RECEIVEDto
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AUG 1 4 2001
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BEFORE THE ILLINOIS POLLUTION CONTROL
BOA~ludonLATE
OF
Control
ILLINOIS
ILLINOIS
COLE TAYLOR BANK, not individually,
but solely as trustee under a certain Illinois
land trust known as trust 40323 ; as
successor trustee to Michigan Avenue
National Bank of Chicago, under trust 1904,
Complainant,
)
vs.
)
ROWE INDUSTRIES, INC ., a corporation,
)
successor to COLEMAN CABLE AND WIRE )
COMPANY, a corporation, and CHAPCO )
CARTON COMPANY, a corporation,
)
Respondents .
)
NOTICE OF FILING
TO: William Speary
Raymond T . Reott
Much Shelist Freed Denenberg
Christina M . Landgraf
Ament Bell & Rubenstein PC
Jenner & Block LLC
200 North LaSalle Street, Suite 2100
One IBM Plaza
Chicago, Illinois 60601
Chicago, Illinois 60611
PLEASE TAKE NOTICE that I have today filed with the Clerk of the Illinois Pollution
Control Board a Motion for Substitution of Counsel, a copy of which is attached hereto and served
upon you.
COLE TAYLOR BANK,
not individually but solely as trustee under a certain Illinois land
trust known as trust 40323 ; as successor trustee to Michigan
Avenue Natio
Bank Chicago, under trust 1904
By:
One of Its Attorneys
Gerald B
. Mullin
Gerald B . Mullin, P .C .
55 East Monroe Street, Suite 3030
Chicago, Illinois 60603
(312) 456-4975
PCB 01-173
Citizen's Enforcement
CERTIFICATE OF SERVICE
I, the undersigned, an attorney, certify that I caused a copy of the foregoing Motion for
Substitution of Counsel to be served upon :
William Speary
Raymond T . Reott
Much Shelist Freed Denenberg
Christina M. Landgraf
Ament Bell & Rubenstein PC
Jenner & Block LLC
200 North LaSalle Street, Suite 2100
One IBM Plaza
Chicago, Illinois 60601
Chicago, Illinois 60611
by enclosing the same in an envelope with first-class postage prepaid and depositing the same in
the U .S
. Mail Chute located at 55 East Monroe Street, Chicago, Illinois, on this _ day of
2001 .
,rtECEIVED
CI ERICS OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
4UG 14 2001
SIlk! L OF ILLINOIS
COLE TAYLOR BANK, not individually,
)
pollution
Control
Board
but solely as trustee under a certain Illinois
)
land trust known as trust 40323 ; as
)
successor trustee to Michigan Avenue
)
National Bank of Chicago, under trust 1904,
)
Complainant,
)
PCB 01-173
Citizen's Enforcement
vs.
)
ROWE INDUSTRIES, INC ., a corporation,
)
successor to COLEMAN CABLE AND WIRE
)
COMPANY, a corporation, and CHAPCO
)
CARTON COMPANY, a corporation,
)
Respondents.
)
MOTION FOR SUBSTITUTION OF COUNSEL
Complainant COLE TAYLOR BANK ("Cole Taylor"), not individually, but solely as trustee
under a certain Illinois land trust known as trust 40323 ; as successor trustee to Michigan Avenue
National Bank of Chicago, under trust 1904, moves to allow the substitution of attorneys in the
above-captioned matter. In support of the motion, Cole Taylor states as follows :
1 .
Cole Taylor's current law firm, Rosenthal and Schanfield, P.C., has dissolved
effective July 31, 2001 .
2 .
Gerald B . Mullin, counsel primarily responsible for this file, has relocated to the firm
of Gerald B . Mullin, P .C.
3 .
Cole Taylor have consented to the substitution of counsel .
4.
Attached hereto as Exhibit A is a stipulation of substitution of counsel .
WHEREFORE, Cole Taylor respectfully requests that Rosenthal and Schanfield, P
.C . be
allowed to withdraw as counsel and that Gerald B
. Mullin, P .C . be allowed to enter its appearance
as counsel.
Gerald B . Mullin
Gerald B . Mullin, P .C.
55 East Monroe Street, Suite 3030
Chicago, Illinois 60603
(312) 456-4975
COLE TAYLOR BANK,
not individually but solely as trustee under a certain Illinois land
trust known as trust 40323
; as successor trustee to Michigan
Avenue Nat
I Ban
Chicago, under trust 1904
By :
One of Its Attorneys
1f(ECEIVED
r'1
Fn";
OFFICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
AUG
1 4 2001
ntAtE OF ILLINOIS
COLE TAYLOR BANK, not individually,
)
Pollution Control Board
but solely as trustee under a certain Illinois
)
land trust known as trust 40323 ; as
)
successor trustee to Michigan Avenue
)
National Bank of Chicago, under trust 1904,
)
Complainant,
)
PCB 01-173
Citizen's Enforcement
vs .
)
ROWE INDUSTRIES, INC ., a corporation,
)
successor to COLEMAN CABLE AND WIRE
)
COMPANY, a corporation, and CHAPCO
)
CARTON COMPANY, a corporation,
)
Respondents.
)
STIPULATION FOR SUBSTITUTION OF ATTORNEYS
ROSENTHAL AND SCHANFIELD,
P.C
.,
hereby withdraws as the attorney of record for
Cole Taylor Bank, not individually, but solely as trustee under a certain Illinois land trust known as
trust 40323 ; as successor trustee to Michigan Avenue National Bank of Chicago, under trust 1904
.
ROSENTHAL AND SCHANFIELD, P .C.
One of its attorneys
GERALD B. MULLIN, P .C. hereby enters its appearance as attorney of record for Cole
Taylor Bank, not individually, but solely as trustee under a certain Illinois land trust known as trust
40323 ; as successor trustee to Michigan Avenue National Bank of Chicago, under trust 1904
Barbara A
. Gimbel
ROSENTHAL AND SCHANFIELD, P .C.
55 East Monroe Street, Suite 4620
Chicago, Illinois 60603
(312) 236-5622
EXHIBIT A
