9 If the Court does not deem Rule 24 to be the proper vehicle to join Proposed Intervenors as plaintiffs to this Action, Plaintiffs and Proposed Intervenors would respectfully request the Court to order the same relief under any other Rule or statute it may deem more appropriate. E.g., Wicks, 2006 U.S. Dist. LEXIS 1947 (this Court permitted additional plaintiffs to be added to an existing § 36(b) action pursuant to plaintiffs’ motion to amend under Rule 15). Case 1:04-cv-10584-GAO Document 116 Filed 05/03/2006 Page 25 of 28 21 Dated: May 3, 2006 Respectfully submitted, MOULTON & GANS, P.C. By: __/s/ Nancy Freeman Gans________ Nancy Freeman Gans (BBO #184540) 55 Cleveland Road Wellesley, Massachusetts 02481 (781) 235-2246 Liaison Counsel For Plaintiffs WEISS & LURIE Joseph H. Weiss Richard A. Acocelli Julia J. Sun 551 Fifth Avenue, Suite 1600 New York, New York 10176 (212) 682-3025 MILBERG WEISS BERSHAD & SCHULMAN LLP Jerome M. Congress Janine L. Pollack Kim

DATED this 18th day of December, 2012. TEDESCO LAW GROUP By: /s/ Anil S. Karia ANIL S. KARIA , OSB No. 063902 E-mail: anil@miketlaw.com Tedesco Law Group 3021 NE Broadway Portland, OR 97232 Telephone: 866-697-6015 Facsimile: 503-210-9847 Attorneys for Intervener-Defendant Portland Police Association Case 3:12-cv-02265-SI Document 8 Filed 12/18/12 Page 35 of 36 Page ID#: 165 Page 1 – CERTIFICATE OF SERVICE CERTIFICATE OF SERVICE I hereby certify that I served the foregoing MEMORANDUM IN SUPPORT OF INTERVENER-DEFENDANT PORTLAND POLICE ASSOCIATION'S FRCP 24 MOTION TO INTERVENE on: S. Amanda Marshall Adrian L. Brown Billy J. Williams United States Attorney's Office District of Oregon 1000 SW Third Ave., Ste 600 Portland, OR 97204-2902 Attorneys for Plaintiff United States Thomas E. Perez Roy L. Austin, Jr. Jonathan M. Smith Laura Coon R. Jonas Geissler Michelle Jones Civil Rights Division U.S. Department of Justice 50 Pennsylvania Ave., NW Washington, D.C. 20530 Attorneys for Plaintiff United States James H. Van Dyke City Attorney's Office 1221 SW Fourth Ave., Ste 430 Portland, OR 97204 Attorney for Defendant City of Portland by service electronically pursuant to LR 100.

Regardless, Read and Suzuki’s failure to take any action to protect their interests (or Case 2:15-cv-00957-FMO-PJW Document 149 Filed 09/08/16 Page 20 of 21 Page ID #:2539 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -16- Case No. :15-CV-00957-FMO-PJW AMIRA DEFENDANTS’ OPPOSITION TO READ AND SUZUKI’S MOTION FOR RELIEF UNDER FRCP 60(B) AND FRCP 24 those of the proposed class) prior to the entry of judgment strongly suggests they are inadequate lead plaintiffs. The Court should, therefore, deny Read and Suzuki’s motion to be appointed co-lead plaintiffs and deny their selection of co-lead counsel as well.4 CONCLUSION For the foregoing reasons, the Amira Defendants respectfully request that the Court deny Read and Suzuki’s motion in its entirety and deny all relief sought therein.

In addition, Syngenta Case 3:08-cv-00484-JSW Document 23 Filed 04/17/2008 Page 20 of 21 ____ CASE NO. 3:08-cv-00484-JSW NOTICE OF MOTION & MOTION TO INTERVENE; MEMORANDUM IN SUPPORT THEREOF -15- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 respectfully requests that the Court grant permissive intervention pursuant to FRCP 24(b)(2) to address the merits of Plaintiffs’ NEPA claims. In the alternative, Syngenta respectfully requests that the Court grant Syngenta permissive intervention on all Plaintiffs’ claims pursuant to FRCP 24(b)(2). Respectfully submitted, Dated: April 17, 2008 /s/ Lowell M. Rothschild LOWELL M. ROTHSCHILD VENABLE LLP 575 7th Street N.W. Washington, D.C. 20004-1601 Phone: 202.

Titan’s claims and defenses—that is, its direct and substantial interests in this action— clearly “share[] with the main action . . . common question[s] of law or fact.” FRCP 24(b); see also New York v. Abraham, 204 F.R.D. 62, 66 (S.D.N.Y. 2001) (permitting intervention where the intervenor’s proposed defense had issue of law in common with main action). As established above, this Court’s interpretation of the Intercreditor Agreement may impact Titan’s rights under that agreement, including adequate protection payments made to Titan as a secured creditor of TCEH.

V. CONCLUSION. For the foregoing reasons, the court should find the Applicants have a right to intervene under Federal Rule of Civil Procedure 24(a). In the alternative, the Court should permit the Applicants to intervene permissively pursuant to Rule 24(b).

CONCLUSION The Court should grant North Dakota’s motion to intervene as of right as a defendant for all pursuant to Fed. R. Civ. P. 24(a)(2). In the alternative, The State should be granted permissive intervention pursuant to Fed. R. Civ. P. 24(b). Respectfully submitted this 19th day of February, 2015.

Conclusion For the foregoing reasons, the NAM respectfully requests that the Court grant its motion for leave to intervene as of right pursuant to Fed. R. Civ. P. 24(a) with respect to all of Plaintiffs’ claims. In the alternative, the NAM requests that it be granted permissive intervention pursuant to Fed. R. Civ. P. 24(b) with respect to all of Plaintiffs’ claims. Dated: October 31, 2011 Respectfully submitted, SIDLEY AUSTIN LLP By: /s/ Samuel R. Miller Attorneys for Proposed Intervenor-Defendant The National Association of Manufacturers Case 1:11-cv-02235-RLW Document 65 Filed 10/31/11 Page 18 of 18

Thus, granting the Committee’s Motion would result in undue delay or prejudice. CONCLUSION For the reasons stated herein, the Committee’s Motion for intervention as of right under Fed. R. Civ. P. 24(a)(2) and/or for permissive intervention under Fed. R. Civ. Pro. 24(b)(1)(B) should be granted. The Committee respectfully requests an oral hearing on this Motion.

35 Evans v. Jeff D., 475 U.S. 717, 726-27 (1986). Case 3:12-cv-02265-SI Document 26 Filed 01/22/13 Page 12 of 13 Page ID#: 587 Page 13 – CITY OF PORTLAND'S RESPONSE IN SUPPORT OF CONDITIONAL GRANT OF PORTLAND POLICE ASSOCIATION’S FRCP 24 MOTION TO INTERVENE PORTLAND CITY ATTORNEY’S OFFICE 1221 SW 4TH AVENUE, RM 430 PORTLAND, OREGON 97204 (503) 823-4047 Court’s authority to insert their preferred terms. VIII.