UNITED STATES DISTRICT COURT FOR THE ... - Letters Blogatory

Case 1:11-mc-91078-WGY Document 31 Filed 12/05/11 Page 20 of 21
Whereas the Intervenors could have filed an original action seeking preliminary
injunctive relief and moved to have such action consolidated with the present matter, the
Intervenors, respecting judicial economy and not intending to delay this matter, chose to be
heard through intervention.
E Conclusion
Based on all of the foregoing, the requirements of Fed. R. Civ. P. 24 (a)(2) and (b) (2)
have been satisfied and exceeded and that intervention should be permitted. If, however, this
Court determines that intervention under Fed. R. Civ. P. 24 (a) or (b) is not appropriate, the
Intervenors' request that the Complaint for Intervention be treated as an original complaint.
Dated: December 5, 2011
Long Island City, New York
Respectfully submitted,
DORNAN & ASSOCIATES PLLC
By: /s/Eamonn Dornan
______________________
EAMONN DORNAN,ESQ
Appearing Pro Hac Vice
1040 Jackson Avenue, Suite 3B
Long Island City, New York 10017
Tel: (718) 707-9997
Fax: (718) 228-5940
LAW OFFICES OF JAMES J. COTTER, III
MA BBO 101620
By: /s/James J. Cotter, III
_____________________
JAMES J. COTTER, III
(MA BBO 101620)
Post Office Box 270
N. Quincy, MA 02171
Tel. 617 899-0549
Fax 617 984-5858
Attorneys for Intervenors
Ed Moloney and Anthony McIntyre
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