KC-1359869-1
BEFORE THE
POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
PRAIRIE RIVERS NETWORK and
)
SIERRA CLUB,
)
Petitioners,
)
Case No
. PCB 06-124
vs.
)
(NPDES Permit Appeal)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY and
)
PRAIRIE STATE GENERATING COMPANY,
)
LLC,
)
Respondents .
)
AMERICAN BOTTOM CONSERVANCY and )
DALE WOJTKOWSKI,
)
Petitioners,
)
Case No. PCB 06-127
vs.
)
(NPDES Permit Appeal)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY and
)
PRAIRIE STATE GENERATING COMPANY,
)
LLC,
)
Respondents .
)
NOTICE OF FILING
RECEIVED
JAN 3 0 2006
Pollution
STATE OF
control
ILLINOIS
Board
Please take notice that Respondent, Prairie State Generating Company,
LLC has, this
26th day of January, 2006 filed with Board its Motion For Leave Of Counsel To Appear Pro Hac
Vice
.
KC-1359869-1
Dated: January 26, 2006
Respectfully submitted :
W.C. Blanton
(Mo. Bar No. 54125)
BLACKWELL SANDERS PEPER MARTIN, LLP
4801 Main Street, Suite 1000
Kansas City, Missouri 64112
Telephone
: (816) 983-8151
Facsimile: (816) 983-8080
E-mail :
wblanton(o)blackwellsanders
.com
Alison M. Nelson
(Mo. Bar No. 58004)
BLACKWELL SANDERS PEPER MARTIN, LLP
720 Olive Street, Suite 2400
St. Louis, Missouri 63101
Telephone: (314) 345-6218
Facsimile
: (314) 345-6060
E-mail
: anelson ablackwellsanders
.com
ATTORNEYS FOR RESPONDENT,
PRAIRIE STATE GENERATING COMPANY,
LLC
2
CERTIFICATE OF SERVICE
The undersigned hereby certifies that copies of the foregoing
NOTICE OF FILING
have been deposited in the U
.S
. Mail, first class postage prepaid, this 26th day of January, 2006,
in envelopes addressed to :
Carol Webb
Hearing Officer
Illinois Pollution Control Board
James R. Thompson Center, Suite 11-500
100 West Randolph Street
Chicago, IL 60601-3218
Albert F. Ettinger
Richard H. Acker
Environmental Law & Policy Center
35 East Wacker Drive, Suite 1300
Chicago, IL 60601-2110
Penni S. Livingston
Livingston Law Firm
4972 Benchmark Centre, Ste
. 100
Swansea, IL 62226
Sanjay Sofat
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O
. Box 19276
Springfield, IL 62794-9276
KC-1359869- 1
3
W.C. Blanton
BLACKWELL SANDERS PEPER MARTIN, LLP
4801 Main Street
Suite 1000
Kansas City, MO 64112
RECEIVED
JAN 3 0 2006
STATE
OF
ILLINOIS
rullutiun Control
Board
PRAIRIE RIVERS NETWORK and
)
SIERRA CLUB,
)
Petitioners,
)
Case No. PCB 06-124
Vs .
)
(NPDES Permit Appeal)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY and
)
PRAIRIE STATE GENERATING COMPANY, )
LLC,
)
Respondents.
)
AMERICAN BOTTOM CONSERVANCY and
DALE WOJTKOWSKI,
)
Petitioners,
)
Case No. PCB 06-127
Vs .
)
(NPDES Permit Appeal)
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY and
)
PRAIRIE STATE GENERATING COMPANY, )
LLC,
)
Respondents.
)
KC-1358918- 1
BEFORE THE
POLLUTION CONTROL BOARD
OF THE STATE OF ILLINOIS
MOTION FOR LEAVE OF COUNSEL TO APPEAR PRO HAC VICE
Respondent, Prairie State Generating Company, LLC ("Prairie State"), hereby moves this
Board under its Procedural Rule 101 .400(a)(3) to grant W .C . Blanton and Alison Nelson of the
law firm Blackwell Sanders Peper Martin LLP leave to appear pro hac vice on its behalf in
connection with this matter, and in support thereof states :
1 .
Mr
. Blanton is a partner in the Kansas City, Missouri office of Blackwell Sanders
Peper Martin LLP
. He is currently a member in good standing of the Bars of the States of
Missouri, Minnesota and Indiana
. He has been licensed to practice law by the Indiana Supreme
Court since 1975, by the Minnesota Supreme Court since 1996, and by the Missouri Supreme
Court since 2002
. He also is admitted to practice before the United States District Courts for the
Northern and Southern Districts of Indiana, the District of Minnesota, the Western and Eastern
Districts of Missouri, and the Western District of Wisconsin, and the United States Courts of
Appeals for the Sixth, Seventh, Eighth, and Tenth Circuits
. He has never been denied admission
to the courts of any state or to any federal court
; and he has never been censured, suspended, or
disbarred by any court, except for six (6) days in 1998 in Minnesota when he was suspended for
late payment of the annual licensing fee as a result of not receiving notice of the due date
.
Mr
. Blanton is presently appearing pro hac vice before this Board on behalf of
Respondent, Peabody Coal Company, LLC
., in the case encaptioned
People of the State of
Illinois v
. Peabody Coal Company, LLC,
Case No . PCB 99-134
. Mr. Blanton has previously
appeared pro hac vice
before this Board on behalf of Respondent, Black Beauty Coal Company,
in the case of
Prairie Rivers Network v
. Illinois Environmental Protection Agency and Black
Beauty Coal Company, Case No
. PCB 01-112.
2.
Ms. Nelson is an associate in the St
. Louis, Missouri office of Blackwell Sanders
Peper Martin LLP .
She is currently a member in good standing of the Bar of the State
of Missouri
. She has been licensed to practice law by the Missouri Supreme Court since 2005
.
She is also admitted to practice before the United States District Court for the Eastern District
of Missouri and the United States District Court for the Western District of Missouri
. She has
KC-1358918-1
2
never been denied admission to the courts of any state or to any federal court ; and she has never
been censured, suspended, or disbarred by any court .
3 .
Prairie State desires that Mr . Blanton and Ms. Nelson appear as counsel of record
on its behalf in this matter and to represent its interests in this matter .
WHEREFORE, Respondent, Prairie State Generating Company, LLC, respectfully
requests that Board to grant this motion and to grant W
.C
. Blanton and Alison Nelson leave to
appear
pro hac vice on its behalf in this matter.
Dated : January 26, 2006
KC .1358918-1
Respectfully submitted
:
3
G
W.C. Blanton
(Mo. Bar No. 54125)
BLACKWELL SANDERS PEPER MARTIN, LLP
4801 Main Street, Suite 1000
Kansas City, Missouri 64112
Telephone : (816) 983-8151
Facsimile : (816) 983-8080
E-mail : ,vblanton(ajblackwellsanders .com
Alison M
. Nelson
(Mo. Bar No. 58004)
BLACKWELL SANDERS PEPER MARTIN, LLP
720 Olive Street, Suite 2400
St
. Louis, Missouri 63101
Telephone: (314) 345-6218
Facsimile : (314) 345-6060
E-mail : anelson ablackwellsanders .com
ATTORNEYS FOR RESPONDENT,
PRAIRIE STATE GENERATING COMPANY,
LLC
CERTIFICATE OF SERVICE
The undersigned hereby certifies that copies of the foregoing Motion
For Leave Of
Counsel To Appear Pro
Hac Vice have been deposited in the U
.S. Mail, first class postage
prepaid, this 264day
of January, 2006, in envelopes addressed to
:
Carol Webb
Hearing Officer
Illinois Pollution Control Board
James R
. Thompson Center, Suite 11-500
100 West Randolph Street
Chicago, IL 60601-3218
Albert F . Ettinger
Richard H
. Acker
Environmental Law & Policy Center
35 East Wacker Drive, Suite 1300
Chicago, IL 60601-2110
Penni S . Livingston
Livingston Law Firm
4972 Benchmark Centre, Ste . 100
Swansea, IL 62226
KC-1358918- 1
Sanjay Sofat
Division of Legal Counsel
Illinois Environmental Protection Agency
1021 North Grand Avenue East
P.O. Box 19276
Springfield, IL 62794-9276
W.C . Blanton
~'- J
BLACKWELL SANDERS PEPER MARTIN, LLP
4801 Main Street
Suite 1000
Kansas City, MO 64112
4
