UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIA
., ) Civil Action No. 11-1928 (JEB))Plaintiffs, ))
FRIENDS OF THE EARTH, INC.
AND SIERRA CLUB
TO INTERVENE AS DEFENDANTS
., ))Defendants. ))
Pursuant to Federal Rules of Civil Procedure 24(a), (b), (c), and Local Rule 7(j) of thisCourt, Friends of the Earth, Inc. and Sierra Club (collectively, “Movants”) hereby move thisCourt for leave to intervene in this proceeding as defendants. Movants seek intervention as of right under Rule 24(a)(2), or, in the alternative, permissive intervention under Rule 24(b)(1). Insupport of this motion, Movants submit the accompanying Memorandum of Points andAuthorities, attached Exhibits, and Proposed Order, as well as a proposed Motion to Dismiss andProposed Order pursuant to Rule 24(c).Movants have conferred with the parties and counsel for the parties. Government counselhave indicated to Counsel for Movants that Defendants, including all Federal and Districtagencies and officials sued by Plaintiffs, take no position on Movants’ intervention at this time.Plaintiffs, who are pro se, are not unified as to whether they intend to oppose this motion.Pursuant to the procedure set forth in Rule 24(c), Movants state the following as groundsfor this Motion to Intervene:
Case 1:11-cv-01928-JEB Document 14 Filed 03/06/12 Page 1 of 26