IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

BCBSM, INC., et al.,

Plaintiffs,

v.

WALGREEN CO. AND WALGREENS BOOTS 

ALLIANCE, INC.,

Defendants.

Case No. 1:20-cv-01853

Honorable Virginia M. Kendall

Honorable Sheila M. Finnegan

Motion to Withdraw as Counsel

Consolidated with:

Case No. 1:20-cv-04738

Case No. 1:20-cv-03332

Case No. 1:20-cv-01929

Case No. 1:20-cv-04940

MOTION TO WITHDRAW AS COUNSEL

Pursuant to Northern District of Illinois Local Rule 83.17 and Illinois Rule of 

Professional Conduct 1.16, attorneys Thomas Connolly, Thomas Mason, and Jared Marx

(“counsel from HWG”) hereby move the Court to withdraw as local counsel of record in this 

matter. In support thereof, counsel from Harris, Wiltshire & Grannis state as follows:

1. Plaintiffs are represented by Crowell & Moring (“Crowell”) in connection with 

their Complaint against defendants Walgreen Co. and Walgreens Boots Alliance, Inc. 

(“Defendants”) (See Compl., Dkt. 1).

2. On July 30, 2021, counsel from Harris Wiltshire & Grannis LLP (“HWG”)

entered motions to appear pro hac vice on behalf of non-party Crowell and each of the Plaintiff

entities (see Dkts. 154 and 155), which this Court granted on August 3, 2021 (Dkt. 162). 

3. Counsel from Perkins Coie also entered appearances as local counsel on behalf of 

Plaintiffs and Crowell in this action. (see, Dkts. 156-157; 179-180.

Case: 1:20-cv-01853 Document #: 245 Filed: 04/01/22 Page 1 of 3 PageID #:6008
- 2 -

4. Counsel from HWG and Perkins Coie subsequently filed a Motion for 

Qualification of Counsel and related pleadings on July 30, 2021 (see, Dkts. 158-161).

5. On August 3, 2021, Defendants filed a Motion to Strike the Plaintiffs’ Motion for 

Qualification of Counsel (Dkt. 163), which this Court granted on February 9, 2022. (Dkt. 217).

6. HWG’s and Perkins Coie’s representation in this matter was limited to the Motion 

for Qualification of Counsel, which is now resolved. Plaintiffs will continue to be represented 

by counsel from Crowell for the purposes of their Complaint, and Plaintiffs have retained 

counsel at Holland & Knight to represent them in connection with Defendants’ Counterclaim 

(see, Dkt. 225). 

7. The withdrawal of HWG and Perkins Coie can be accomplished without material 

adverse effect on the interests of Plaintiffs and non-party Crowell, who consent to this Motion.

8. Counsel for Defendants has been consulted regarding this Motion and Defendants 

do not oppose the withdrawal of HWG and Perkins Coie.

9. Accordingly, counsel from Perkins Coie moves for leave to withdraw as local 

counsel of record in this action for Plaintiffs and non-party Crowell. Concurrently with this 

Motion, HWG will move to withdraw as counsel of record, as well.

10. In compliance with the Court’s Second Amended General Order 21-0027, counsel 

has not noticed this motion for presentment.

WHEREFORE, Attorneys Thomas Connolly, Thomas Mason, and Jared Marx 

respectfully request that their Motion to Withdraw as Counsel be granted.

Case: 1:20-cv-01853 Document #: 245 Filed: 04/01/22 Page 2 of 3 PageID #:6009
- 3 -

Dated: April 1, 2022

Respectfully Submitted,

/s/ Jared Paul Marx________________

Thomas B. Mason (pro hac vice)

Thomas G. Connolly (pro hac vice)

Jared Marx (pro hac vice)

HARRIS, WILTSHIRE & GRANNIS LLP

1919 M Street NW, Eighth Floor

Washington, DC 20036

Telephone: (202) 730-1300

Facsimile: (202) 730-1301

tmason@hwglaw.com

tconnolly@hwglaw.com

jmarx@hwglaw.com

Counsel for Plaintiffs and non-party 

Crowell & Moring LLP

Case: 1:20-cv-01853 Document #: 245 Filed: 04/01/22 Page 3 of 3 PageID #:6010