BEFORE THE ILLINOIS
ORIGINAL
POLLUTION CONTROL
RECEIVED
BOARD
CLERK'S OFFICE
MOTION FOR PRO HAC VICE
ADMISSION OF KATHLEEN G. HENRY
Pursuant to 35 Ill
. Adm. Code § 101 .400(a)(3), I, Kathleen G
. Henry, respectfully request
that the Illinois Pollution Control Board authorize me to appear
pro hac vice in the above-
captioned matter on behalf of petitioners American Bottom Conservancy and Sierra Club
. The
grounds for this motion are as follows :
1
. I am a licensed attorney in the State of Missouri, where I was admitted to practice law in
1989
. My attorney registration number in Missouri is 39504, and I am in good standing
.
2
. I am a licensed attorney in the State of Illinois, where I was admitted to practice law in
1990
. I have been on inactive status since then
. My attorney registration number in Illinois is
6203060.
3
. I am a licensed attorney in the District of Columbia, where I was admitted to practice law
in 1999. My attorney registration number is 464240
. I resigned from that bar in 2000
.
4
. I am a member in good standing of the bars of the following federal courts
: US District
Court for the Eastern District of Missouri
; US District Court for the District of Columbia
; US
Court of Appeals for the Seventh Circuit
; and the US Court of Appeals for the Eighth Circuit
.
APR 1 0
2007
AMERICAN BOTTOM CONSERVANCY, and
)
STATE
OF
ILLINOIS
SIERRA CLUB,
)
Pollution
Control Board
Co-Petitioners,
)
CITY OF MADISON, ILLINOIS, and
)
(Siting
Pollution
Appeal)
Control Facility
WASTE MANAGEMENT OF ILLINOIS, INC., )
Respondents .
)
5. No
disciplinary proceedings are pending or have ever been brought against me .
6. 1 have never been disbarred or subject to disbarment proceedings
.
7. Petitioners American Bottom Conservancy and Sierra Club are represented by Great
Rivers Environmental Law Center . I am the President of Great Rivers .
8
. I am familiar with the Illinois Code of Civil Procedure, Illinois Supreme Court Rules, and
the Rules of the Illinois Pollution Control Board and I understand and agree to be bound by them
in all proceedings before the Illinois Pollution Control Board .
9. With the Board's permission, attached is my Entry of Appearance in this matter
.
WHEREFORE, I, Kathleen G . Henry, respectfully request permission to appear
pro hae
vice
on behalf of petitioners American Bottom Conservancy and Sierra Club .
Respectfully submitted,
Kathleen G
,
.
e'
Henry
/
LA"
President, Great Rivers Environmental Law Center
705 Olive Street, Ste . 614
St. Louis, MO 63101
(314) 231-4181
(314) 231-4184 (facsimile)
khenry(agreatriverslaw.org
Dated:
k
Subscribed and sworn to before me this/BLit day ofd1t....J, 2007
.
City, State, Zip code :
Note
JOHN
STTTE
StPublic
. Louis
T,OF
MCDONALD
MISSOURI-CountyNotary
Seal
ily Commission Expires June 25, 2009
Pointed on recycled paper
Printed on recycled paper
CERTIFICATE OF SERVICE
2007, a
The
complete
undersigned
copy of
hereby
this
certifies
instrument
that
was
on
served
the l
upon
counsel
day offor
16,0^1
defendants
by
enclosing the same in an envelope and depositing such envelope, with first class postage
fully prepaid, in a United States post office box in St . Louis, Missouri, addressed to :
Donald J . Moran
Penni S . Livingston
Pedersen & Houpt
Livingston Law Firm
161 North Clark Street
5701 Perrin Road
Suite 3100
Fairview Heights, IL 62208
Chicago, IL 60601-3224
John T . Papa
Callis, Papa, Hale, Szewczyk & Danzinger, PC
1326 Niedringhaus Avenue
Granite City, IL 62040
BEFORE THE ILLINOIS POLLUTION CONTROLRECEIVEDqK
OFFICE
APR 2,0 2007
STATE OF ILLINOIS
Pollution Control Board
AMERICAN BOTTOM CONSERVANCY, and )
SIERRA CLUB,
Co-Petitioners,
V .
CITY OF MADISON, ILLINOIS, and
WASTE MANAGEMENT OF ILLINOIS, INC
.,
Respondents .
Printed on recycled paper
ORIGINAL
Respectfully submitted,
Pollution Control Facility
(Siting Appeal)
ENTRY OF APPEARANCE BY KATHLEEN
G. HENRY
Comes now Kathleen G . Henry, attorney for petitioners, and hereby enters her appearance
on the above-styled cause .
Kathleen G
. Henry
Great Rivers Environmental Law Center
705 Olive Street, Ste . 614
St. Louis, MO 63101
(314) 231-4181
(314) 231-4184 (facsimile)
khenry®greatriverslaw.org
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the
1Y&
day of
2007, a complete copy of this instrument was served upon counsel for defendants by
enclosing the same in an envelope and depositing such envelope, with first class postage
fully prepaid, in a United States post office box in St
. Louis, Missouri, addressed to :
Donald J . Moran
Penni S
. Livingston
Pedersen & Houpt
Livingston Law Firm
161 North Clark Street
5701 Perrin Road
Suite 3100
Fairview Heights, IL 62208
Chicago, IL 60601-3224
John T . Papa
Callis, Papa, Hale, Szewczyk & Danzinger, PC
1326 Niedringhaus Avenue
Granite City, IL 62040
/1P"''1
Printed on recycled paper
