MOTION TO INTERVENE

mukiialice64
Motions
February 15, 2024

XXX LLC

XXX

XXX

XXX

XXX

In Pro Per

 

 

 

XXX COUNTY MAGISTRATE COURT, XXX

 

XXX, LLC,

Plaintiff,

vs.

XXX,

Defendant(s)

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 Case No.:

 

FOOD HUB BY XXX LLC’S MOTION TO INTERVENE

 

NOTICE OF FOOD HUB BY SESSYKS’S MOTION TO INTERVENE

TO ALL PARTIES AND ATTORNEYS OF RECORD:

You are hereby notified that on XXX, at 11am, Food Hub By XXX  LLC will bring on for hearing her Motion to Intervene. It will be based on this Notice of Motion, the attached Motion to Intervene, exhibits adduced, and oral arguments presented during the hearing of the Motion.

 

Dated this XX  day of XXX

 

Respectfully Submitted,

 

 

___________________________________

XXX

Food Hub By XXX LLC,

 

 

 

XXX

XXX

XXX

XXX

In Pro Per

 

 

 

XXX COUNTY MAGISTRATE COURT, XXX

 

XXX

,

Defendant(s)

 )

)

)

)

)

)

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 Case No.:

 

FOOD HUB BY SESSYKS LLC’S MOTION TO INTERVENE

 

 

NOW COMES FOOD HUB BY XXX LLC, and files this Motion to Intervene, and for cause would show this Honorable Court as follows:

 

Factual Background

  1. On XXX, Plaintiff filed a mechanic’s lien against Defendant alleging unpaid amounts of money.
  2. The named Defendant in the case is Jay Cameron, the landlord of the property in question.
  3. I, Sele Rhodes, am the individual who signed the estimates related to the alleged unpaid amounts.
  4. The landlord has requested that I respond to the Complaint since I am the one who signed the estimates, as I have personal knowledge and information relevant to the claims raised by the Plaintiff.
  5. Unfortunately, as I am not a named party in this case, I am unable to respond to the Complaint and present my defense or provide necessary information to the Court.

 

Basis for Intervention

  1. I seek intervention in this case to protect my interests and ensure that I have the opportunity to respond to the allegations raised by the Plaintiff.
  2. My intervention is essential to a just and equitable resolution of this matter, as I possess unique knowledge and information regarding the estimates, the circumstances surrounding the alleged unpaid amounts, and any potential defenses that may be raised.
  3. By allowing me to intervene as a defendant, the Court can ensure the fair and complete adjudication of the issues in dispute and prevent any potential prejudice that may arise from my absence as a party.

 

Argument

  1. Intervention is warranted in this case under the applicable legal standards. S.C. R. Civ. P. 24 provides for intervention as a matter of right when the intervenor’s interests may be impaired or affected by the outcome of the litigation.
  2. My interests are directly implicated by the allegations in the Complaint, as I am the one who signed the estimates and have personal knowledge of the circumstances surrounding the alleged unpaid amounts.
  3. As a non-party, I am currently unable to participate in this litigation or assert any defenses or counterclaims on my own behalf, thereby depriving me of due process rights and the opportunity to present a complete defense.

 

Relief Requested

  1. Based on the foregoing, I respectfully request that this Honorable Court grant my Motion to Intervene and allow me to be added as a defendant in this case.
  2. As an intervenor, I will diligently participate in all proceedings, comply with all court orders, and assert any necessary defenses and counterclaims to protect my interests.
  3. I further request that the Court provide me with all rights and privileges afforded to a named defendant, including the opportunity to respond to the Complaint, engage in discovery, present evidence, and argue motions.
  4. I also request that all necessary amendments to the pleadings, scheduling orders, and other relevant court documents be made to reflect my inclusion as a defendant in this case

 

Conclusion

For the reasons stated above, I respectfully request that this Honorable Court grant my Motion to Intervene and allow me to be added as a defendant in this case. By doing so, the Court will ensure the fair and complete adjudication of the issues and uphold the principles of due process.

 

Dated this XXX

 

Respectfully Submitted,

 

 

___________________________________

XXX

 

Food Hub By XXX

 

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