UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
SOUTHERN DIVISION
SAVE OUR CHILDREN TRUTH
COMMISSION; MELODY RODGERS;
MALACHI CHAPMAN; LAURIE
REYNOLDS; TIJANA VIDANOVIC;
TERESA GOIN; DESIREE PETERSON;
MOHOGANY HUNTER; NATASHA
LOACH; RENESHA TOMLIN;
SHANEQUAAUSTIN; DMITRI & LISA
CASH; RAYMOND SIPULT; GLENDA &
RUSS CODY; KESHIA HOLLIMAN;
KENYA CLOUD; KEONA BRADLEY;
KRISTEN CLARK-HASSEL;
ELIZABETH ANDREWS; WILLIAM &
EMILY O’DELL; KRISTINA
SINGLETON; SALLY BORGHESE;
ALAN MEDDOWS; CHRISTINA
ANDERSON; DEANNA ROBINSON;
LATASHA WOOLRIDGE; JESSICA
KIRBY; CONNIE FORD; WILNIESA
TURNER; JOY TYLER & ROBERT
LISBY JR.; GERRI HOOD; BRANDEE
RITSEMA; STEVEN BRADLEY;
RONISHA PETERS, HEIDI DAVIS;
KATHERINE THOMAS;
Plaintiffs
vs.
THE UNITED STATES OF AMERICA;
JOE BIDEN; KAMALA HARRIS;
XAVIER BECERRA; MERRICK B.
GARLAND; ET. AL.,
Defendants
Case No. 7:22-CV-178-FL
MOTION TO INTERVENE AS
PLAINTIFF-INTERVENOR
COMES NOW [ENTER NAME] (“intervenor”), and moves this court to intervene in
the above-captioned case as a party-plaintiff, pursuant to Rule 24 of the Federal Rules of
Civil Procedure. In support of this motion, the intervenor submits:
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1. The Plaintiffs’ Complaint was filed on or about October 11, 2022, in the
above-captioned case asserting claims under 42 U.S.C. § 1983; 42 U.S.C. § 1988; 42 U.S.C.§
1985; 42 U.S.C.§ 1986; Monell-Related Claims; RICO conspiracy to commit fraud; legal
malpractice; medical malpractice; breach of fiduciary duty; breach of implied and express
warranties; unconscionable contracts; 28 U.S.C. § 1361; Bivens Claims; and declaratory and
injunctive relief.
2. Rule 24(a) of the Federal Rules of Civil Procedure provides for intervention as
of right when the applicant claims an interest in the subject matter of the action which may be
affected. Rule 24(b) provides for permissive intervention when an applicant’s claim and the
main action have common questions of law or fact.
3. The intervenor meets the requirements of Rule 24(a) of the Federal Rules of
Civil Procedure in that she, just like the Plaintiffs in the action, seeks legal redress for the
deprivation, under color of law, of the rights of families and children as secured by the United
States Constitution, and other applicable law. Accordingly, disposing of the action without
the intervenor may as a practical matter impair or impede intervenor’s ability to protect its
interest, unless the existing parties adequately represent that interest.
4. The intervenor also meets the requirements of Rule 24(b) of the Federal Rules
of Civil Procedure in that both the Plaintiffs and the intervenor assert claims under 42 U.S.C.
§ 1983; 42 U.S.C. § 1988; 42 U.S.C.§ 1985; 42 U.S.C.§ 1986; Monell-Related Claims; RICO
conspiracy to commit fraud; legal malpractice; medical malpractice; breach of fiduciary duty;
breach of implied and express warranties; unconscionable contracts; 28 U.S.C. § 1361;
Bivens Claims; and declaratory and injunctive relief; and these claims are based on
substantially the same facts.
5. The intervenor’s proposed intervention is timely. No dispositive motions have
been filed with the Court, and discovery is not yet concluded.
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WHEREFORE, the intervenor requests that this Court allow it to intervene and
permit the intervenor to file a Complaint-in-Intervention. A proposed Order is attached
hereto.
Dated: __________
Respectfully submitted:
______________________________
[ENTER NAME]
ENTER ADDRESS
4
UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
SOUTHERN DIVISION
SAVE OUR CHILDREN TRUTH
COMMISSION; MELODY RODGERS;
MALACHI CHAPMAN; LAURIE
REYNOLDS; TIJANA VIDANOVIC;
TERESA GOIN; DESIREE PETERSON;
MOHOGANY HUNTER; NATASHA
LOACH; RENESHA TOMLIN;
SHANEQUAAUSTIN; DMITRI & LISA
CASH; RAYMOND SIPULT; GLENDA &
RUSS CODY; KESHIA HOLLIMAN;
KENYA CLOUD; KEONA BRADLEY;
KRISTEN CLARK-HASSEL;
ELIZABETH ANDREWS; WILLIAM &
EMILY O’DELL; KRISTINA
SINGLETON; SALLY BORGHESE;
ALAN MEDDOWS; CHRISTINA
ANDERSON; DEANNA ROBINSON;
LATASHA WOOLRIDGE; JESSICA
KIRBY; CONNIE FORD; WILNIESA
TURNER; JOY TYLER & ROBERT
LISBY JR.; GERRI HOOD; BRANDEE
RITSEMA; STEVEN BRADLEY;
RONISHA PETERS, HEIDI DAVIS;
KATHERINE THOMAS;
Plaintiffs
vs.
THE UNITED STATES OF AMERICA;
JOE BIDEN; KAMALA HARRIS;
XAVIER BECERRA; MERRICK B.
GARLAND; ET. AL.,
Defendants
Case No. 7:22-CV-178-FL
PROPOSED ORDER
Upon good cause shown, the intervenor’s Motion to Intervene as Plaintiff-Intervenor
is granted.
______________________________
[ENTER NAME]
ENTER ADDRESS
5
CERTIFICATE OF SERVICE
I hereby certify that on [ENTER DATE], copies of the foregoing document have
been sent to the parties in the following addresses:
[ENTER ADDRESSES]
DATED:
______________________________
[ENTER NAME]
ENTER ADDRESS
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