1. BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
      2. MOTION TO WITHDRAW
      3. PROOF OF SERVICE
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
PEOPLE OF THE STATE OF ILLINOIS
Complainant,
v.
BARGER ENGINEERING, INC.,
an Indiana corporation
Respondent
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)
)
)
)
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)
)
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PCB 06-82
(Enforcement - Water)
MOTION TO WITHDRAW
NOW COMES Charles 1. Northrup, an attorney for Respondent, and hereby moves to
withdraw as counsel in this matter. In support, Movant states:
1.
Charles 1. Northrup and the law firm of Sorling, Northrup, Hanna, Cullen
&
Cochran, Ltd. have appeared in the above captioned matter as an attorney for Respondent.
2.
Charles J. Northrup has accepted a legal position with a not-for-profit association
and will no longer be engaged in the private practice
of law. The scope of his duties at his new
employer, as well
as the terms of that new employment, will not allow him to devote any time or
resources to continuing representation
of private clients, including the Respondent in this matter.
3.
Charles J. Northrup has advised Respondent of his intent to withdraw and has
given notice
of this action.
4.
Charles J. Northrup has, consistent with Supreme Court of Illinois Rule of
Professional Conduct 1.16(d) taken reasonable steps to avoid foreseeable prejudice to the
Respondent including giving notice
of this Motion.
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Electronic Filing - Received, Clerk's Office, October 8, 2008
5.
All notices and official papers in this matter should be sent to:
Ms. Claire Manning
Brown, Hay
&
Stephens, LLP
205 S. 5
th
St.
P. O. Box 2459
Springfield, IL 62705-2459
WHEREFORE, Charles
J.
Northrup respectfully requests that this tribunal allow him to
withdraw from this matter, and for any other relief this tribunal deems appropriate.
Respectfully submitted,
Mr. Charles
J. Northrup
Illinois State Bar Association
424
S. 2
nd
St.
Springfield,IL 62701
Sorling, Northrup, Hanna,
Cullen
&
Cochran, Ltd.
Suite 800 Illinois Building
P.O. Box 5131
Springfield,
IL 62705
Telephone: 217.544.1144
Fax: 217.522.3173
2
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PROOF OF SERVICE
The undersigned hereby certifies that the foregoing Motion to Withdraw was filed
electronically with the Clerk
of the Illinois Pollution Control Board in Chicago, Illinois and
copies
of said document were
serve~.
U.S. Mail to the following addresses with postage fully
pre-paid
on the S7#'l day of
(2
J...v-.. ,
2008.
Ms. Carol Webb
Hearing Officer
Illinois Pollution Control Board
1021 N. Grand Ave. East
P.
O. Box 19274
Springfield,IL 62794-9274
Ms. Kristen Laughridge Gale
Office
of the Attorney General
Environmental Bureau
500 South Second St.
Springfield, IL 62706
Ms. Claire
A. Manning
Brown, Hay
&
Stephens, LLP
205 South Fifth St.
P.
O. Box 2459
Springfield, IL 62705-2459
Barger Engineering
c/o Matthew Stone
P.
O. Box 2507
Evansville, IN 47728
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Printed on Recycled Paper
Electronic Filing - Received, Clerk's Office, October 8, 2008

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