BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
IN THE MATTER OF:
RANDY GRANT
DONALD GRANT
PATRICIA WALLACE
Complainants,
v.
MACH MINING LLC
Respondent
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PCB 2007-145
MOTION TO WITHDRAW
NOW COMES Charles J. Northrup, attorney for Respondent, MACH MINING, LLC,
and hereby moves to withdraw
as counsel in this matter. In support, Movant states:
1.
Charles .T. Northrup and the law finn of Sorling, Northrup, Hanna, Cullen
&
Cochran, Ltd. have appeared in the above captioned matter as attorney for Respondent.
2.
Charles.T. Northrup has accepted a legal position with a not-for-profit association
and will no longer be engaged in the private practice oflaw. The scope of his duties at his new
employer,
as well as the tem1S of that new employment, will not allow him to devote any time or
resources
to continuing representation ofprivate clients, including the Respondent in this matter.
3.
Charles J. NOlihrup has advised Respondent of his intent to withdraw and has
given notice
of this action.
{SOSSi 192,2
5/2212008
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Printed on Recycled Paper
Electronic Filing - Received, Clerk's Office, May 22, 2008
4.
Charles
.J.
Northrup has, consistent with Supreme Court of Illinois Rule of
Professional Conduct
1.16(
dl taken reasonable steps to avoid foreseeahle prejudiee to the
Respondent including giving notice
of this Motion.
5.
All notices and official papers in this matter should be sent to:
Ms. Claire Manning
Brown, Hay
&
Stephens, LLP
205
S. 5
th
St.
Springfield, IL 62701
WHEREFORE, Charles
.T. Nortlmlp respectfully requests that this tribunal allow him to
withdraw fyom this malter, and for any other relief this tribunal deems appropriate.
Respectfully submitted,
Sorling, Northrup, Hanna,
Cullen
&
Cochran, Ltd.
Charles
.T. Northrup, of Counsel
Suite 800 Illinois Building
P.O. Box 5131
Springfield, IL 62705
Telephone: 217.544.1144
Fax: 217.522.3173
E-Mail:
S0581192.2 5/22/2008 CIN ELF
2
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on
Recycled Paper
Electronic Filing - Received, Clerk's Office, May 22, 2008
PROOF OF SERVICE
The undersigned hereby certifies that a copy of the foregoing Motion to Withdraw was
served
by O.S. mail addressed:
Ms. Patricia Wallace
17235 Liberty School
Road
Marion. lL 62959
Mr. Randy Grant
17235 Liberty School Road
Marion.
IL 62959
Mr. Donald Grant
17712 Dean Road
Johnston City,
IL
62951
Mr. James Plumley
Williamson Energy
P. O. Box 300
Johnston City,
IL
62951
with all postage prepaid on the
":I;;3,)c,,1
day of
-~)I'+~i'.../\,
(7) __,2008.
SOS8Il92.2
5/22/2008
CJN ELF
3
Printed on Recycled Paper
Electronic Filing - Received, Clerk's Office, May 22, 2008
