Epstein Survivors vs USVI: The USVI's Memorandum Of Law In Support Of Motion To Intervene (8/2/24)

Beyond The Horizon

The proposed intervenors seek to intervene in the case and request the disclosure of specific filings to the litigants and their counsel in the related action. Their main arguments are grounded in the principles of legal transparency and the need to protect their interests which may be affected by the outcome of the current litigation.
Key Points:

1. Legal Basis for Intervention:
   • Rule 24(a) - Intervention as of Right: The intervenors argue they have a right to intervene based on their substantial legal interests that may be impaired by the disposition of the case.
   • Rule 24(b) - Permissive Intervention: Alternatively, they seek permissive intervention on the grounds that their claim or defense shares a common question of law or fact with the main action.
2. Interests of the Intervenors:
   • The intervenors have a significant interest in the subject matter of the litigation that is not adequately represented by the existing parties.
   • Their involvement is crucial for protecting these interests and ensuring a fair and comprehensive resolution of the issues at hand.
3. Disclosure of Certain Filings:
   • The intervenors request the court to order the disclosure of specific filings that are relevant to their interests and necessary for them to participate meaningfully in the litigation.
   • The filings sought for disclosure contain information that may directly impact the intervenors' legal and factual assertions.
4. Precedent and Legal Standards:
   • The memorandum cites several precedents and legal standards supporting the notion that intervention and disclosure are appropriate under the circumstances.
   • It highlights that the courts have a history of allowing intervention and disclosure when it serves the interests of justice and transparency.
5. Public Interest and Transparency:
   • The motion emphasizes the public interest in ensuring transparency and accountability in judicial proceedings.
   • It argues that allowing intervention and disclosure will enhance the integrity of the judicial process and the equitable administration of justice.
6. Practical Considerations:
   • The intervenors assert that their participation will not unduly delay or prejudice the adjudication of the original parties' rights.
   • They propose a reasonable framework for their involvement that aligns with the procedural and substantive requirements of the court.

The memorandum concludes by urging the court to grant the motion to intervene and to order the disclosure of the relevant filings, asserting that doing so will protect the intervenors' interests, promote transparency, and serve the interests of justice.
(commercial at 9:51)
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Microsoft Word - 00257414.DOCX (courtlistener.com)