Printed on Recycled Paper
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
DiMUCCI DEVELOPMENT CORPORATION,
Petitioner,
v.
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY,
Respondent.
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PCB No. 04-209
(UST Appeal)
MOTION TO WITHDRAW
Now comes Jeep & Blazer, L.L.C., attorneys for Petitioner, DiMucci Development
Corporation, and moves the Illinois Pollution Control Board (“Board”) for leave to withdraw. In
support thereof, Jeep & Blazer, L.L.C. states as follows:
1.
The client and its counsel are unable to work together.
2.
The client and its counsel mutually agree that the best interests of the client
would be served by counsel’s withdrawal.
Wherefore, DiMucci Development Corporation respectfully requests that the Illinois
Pollution Control Board (the “Board”) enter an order granting Jeep and Blazer, LLC to withdraw
as counsel for DiMucci Development Corporation.
Respectfully submitted,
s/ Thomas S. Yu
By: _______________________
One of its attorneys
Thomas S. Yu
Jeep & Blazer, L.L.C.
1749 S. Naperville Road, Suite 102
Wheaton, IL 60187
(630) 681-2530
tsyu@enviroatty.com
ELECTRONIC FILING, RECEIVED, CLERK'S OFFICE, JULY 28, 2005
Printed on Recycled Paper
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
DiMUCCI DEVELOPMENT CORPORATION,
Petitioner,
v.
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY,
Respondent.
)
)
)
)
)
)
)
)
)
)
)
)
PCB No. 04-209
(UST Appeal)
NOTICE OF FILING AND PROOF OF SERVICE
Dorothy Gunn
Clerk of the Board
Illinois Pollution Control Board
James R. Thompson Center
Suite 11-500
100 West Randolph Street
Chicago, Illinois 60601
John J. Kim
Special Assistant Attorney General
Illinois Environmental Protection Agency
Division of Legal Counsel
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
Bradley P. Halloran
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center
Suite 11-500
100 West Randolph Street
Chicago, Illinois 60601
Environmental Protection Industries
Michael Musa
President/CEO
16650 S. Canal
South Holland, IL 60473
DiMucci Development Corporation
Larry Kowalczyk
100 West Dundee Rd.
Palatine, IL 60067
PLEASE TAKE NOTICE
that on Thursday, July 28, 2005, I filed with the Clerk of the
Illinois Pollution Control Board of the State of Illinois via electronic filing, a Motion to Withdraw,
for filing in the above-entitled cause, copies of which are attached hereto.
Printed on Recycled Paper
The undersigned hereby certifies that copies of the Notice of Filing, together with copies
of the documents described above were served upon the above persons, via certified mail,
return receipt requested, and by depositing same in the United States Mail on July 28, 2005
Dated:
July 28, 2005
Respectfully Submitted,
s/ Thomas S. Yu
By: _______________________
Thomas S. Yu
Jeep & Blazer, L.L.C.
1749 S. Naperville Road, Suite 102
Wheaton, IL 60187
(630) 681-2530
Fax (630) 690-2812
tsyu@enviroatty.com