RECEIVED
    CLERK’S OFFICE
    BEFORE THE ILLiNOIS POLLUTION CONTROL BOARD
    MAR
    242004
    STATE OF ILLINOIS
    JEAN A. MATHISON AND
    )
    Pollution
    Control
    Board
    ROCKFORD STOP-N-GO, iNC.,
    )
    )
    Petitioners,
    )
    )
    vs.
    )
    PCB No. 04-146
    )
    (UST Fund Appeal)
    ILLINOIS OFFICE OF STATE
    )
    FIRE MARSHAL AND
    )
    ILLINOIS ENVIRONMENTAL
    )
    PROTECTION AGENCY
    )
    Respondents. )
    NOTICE OF MOTION AND MOTION TO VOLUNTARILY
    DISMISS ILLINOIS POLLUTION CONTROL AGENCY
    TO:
    Jennifer A. Tomas
    Mitchell L. Cohen
    Assistant Attorneys General
    188 West Randolph, Suite 2001
    Chicago, IL 60601
    And
    Ms. Dorothy M. Gunn
    Clerk of the Board
    Illinois Pollution Control Board
    100 West Randolph Street
    Suite 11-500
    Chicago, IL 60601
    PLEASE TAKE NOTICE that the Petitioners, JEAN A. MATHISON and
    ROCKFORD STOP-N-GO, INC., by their attorneys, Reinhart Boerner Van
    Deuren s.c. and Raymond M. Roder, will and hereby do move for the voluntary
    dismissal of the Illinois Environmental Protection Agency (“IEPA”) as a
    Madison\1 24534RMR:KM 03/22/04
    Respondent in the above-entitled action. The grounds for the Motion are as
    follows:
    1.
    The Petitioners’ counsel has been advised and believes is correct that
    the IEPA took no part in and has no responsibility for the decision on the amount
    of the deductible, the sole matter at issue in this appeal.
    2.
    The Petitioners, therefore, have no controversy with the IEPA and its
    participation as a party in this proceeding is unnecessary.
    WHEREFORE, the Petitioners move voluntarily for the dismissal of IEPA
    as a party to this contested proceeding.
    Dated at Madison, Wisconsin, this 22nd day of March, 2004.
    22ReinhartEast MifflinBoernerStreet,Van
    DeurenSuite
    600s.c.
    Raymo~Td
    ,/~
    /,*.
    M. Roder
    ,~2..
    Madison, Wisconsin
    53703
    WI State Bar ID No. 1010463
    6082292200
    Attorney forPetitioners,
    Jean A. Mathison and
    Mailing Address:
    Rockford Stop-N-Go, Inc.
    P.O. Box 2018
    Madison, WI
    5370
    1-2018
    Madison\124534RMR:KJVI 03/22/04
    2

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