Donald J. Moran
Abad Lopez
Pedersen & Houpt
161 North Clark Street, Suite 3100
Chicago, IL 60601
Telephone: (312) 641-6888
429068 .1
B
PLEASE TAKE NOTICE that on February 16, 2006, we caused to be filed with the Illinois
Pollution Control Board in the James R. Thompson Center, Chicago, Illinois, MOTION FOR
WITHDRAWAL (OF REPRESENTATION), a copy of which is attached and hereby served upon you .
Respectfully submitted,
RIVER EAST L.L.C. AND CHICAGO
DOCK
CANAL TRUST
RECEIVED
BEFORE THE ILLINOIS
CLERK'S OFFICE
POLLUTION CONTROL BOARD
FEB 1 6 2006
GRAND PIER CENTER LLC and
AMERICAN INTERNATIONAL
SPECIALTY LINES INSURANCE CO
.
as subrogee of Grand Pier Center, LLC
Complainants
)
V .
PCB 05
- 157
(Enforcement)
RIVER EAST LLC
)
CHICAGO DOCKAND CANAL TRUST
)
STATE OF ILLINOIS
Pollution Control Board
CHICAGO DOCKAND CANAL COMPANY)
KERR-MCGEE CHEMICAL LLC
)
Respondents
NOTICE OF FILING
Frederick S . Mueller
Michael P. Connelly
Bradley Halloran
Daniel C. Murray
Garret C. Carter
Hearing Officer
Garrettt L. Boehm, Jr.
Connelly Roberts & McGivney
Illinois Pollution Control Board
Johnson & Bell, Ltd.
LLC
James R. Thompson Center
33 West Monroe Street
One North Franklin Street,
Suite 11-500
Suite 2700
Suite 1200
Chicago, Illinois 60601
Chicago, Illinois 60603
Chicago, IL 60606
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
RECEIVED
'OFFICE
GRAND PIER CENTER LLC and
CLERKS
)
AMERICAN INTERNATIONAL
E 16 FFI
)
2006
SPECIALTY LINES INSURANCE CO
.
)
STATE OF
ILLINOIS
as subrogee of Grand Pier Center, LLC
)
Pollution Control Board
Complainants
)
v
.
)
PCB 05 - 157
(Enforcement)
RIVER EAST LLC
)
CHICAGO DOCK AND CANAL TRUST
)
CHICAGO DOCK AND CANAL COMPANY)
KERR-MCGEE CHEMICAL LLC
)
Respondents
)
MOTION FOR WITHDRAWAL (OF REPRESENTATION)
NOW COMES, PEDERSEN & HOUPT, as attorneys of record for RIVER EAST L.L.C .,
CHICAGO DOCK and CANAL TRUST (collectively "River East"), and hereby Move to Withdraw
as Attorneys of Record for River East in the above captioned case, and in support thereof state as
follows :
1
.
Pedersen & Houpt is currently counsel of record for River East in the above captioned
case .
2 .
Over the past few months, River East has been unable to pay the amounts due to
Pedersen & Houpt for their representation in the above captioned case and upon information and
belief will be unable to make any future payments . Despite efforts to resolve these issues, the unpaid
amounts prevent Pedersen & Houpt from being able to carry out its duties as counsel
.
3 .
Pedersen & Houpt requests that this Honorable Court grant it leave to withdraw its
428316 . 1
Appearance of Record on behalf of River East
.
Dated: February 16, 2006
Donald J. Moran
Abad Lopez
Pedersen & Houpt
161 North Clark Street
Suite 3100
Chicago, IL 60601
Telephone: (312) 641-6888
428316. 1
Respectfully submitted,
RIVER EAST L.L.C. AND CHICAGO
DOCK AND CANAL TRUST
By :
Sa
CERTIFICATE OF SERVICE
I, Abad Lopez, an attorney, on oath certify that I caused to be served the foregoing
Motion for Withdrawal (of Representation), upon the following counsel of record :
by U.S. mail delivery by depositing said document into the United States mail at 161 North Clark
Street, Chicago, Illinois, proper postage paid, at or before 5 :00 p.m. this 16th day of February
2006 .
429068.1
-2-
By :
S i I
W
.Or
o
.r
opez
Frederick S . Mueller
Michael P. Connelly
Bradley Halloran
Daniel C. Murray
Garret C. Carter
Hearing Officer
Garrettt L. Boehm, Jr .
Connelly Roberts &
Illinois Pollution Control
Johnson & Bell, Ltd .
McGivney LLC
Board
33 West Monroe Street
One North Franklin Street,
James R. Thompson Center
Suite 2700
Suite 1200
Suite 11-500
Chicago, Illinois 60603
Chicago, IL 60606
Chicago, Illinois 60601
