Document Page 1 of 5 UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In re: Chapter 11 EDISON MISSION ENERGY, et al., Case No. 12-49219 (JPC Debtors. 1 (Jointly Administered NOTICE OF MOTION PLEASE TAKE NOTICE that on Wednesday, April 16, 2014, at 10:30 a.m., or at such time as counsel may be heard, we shall appear before the Honorable Jacqueline P. Cox in Courtroom 680 of the United States Bankruptcy Court for the Northern District of Illinois, Eastern Division, 219 S. Dearborn St., Chicago, IL 60604, and then and there present the Motion for Leave to Withdraw as Counsel, at which time and place you may appear as you see fit. A copy of the Motion is hereby served upon you. Dated: March 7, 2014 /s/ Maria A. Diakoumakis Richard M. Bendix, Jr. Maria A. Diakoumakis 10 South Wacker Drive, Suite 2300 1 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, include: Edison Mission Energy (1807; Camino Energy Company (2601; Chestnut Ridge Energy Company (6590; Edison Mission Finance Co. (9202; Edison Mission Energy Fuel Services, LLC (4630; Edison Mission Fuel Resources, Inc. (3014; Edison Mission Fuel Transportation, Inc. (3012; Edison Mission Holdings Co. (6940; Edison Mission Midwest Holdings Co. (6553; EME Homer City Generation L.P. (6938; Homer City Property Holdings, Inc. (1685; Midwest Finance Corp. (9350; Midwest Generation EME, LLC (1760; Midwest Generation, LLC (8558; Midwest Generation Procurement Services, LLC (2634; Midwest Peaker Holdings, Inc. (5282; Mission Energy Westside, Inc. (0657; San Joaquin Energy Company (1346; Southern Sierra Energy Company (6754; and Western Sierra Energy Company (1447. The location of parent Debtor Edison Mission Energy s corporate headquarters and the Debtors service address is: 3 MacArthur Place, Suite 100, Santa Ana, California 92707.
Document Page 2 of 5 Telephone: (312 876-1700 rbendix@dykema.com and Earl M. Forte, Esq. Amy E. Vulpio, Esq. WHITE AND WILLIAMS LLP 1650 Market Street, 18 th Floor Philadelphia, PA 19103 Telephone: (215 864-7000 fortee@whiteandwilliams.com vulpioa@whiteandwilliams.com Attorneys for the Allied World National Assurance Company
Document Page 3 of 5 CERTIFICATE OF SERVICE I, Maria A. Diakoumakis, an attorney, hereby certify that on this 7th day of March, 2014, I caused a true and correct copy of the foregoing Motion for Leave to Withdraw as Counsel to be filed with the Court using the Court s CM/ECF system, which will send notification of such filing to all registered users in this Case. /s/ Maria A. Diakoumakis Maria A. Diakoumakis (ARDC #6289309 10 S. Wacker Drive, Suite 2300 T: (312 627-2132 F: (312
Document Page 4 of 5 UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION In re: Chapter 11 EDISON MISSION ENERGY, et al., Case No. 12-49219 (JPC Debtors. 2 (Jointly Administered MOTION FOR LEAVE TO WITHDRAW AS COUNSEL Pursuant to Local Bankruptcy Rule 2091-1, Richard M. Bendix and Maria A. Diakoumakis of the law firm of Dykema Gossett PLLC (collectively, Counsel respectfully submit this Motion for Leave to Withdraw as Counsel on behalf of Allied World National Assurance Company ( Allied World, and state as follows: 1. Counsel first appeared in the above-captioned bankruptcy case ( Case on February 14, 2014 (Docket Nos. 2051 and 2052. Since that time, Counsel has represented Allied World in connection with its objection (Docket No. 2053 ( Objection to the Debtors plan of reorganization. 2. Allied World and the Debtors have resolved the Objection. 2 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor s federal tax identification number, include: Edison Mission Energy (1807; Camino Energy Company (2601; Chestnut Ridge Energy Company (6590; Edison Mission Finance Co. (9202; Edison Mission Energy Fuel Services, LLC (4630; Edison Mission Fuel Resources, Inc. (3014; Edison Mission Fuel Transportation, Inc. (3012; Edison Mission Holdings Co. (6940; Edison Mission Midwest Holdings Co. (6553; EME Homer City Generation L.P. (6938; Homer City Property Holdings, Inc. (1685; Midwest Finance Corp. (9350; Midwest Generation EME, LLC (1760; Midwest Generation, LLC (8558; Midwest Generation Procurement Services, LLC (2634; Midwest Peaker Holdings, Inc. (5282; Mission Energy Westside, Inc. (0657; San Joaquin Energy Company (1346; Southern Sierra Energy Company (6754; and Western Sierra Energy Company (1447. The location of parent Debtor Edison Mission Energy s corporate headquarters and the Debtors service address is: 3 MacArthur Place, Suite 100, Santa Ana, California 92707.
Document Page 5 of 5 3. Allied World will not be prejudiced by Counsel s withdrawal in this Case at this time. WHEREFORE, the undersigned respectfully requests that the Court enter an order permitting Richard M. Bendix, Maria A. Diakoumakis, and the law firm of Dykema Gossett PLLC to withdraw their appearances as counsel for Allied World National Assurance Company in the above-captioned bankruptcy case. Dated: March 7, 2014 /s/ Maria A. Diakoumakis Richard M. Bendix, Jr. Maria A. Diakoumakis 10 South Wacker Drive, Suite 2300 Telephone: (312 876-1700 rbendix@dykema.com and Earl M. Forte, Esq. Amy E. Vulpio, Esq. WHITE AND WILLIAMS LLP 1650 Market Street, 18 th Floor Philadelphia, PA 19103 Telephone: (215 864-7000 fortee@whiteandwilliams.com vulpioa@whiteandwilliams.com Attorneys for the Allied World National Assurance Company
UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF ILLINOIS Eastern Division In Re: BK No.: 12-49219 EDISON MISSION ENERGY, et al. (Jointly Administered Chapter: 11 Honorable Jacqueline Cox Debtor(s ORDER GRANTING MOTION FOR LEAVE TO WITHDRAW AS COUNSEL THIS CAUSE COMING ON TO BE HEARD on the motion of Richard M. Bendix, Maria A. Diakoumakis, and the law firm of Dykema Gossett PLLC for leave to withdraw as attorney on behalf of Allied World National Assurance Company, and the Court being duly advised in the premises: IT IS HEREBY ORDERED that: 1. The motion be, and hereby is, GRANTED; 2. Richard M. Bendix, Maria A. Diakoumakis, and the law firm of Dykema Gossett PLLC are granted leave to withdraw their appearances on behalf of Allied World National Assurance Company in this Case. Enter: Dated: United States Bankruptcy Judge Prepared by: Richard M. Bendix, Jr. (ARDC# 0168130 Maria A. Diakoumakis (ARDC# 6289309 10 S. Wacker Drive, Suite 2300 Telephone: (312 876-1700 rbendix@dykema.com Rev: 20120209_bko