.40 foot chord, bearing North 09 Degrees 57 Minutes 00 Seconds West, for an arc length of 93.40 feet; thence North 80 Degrees 15 Minutes 09 Seconds East, a distance of 10.00 feet to a point on a curve; thence Northerly along a curve concave Easterly, haiving a Radius of 13,202.75 feet and a 299.55 foot chord, bearing North 09 Degrees 05 Minutes 51 Seconds West, for an arc length of 299.56 feet; thence North 81 Degrees 33 Minutes 09 Seconds East, a distance of 80.00 feet to said Center of Road, at a point of tangency of said Center of Road; thence Southeasterly along said Center of Road, being a curve concave Northeasterly, having a Radius of 2,291.89 feet and a 408.68 foot chord, bearing South 13 Degrees 47 Minutes 13 Seconds East, for an arc length of 409.22 feet; thence South 87 Degrees 59 Minutes 12 Seconds West, a distance of 122.95 feet to the Point of Beginning. Said parcel containing 0.854 acres, more or less, of which 0.545 acres, more or less, was previously dedicated or used for highway purposes. EXHIBIT C Route: U.S. Route 45 Section: Millburn Bypass County: Lake Job No.: R-91-026-13 Parcel No.:1LC0027TE-A Sta. 167+50.00 To 171+86.66 PIN: 02-25-400-012 That part of the Southeast Quarter of Section 25, Township 46 North, Range 10 East of the Third Principal Meridian, in Lake County, Illinois, bearings and distances based on the Illinois State Plane Coordinate System, East Zone, NAD83 (2011 Adjustment), with a combined factor of 0.9998952584, described as follows: commencing at the Northeast Corner of the South 6.67 Chains of said Southeast Quarter; thence North 89 Degrees 32 Minutes 09 Seconds West along the North Line of said 6.67 Chains (Line also known as the north Line of the South 20 acres of that part of the South Half of the Southeast Quarter of said Section 25 which lies Westerly of the Center of a Road [U.S. Route 45]), a distance of 1,129.68 feet; thence North 02 Degrees 59 Minutes 59 Seconds West, a distance of 20.41 feet; thence North 11 Degrees 10 Minutes 48 Seconds West, a distance of 150.00 feet to the Point of Beginning; thence South 78 Degrees 49 Minutes 12 Seconds West, a distance of 5.00 feet; thence North 11 Degrees 10 Minutes 48 Seconds West, a distance of 437.09 feet to a Line 1,612.73 feet South of and parallel with the North Line of said Southeast Quarter; thence South 89 Degrees 37 Minutes 31 Seconds East along said Line, a distance of 5.26 feet to a point on a curve; thence Southerly along a curve concave Easterly, having a Radius of 13,202.75 feet and a 64.11 foot chord, bearing South 11 Degrees 02 Minutes 27 Seconds Eastt, for an arc length of 64.11 feet to a point of tangency; thence South 11 Degrees 10 Minutes 48 Seconds East, a distance of 371.92 feet to the Point of Beginning. Said parcel containing 0.050 acres, more or less. EXHIBIT D Route: U.S. Route 45 Section: Millburn Bypass County: Lake Job No.: R-91-026-13 Parcel No.:1LC0027TE-B Sta. 173+57.28 To 173+68.70 PIN: 02-25-400-012 That part of the Southeast Quarter of Section 25, Township 46 North, Range 10 East of the Third Principal Meridian, in Lake County, Illinois, bearings and distances based on the Illinois State Plane Coordinate System, East Zone, NAD83 (2011 Adjustment), with a combined factor of 0.9998952584, described as follows: commencing at the Northeast Corner of the South 6.67 Chains of said Southeast Quarter; thence North 89 Degrees 32 Minutes 09 Seconds West along the North Line of said 6.67 Chains (Line also known as the North Line of the South 20 acres of that part of the South Half of the Southeast Quarter of said Section 25 which lies Westerly of the Center of a Road [U.S. Route 45]), a distance of 1,129.68 feet; thence North 02 Degrees 59 Minutes 59 Seconds West, a distance of 20.41 feet; thence North 11 Degrees 10 Minutes 48 Seconds West, a distance of 521.92 feet to the point of curvature; thence NOrtherly along a curve concave Easterly, having a Radius of 13,202.75 feet and a 64.11 foot chord, bearing North 11 Degrees 02 Minutes 27 Seconds West, for an arc length of 64.11 feet to a Line 1,612.73 feet South of and parallel with the North Line of said Southeast Quarter; thence North 89 Degrees 37 Minutes 31 Seconds West along said Line, a distance of 461.12 feet; thence North 00 Degrees 42 Minutes 33 Seconds West, a distance of 150.15 feet; thence North 87 Degrees 59 Minutes 12 Seconds East, a distance of 373.60 feet to the Point of Beginning; thence North 00 Degrees 07 MInutes 46 Seconds West, a distance of 4.78 feet; thence North 86 Degrees 52 Minutes 14 Seconds East, a distance of 47.53 feet to a point on a curve; thence Southerly along a curve concave Easterly, having a Radius of 13,212.75 feet and a 5.76 foot chord, bearing South 10 Degrees 08 Minutes 24 Seconds East, for an arc length of 5.76 feet; thence South 87 Degrees 59 Minutes 12 Seconds West, a distance of 48.24 feet to the Point of Beginning. Said parcel containing 0.006 acres (251 square feet), more or less. EXHIBIT E Route: U.S. Route 45 Section: Millburn Bypass County: Lake Job No.: R-91-026-13 Parcel No.:1LC0027TE-C Sta. 174+50.00 To 177+00.00 PIN: 02-25-400-012 That part of the Southeast Quarter of Section 25, Township 46 North, Range 10 East of the Third Principal Meridian, in Lake County, Illinois, bearings and distances based on the Illinois State Plane Coordinate System, East Zone, NAD83 (2011 Adjustment), with a combined factor of 0.9998952584, described as follows: commencing at the Northeast Corner of the South 6.67 Chains of said Southeast Quarter; thence North 89 Degrees 32 Minutes 09 Seconds West along the North Line of said 6.67 Chains (Line also known as the North Line of the South 20 acres of that part of the South Half of the Southeast Quarter of said Section 25 which lies Westerly of the Center of a Road [U.S. Route 45]), a distance of 1,129.68 feet; thence North 02 Degrees 59 Minutes 59 Seconds West, a distance of 20.41 feet; thence North 11 Degrees 10 Minutes 48 Seconds West, a distance of 521.92 feet to the point of curvature; thence Northerly along a curve concave Easterly, having a Radius of 13,202.75 feet and a 64.11 foot chord, bearing North 11 Degrees 02 Minutes 27 Seconds West, for an arc length of 64.11 feet to a Line 1,612.73 feet South of and parallel with the North Line of said Southeast Quarter; thence North 89 Degrees 37 Minutes 31 Seconds West along said Line, a distance of 461.12 feet; thence North 00 Degrees 42 Minutes 33 Seconds West, a distance of 150.15 feet; thence North 87 Degrees 59 Minutes 12 Seconds East, a distance of 421.84 feet; thence Northerly along a curve concave Easterly, having a Radius of 13,212.75 feet and a 93.40 foot chord, bearing North 09 Degrees 57 Minutes 00 Seconds West, for an arc length of 93.40- feet; thence North 80 Degrees 15 Minutes 09 Seconds East, a distance of 5.00 feet to the Point of Beginning; thence Northerly along a curve concave Easterly, having a Radius of 13,207.75 feet and a 251.61 foot chord, bearing North 09 Degrees 12 Minutes 06 Seconds West, for an arc length of 251.62 feet; thence North 81 Degrees 20 Minutes 38 Seconds East, a distance of 5.00 feet to a point on a curve; thence Southerly along a curve concave Easterly, having a Radius of 13,202.75 feet and a 251.52 chord, bearing South 09 Degrees 12 Minutes 06 Seconds East, for an arc length of 251.52 feet; thence South 80 Degrees 15 Minutes 09 Seconds West, a distance of 5.00 feet to the Point of Beginning. Said parcel containing 0.029 acres, more or less. Summons was duly issued out of said court against you as provided by law and such cause is now pending. The aforesaid Complaint for Condemnation is for the ascertainment of the just compensation to be paid to the owner or owners for the fee simple title to the real property designated as Parcel 1LC0027A and Parcel 1LC0027B and three (3) temporary easements for construction purposes for a period not to exceed five (5) years from the date of vesting of title or until completion of construction operations, whichever occurs first, across and upon real property designated as Parcel 1LC0027TE-A, Parcel 1LC0027TE-B, and Parcel 1LC0027TE-C, sought to be acquired for the purpose of the improvement of US Route 45 at Millburn Pass in Lake County, Illinois. NOW THEREFORE, unless you, the above named defendants, file your appearance in this cause, in the office of the Clerk of the Circuit Court of the Nineteenth Judicial Circuit 18 North County Street, Waukegan, Illinois, on or before the 10th day of November, 2016 default may be entered against you at any time after that day, or the case may be tried at any time after said date, and a judgment entered in accordance with the prayer of said Complaint. Dated: September 1, 2016 /s/ Keith Brin, Clerk of the Circuit Court of the Nineteenth Judicial Circuit, Lake County, Illinois Antonia S. Pritchard, Special Assistant Attorney General, Attorney for: Plaintiff Walker Wilcox Matousek, LLP, One N. Franklin Street Suite 3200,Chicago, Illinois 60606,Phone(312)244-6700 Atty. No.: 6207786 Published in Daily Herald September 11, 18, 25, 2016 (4451584) , posted 09/11/2016
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