Motion to Intervene

t1NITED STATES DISTRICT COURT

FOR THE DISTRICT OF RHODE ISLAND
MARK AHLQUIST, as next friend, parent
and guardian of JESSICA AHLQUIST, a
minor,
Plaintiff,
v. C.A. No. 11-138L
CITY OF CRANSTON, by and through
Robert F. Strom, in his capacity as
Director of Finance, and by and through
the School Committee of the City of
Cranston, and SCHOOL COMMITTEE OF THE
CITY OF CRANSTON, by and through Andrea
Iannazzi, in her capacity as Chair of the
School Committee of the City of Cranston,
Defendants.
MOTION TO INTERVENE
Now comes the petitioners, Michael Motaranni, Christian
Frangos, Olivia Frangos, Carolyn Mesagno, Lori McClain, Jared
McMullen and Ronald L'Heureux moves this court to intervene in
the above entitled matter. Your petitioners aver that:
1. Denial of intervention would impair or impede their
ability to protect interests the above entitled matter.
2. That petitioners have a right as a matter of law to
intervene as defendants did not adequately represent them
and issues brought to their attention, for whatever reason
were not brought before the court and absent from this
court's decision.
3. Petitioners have a right based on the subject of the action
being tax paying residents of Cranston
1
students of
1
Case 1:11-cv-00138-L-DLM Document 35 Filed 03/07/12 Page 1 of 3 PageID #: 598
Cranston West, and or prior students of first graduating
class of 1963, to wit; authors and gift givers who believed
this piece of history would remain undisturbed in the place
of their choice.
4. That that as similar case on a pledge issue was decided in
favor of the interyeners and had that case been sited,
outcome would have been different had the issues been
argued in support and with the defendant's arguments, and;
5. The ACLU will .. unjustifiably enriched by their attempt to
extract funds from the Cranston School committee on
fraudulent grounds they are fully cognizant of.
Wherefore, for the reasons also set forth in the
accompanying memoranda your petitioners respectfully
request this Motion be granted.
Respectfully Submitted,
Christian Frangos and Olivia Frangos
2330 Cranston St.
Cranston, RI 02920
I

L'Heureux
213 Waterman Ave.
North Providence RI 02911
/ '161)- 'f ¥7- {p?Js-
2
Case 1:11-cv-00138-L-DLM Document 35 Filed 03/07/12 Page 2 of 3 PageID #: 599
Michael Motaranhi,
Cranston, RI
Lori Mcclain •
23 Nicholas Ave
Groton Ct. 06340
3
Case 1:11-cv-00138-L-DLM Document 35 Filed 03/07/12 Page 3 of 3 PageID #: 600

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