Michael P . Connelly
Garrett C . Carter
Connelly Roberts & McGivney LLC
One North Franklin Street
Suite 1200
Chicago, Illinois 60606
Tele : (312) 251 .9600
1 :\2470\040\Notice of Filing -13
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
GRAND PIER CENTER LLC
)
AMERICAN
SPECIALTY LINES
INTERNATIONAL
INSURANCE CO .
))
as subrogee of GRAND PIER CENTER LLC,
)
Complainants,
)
PCB 05-157
v.
)
(Enforcement)
RIVER EAST LLC
)
CHICAGO DOCK AND CANAL TRUST
)
CHICAGO DOCK AND CANAL COMPANY
)
KERR-McGEE CHEMICAL LLC,
)
Respondents .
)
TO:
Frederick S . Mueller
Daniel C. Murray
Garrett L
. Boehm, Jr.
JOHNSON & BELL, LTD .
33 West Monroe Street
Suite 2700
Chicago, IL 60603-5404
Donald J. Moran
Bradley Halloran
Pedersen
& Houpt
Hearing Officer
161 North Clark Street
Illinois Pollution
Suite 3100
Control Board
Chicago, IL 60601-3242
James R. Thompson
Center - Suite 11-500
Chicago, IL 60601
NOTICE OF FILING
PLEASE TAKE NOTICE that on May 11, 2006, we caused to be filed with the Illinois
Pollution Control Board in the James R
. Thompson Center, Chicago, Illinois, TRONOX LLC'S
MOTION TO WITHDRAW ATTORNEY'S APPEARANCE,
a copy of which is served upon
you along with this notice
.
Tronox LLC
By:
One of its orneys
AECE9VED
CLERK'S OFFICE
f. ; t ,/ 1 ' 2006
Pollution
STATE OF
Control
ILLINOIS
Board
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
GRAND PIER CENTER LLC,
)
AMERICAN INTERNATIONAL
)
SPECIALTY LINES INSURANCE
CO
.
)
as subrogee of Grand Pier Center
LLC,
)
Complainants/
)
Counter-Complaint Respondents,
)
PCB 2005-157
V .
)
(Enforcement)
RIVER EAST
LLC,
)
CHICAGO DOCK AND CANAL TRUST,
)
CHICAGO DOCK AND CANAL COMPANY,
)
Respondents,
)
TRONOX LLC,
)
Respondent/
)
Counter-Complaint Complainant
. )
MOTION TO WITHDRAW ATTORNEY'S APPEARANCE
Tronox, LLC, by its attorneys, Connelly Roberts & McGivney LLC and
Covington & Burling, pursuant to Illinois Supreme Court Rule 13(c), hereby requests the
Illinois Pollution Control Board allow it to withdraw the appearance of J.T
. Smith and in
support states
:
1
.
On or about July 7, 2005, J
.T. Smith and Thomas E
. Hogan, attorneys at
the law firm of Covington & Burling, filed a motion requesting an order allowing them to
appearpro hac vice
as additional counsel for Tronox, LLC
.
2 .
On August 18, 2005, the Illinois Pollution Control Board entered an order
granting their motion to be admitted
pro hac vice .
3 .
J.T
. Smith has since retired from Covington & Burling
.
CLERKS
EVEEOFFICED
f
1 1
9
:
2606
Pollution
STATE
OFControl
ILLINOISBoard
4 .
Pursuant to Illinois Supreme Court Rule 13(c), Tronox requests that J
.T.
Smith be granted leave to withdraw his appearance on behalf of Tronox, LLC
.
5 .
All orders and notices provided to Covington & Burling should be
addressed to Thomas E
. Hogan.
WHEREFORE, Tronox, LLC respectfully requests that the Illinois Pollution
Control Board enter an Order allowing J .T
. Smith to withdraw his appearance on behalf
of Tronox, LLC .
Dated : May 11, 2006
Respectfully submitted,
Tronox, LLC
Michael P. Connelly
Garrett Carter
Connelly Roberts & McGivney LLC
One North Franklin Street
Suite 1200
Chicago, Illinois 60606
Thomas E. Hogan
COVINGTON & BURLING
1201 Pennsylvania Avenue, N
. W.
Washington, D .C. 20004-2401
(202) 662-6000
Attorneys for Tronox LLC
eof i
Subscribed and sworn to
before me May 11, 2006 .
1 :\2470\040\pleadings\cos
CERTIFICATE OF SERVICE
I, Lynne Pudlo, a non-attorney, being first sworn on oath, depose and state that I
served the attached TRONOX LLC'S MOTION TO WITHDRAW ATTORNEY'S
APPEARANCE on the attorneys of record by mailing true and correct copies in a
properly addressed, sealed envelope with appropriate postage affixed and depositing
same in the U
.S. mail located at One North Franklin Street, Chicago, Illinois, before 5 :00
p.m. on May 11, 2006.
).Fiaai Srni"
r. A RANAI
Dd Illinn6
v
m,(- . . .
Ha'a's
oaizsos
,
GRAND PIER CENTER LLC
e;; ?+
1
;
2006
)
AMERICAN INTERNATIONAL
)
STATE OF ILLINOIS
SPECIALTY LINES INSURANCE CO .
)
as subrogee ofGRAND PIER CENTER LLC,
)
Complainants,
)
RIVER EAST LLC
)
CHICAGO DOCK AND CANAL TRUST
)
CHICAGO DOCK AND CANAL COMPANY
)
KERR-McGEE CHEMICAL LLC,
)
Respondents .
)
V .
TO: Frederick S. Mueller
Daniel C
. Murray
Garrett L . Boehm, Jr .
JOHNSON & BELL, LTD
.
33 West Monroe Street
Suite 2700
Chicago, IL 60603-5404
Michael P. Connelly
Garrett C . Carter
Connelly Roberts & McGivney LLC
One North Franklin Street
Suite 1200
Chicago, Illinois 60606
Tele: (312) 251 .9600
1:\2470\040\Notice of Filing -14
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
R
CLERK'S
E C E I
OFFICE
W E D
Donald J. Moran
Bradley Halloran
Pedersen & Houpt
Hearing Officer
161 North Clark Street
Illinois Pollution
Suite 3100
Control Board
Chicago, IL 60601-3242
James R. Thompson
Center - Suite 11-500
Chicago, IL 60601
NOTICE OF FILING
PLEASE TAKE NOTICE that on May
11, 2006,
we caused to be filed with the Illinois
Pollution Control Board in the James R. Thompson Center, Chicago, Illinois, TRONOX LLC'S
MOTION TO WITHDRAW MOTION FOR SUMMARY JUDGMENT DIRECTED
TOWARDS THE HEARING OFFICER, a copy of which is served upon you along with this
notice.
Tronox LLC
B
PCB 05-157
(Enforcement)
-.gdpo- . .zl /1/
Pollution Control Board
BEFORE THE ILLINOIS
POLLUTION CONTROL BOARD
GRAND PIER CENTER
LLC,
)
AMERICAN INTERNATIONAL )
SPECIALTY LINES INSURANCE CO .
)
as subrogee of Grand Pier Center LLC,
)
Complainants/
)
Counter-Complaint Respondents, )
PCB 2005-157
V.
)
(Enforcement)
RIVER EAST LLC,
)
CHICAGO DOCK AND CANAL TRUST,
)
CHICAGO DOCK AND CANAL COMPANY, )
Respondents,
)
TRONOX LLC,
)
Respondent/
)
Counter-Complaint Complainant
. )
TRONOX LLC'S MOTION TO WITHDRAW MOTION FOR SUMMARY
JUDGMENT DIRECTED TOWARDS THE HEARING OFFICER
Tronox, LLC, by its attorneys, Connelly Roberts & McGivney LLC and Covington
& Burling, hereby moves to withdraw its Motion for Summary Judgment with respect to all
claims asserted by Plaintiffs/Counterclaim Defendants Grand Pier Center LLC ("Grand
Pier") and American International Specialty Lines Insurance Co . ("American
International"), as subrogee of Grand Pier (collectively, the "plaintiffs")
. Tronox reserves
the right to file a subsequent motion for summary judgment
.
WHEREFORE, Tronox LLC respectfully requests the Hearing Officer withdraw
Tronox, LLC's Motion for Summary Judgment .
RCLERKS
:rJVIE.D
t'.r,f
t
2006
Pollution
STATE OF
Control
ILLINOISBoard
Dated : May 11, 2006
Respectfully submitted,
Tronox, LLC
By : ~~'
~T'
ne of its
rneys
Michael P
. Connelly
Garrett Carter
Connelly Roberts & McGivney LLC
One North Franklin Street
Suite 1200
Chicago, Illinois 60606
(312) 782-0690
Thomas E . Hogan
COVINGTON & BURLING
1201 Pennsylvania Avenue, N.W .
Washington, D
.C. 20004-2401
(202) 662-6000
Attorneys for Tronox LLC
2470040/motion to withdraw sj
Subscribed and sworn to
before me May 11, 2006 .
"OFFICIAL SEAL"
I)ABRIELA A
. BANA7
Nntary Pobllr
.
. Slake of Illinois
CommssionBxN!~'°` 0812510
1 :\2470\040\pleadings\cos
CERTIFICATE OF SERVICE
I, Lynne Pudlo, a non-attorney, being first sworn on oath, depose and state that I
served the attached
TRONOX LLC'S MOTION TO WITHDRAW MOTION FOR
SUMMARY JUDGMENT DIRECTED TOWARDS THE HEARING OFFICER on
the attorneys of record by mailing true and correct copies in a property addressed, sealed
envelope with appropriate postage affixed and depositing same in the U .S . mail located at
One North Franklin Street, Chicago, Illinois, before 5 :00 p
.m . on May 11, 2006 .
