Legal Utah Motion to Intervene

Joel Ban (Utah Bar No. 10114)

Ban Law Office P.C.

170 S. Main #250

Salt Lake City, UT 84101

TEL: (801) 532-2447

FAX: (860) 770-6223

[email protected]

Katherine A. Meyer (pro hac vice to be submitted)

Caitlin T. Zittkowski (pro hac vice to be submitted)

Michelle D. Sinnott (pro hac vice to be submitted)

Meyer Glitzenstein & Crystal

1601 Connecticut Ave., NW, Suite 700

Washington, DC 20009

TEL: (202) 588-5206

FAX: (202) 588-5049

[email protected]

[email protected]

[email protected]

Attorney for Defendant-Intervenors;

American Wild Horse Preservation Campaign,

The Cloud Foundation, Return to Freedom,

John Steele, and Lisa Friday

IN THE UNITED STATES DISTRICT COURT - DISTRICT OF UTAH

CENTRAL DIVISION

WESTERN RANGELAND )

CONSERVATION ASSOCIATION, et al. )

)

Plaintiffs, )

) No. 2:14-cv-00327-PMW

v. )

) Judge Paul M. Warner

SALLY JEWELL in her official capacity as )

Secretary, UNITED STATES DEPARTMENT )

of the INTERIOR, et al. )

)

Defendants )

)

Case 2:14-cv-00327-PMW Document 15 Filed 06/17/14 Page 1 of 15

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MOTION TO INTERVENE BY AMERICAN WILD HORSE PRESERVATION

CAMPAIGN, THE CLOUD FOUNDATION, RETURN TO FREEDOM,

JOHN STEELE, AND LISA FRIDAY

Pursuant to Rule 24 of the Federal Rules of Civil Procedure, the American Wild Horse

Preservation Campaign (AWHPC), the Cloud Foundation (the Foundation), Return to

Freedom (RTF), John Steele, and Lisa Friday respectfully request leave to intervene in this

case as defendants to protect their professional, economic, aesthetic, recreational, educational,

and other interests in preserving the wild horses that use the public lands throughout the state of

Utah. As demonstrated below, the applicant Defendant-Intervenors meet all of the criteria for

intervention as of right under Rule 24(a): (1) the motion is timely; (2) they claim an interest in

the wild horses that are the subject of the action; (3) the disposition of the action without their

participation may impair their ability to protect those interests; and (4) neither the Plaintiffsthe

Western Rangeland Conservation Association (WRLCA), et al.nor the Defendantsthe

Bureau of Land Management (BLM), et al.adequately represent the applicant Intervenors

interests. Alternatively, the applicant Intervenors seek permissive intervention under Rule 24(b)

because they have claims and defenses that share[] with the main action[] common question[s]

of law and fact.

BACKGROUND

The Wild Free-Roaming Horses and Burros Act of 1971 (Wild Horse Act), 16 U.S.C.

1331 et seq., mandates the protection of wild horses. The Wild Horse Act provides that,

because wild free-roaming horses and burros are fast disappearing from the American scene,

they shall be protected from capture, branding, harassment, [and] death, and be considered in

the area where presently found, as an integral part of the natural system of the public lands. 16

U.S.C. 1331. In passing the Wild Horse Act, Congress declared that these creatures are living


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symbols of the historic and pioneer spirit of the West that enrich the lives of the American

people. Id.

Utah is home to thousands of wild horses and burros. See Decl. of Suzanne Roy (Roy

Decl.), Proposed Intervenors Exhibit (Ex.) A 7. According to BLM estimates, there are

over 3,000 wild horses currently living in Utah on 19 different Herd Management Areas, which

range in size from 32,000 to 376,000 acres. Id. Ranchers use these same public lands to graze

livestock at below-market, taxpayer-subsidized rates pursuant to permits issued under the Taylor

Grazing Act. See 43 U.S.C. 315. Although such grazing permits do not confer any entitlement

to such rates by the permittees, see Phil Taylor, Obama Admin Denies Petition to Raise Grazing

Fees on Public Lands, N.Y. Times, Jan. 19, 2011, http://www.nytimes.com/gwire/2011/01/19/19

greenwire-obama-admin-denies-petition-to-raise-grazing-f-43764.html, these ranchers

nevertheless view wild horses and burros as competition for the limited resources on the range,

see Compl. 38, 41, 59, ECF No. 2.

On April 30, 2014, WRLCA, the named partnership and corporation grazing permittees,

and the named individual Plaintiffs (hereinafter collectively referred to as WRLCA or

Plaintiffs) filed a Complaint seeking to compel BLM to remove wild horses not only from

private lands used by the Plaintiffs and their members to graze their livestock, but also from

federal and state-administered public lands across the state of Utah. See Compl. 20-21.

Specifically, the Plaintiff grazing permittees and WRLCA seek to require (1) the immediate

removal of what they assert are excess wild horses above Appropriate Management Levels

from several Herd Management Areas (HMAs) and one Herd Area (HA); and (2) the

immediate removal of excess wild horses from federal public lands, certain school section

lands that are managed by the Utah School and Institutional Trust Lands Administration


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(SITLA), and private lands outside of the aforementioned HMAs and HAs. See id. The

requested relief, if granted, would significantly tilt the scales on which the fate of Utahs wild

horses and burros is already precariously balanced.

Plaintiffs requested relief seeks to eliminate hundreds of wild horses from Utah in order

to reduce the competition for limited resources on the range and ensure ranchers unbridled

access to public lands for grazing livestock. According to Plaintiffs, there are at least 384

excess wild horses on the HMAs and HA at issue in this case, in addition to the excess wild

horses on public lands outside of these HMAs and HA, and Plaintiffs request that the Court order

BLM to immediately remove these animals. Id. 26-27, 58-59.

If granted, this completely unwarranted relief would devastate wild horse populations in

the state of Utah and damage the professional, aesthetic, and recreational interests of those, like

the proposed Intervenors, who enjoy viewing, studying, and photographing these national

treasures. It is for this reasonto prevent the unnecessary removal of hundreds of wild horses

from the range in Utahthat the proposed Intervenors move to intervene in this case.1

ARGUMENT

I. THE APPLICANT INTERVENORS ARE ENTITLED TO INTERVENE

AS A MATTER OF RIGHT.

Federal Rule of Civil Procedure 24(a) requires courts to grant intervention to any party

(1) [o]n timely motion, (2) who claims an interest relating to the property or transaction that

is the subject of the action, (3) who is so situated that disposing of the action may as a practical

matter impair or impede the movant's ability to protect its interest, and (4) whose interest is not

1 The proposed Intervenors do not believe the Plaintiffs are entitled to the relief they have

requested and, if granted intervention in this case, will so advise the Court. In addition, it is

important to note that the requested relief, if granted, could alter the way in which the Wild

Horse Act is interpreted and implemented, fundamentally changing BLMs management of wild horses throughout the West.


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adequately represent[ed] by the existing parties. See Oklahoma ex rel. Edmondson v. Tyson

Foods, Inc., 619 F.3d 1223, 1231 (10th Cir. 2010). The Court of Appeals for this Circuit follows

a liberal line in interpreting and applying these factors. WildEarth Guardians v. Natl Park

Serv., 604 F.3d 1192, 1198 (10th Cir. 2010) (citation omitted). It has explained that the criteria

for intervention as of right are not rigid, technical requirementsrather, these factors are

intended to capture the circumstances in which the practical effect on the prospective intervenor

justifies its participation in the litigation. Id. at 1198 (emphasis added) (citations omitted). As

demonstrated below, the potential practical effect of this action on the applicant Intervenors

justifies their participation in the litigation. In addition, as established below, the applicant

Intervenors meet all of the criteria for intervention as of right.

A. The Motion To Intervene Is Timely.

There can be no question that the motion to intervene is timely. The Complaint in this

action was filed on April 30, 2014, and the Defendants have not yet filed either an Answer or any

dispositive motion. In light of the relatively early stage of the litigation, the motion to

intervene satisfies the timeliness requirement. See Utah Assn of Counties v. Clinton, 255 F.3d

1246, 1251 (10th Cir. 2001).

B. The Applicant Intervenors Have Interests In The Wild Horses

That Are The Subject Of This Case.

The proposed Intervenors also satisfy the second requirement for intervention as of

righti.e., they claim[] an interest relating to the property or transaction that is the subject of

the action. WildEarth Guardians v. Natl Park Serv., 604 F.3d at 1198. The interest requirement

is not a mechanical rule. United States v. Albert Inv. Co., 585 F.3d 1386, 1392 (10th Cir. 2009)

(quoting San Juan Cnty. v. United States, 503 F.3d 1163, 1199 (10th Cir. 2007) (en banc)).

Rather, the interest test serves as a practical guide to disposing of lawsuits by involving as many


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apparently concerned persons as is compatible with efficiency and due process. Clinton, 255

F.3d at 1252 (emphasis added) (citation omitted). In addition, the Tenth Circuit . . . follows a

very broad interpretation of the interest requirement with respect to public law issues. San Juan

Cnty., 503 F.3d at 1201 (citations omitted); id. (explaining the requirements for intervention

may be relaxed in cases raising significant public interests) (citing Cascade Natural Gas Corp.

v. El Paso Natural Gas Co., 386 U.S. 129 (1967)).

Indeed, the Court of Appeals has found that the protection of wildlife, aesthetic

enjoyment of and desire to conserve the environment, and economic interests are all sufficient to

satisfy the interest requirement. See Clinton, 255 F.3d at 1252 (finding organizations whose

purpose is the protection and conservation of wildlife and its habitat have a protectable interest

in litigation that threatens those goals) (emphasis added) (citations omitted); id.

([E]nvironmental organizations and other special interest groups have been held to have a

sufficient interest for purposes of intervention as of right in cases in which their particular

interests were threatened.) (citation omitted); Coal. of Ariz./N.M. Counties for Stable Econ.

Growth v. Dept of the Interior, 100 F.3d 837, 841 (10th Cir. 1996) (finding wildlife

photographer and conservationist satisfied interest requirement for intervention as of right in case

regarding listing of spotted owl under Endangered Species Act); WildEarth Guardians v. Natl

Park Serv., 604 F.3d at 1198 (explaining that, in granting motions to intervene, the Court of

Appeals has recognized interests ar[ising] from a desire to advance conservation goals);

Utahns for Better Transp. v. U.S. Dept of Transp., 295 F.3d 1111, 1115 (10th Cir. 2002) (The

threat of economic injury from the outcome of litigation undoubtedly gives a petitioner the

requisite interest [to intervene as of right].).

The proposed Intervenors all have interests in protecting the wild horses that are the


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subject of this lawsuit. They wish to preserve, to the maximum extent possible, the wild horses

that live in these areas. Thus, as explained by its Director Suzanne Roy, applicant Intervenor

AWHPC is dedicated to protecting and preserving viable free-roaming herds of wild horses on

public lands for future generations. See Roy Decl., Ex. A 1. Moreover, AWHPCs supporters

enjoy viewing, studying, photographing, and filming the wild horses and burros that roam the

West, including within the state of Utah. Id. 2. AWHPC has for years engaged in advocacy to

protect these wild horses and burros, including by actively participating in numerous

administrative processes for BLM actions that affect wild horses, id. 3, and bringing litigation

of its own to protect wild horses, see, e.g., Am. Wild Horse Pres. Campaign v. Salazar, 859 F.

Supp. 2d 33 (D.D.C. 2012). For these reasons, AWHPC has been granted intervention in other

lawsuits seeking the removal of wild horses from public lands. See Order Granting Motion to

Intervene, Rock Springs Grazing Assn v. Salazar, Civ. No. 2:11-CV-00263-NDF (D. Wyo. Nov.

2, 2011) (Attach. 1 to Roy Decl.); Order, Nev. Assn of Counties v. U.S. Dept of the Interior,

Civ. No. 3:13-cv-00712-MMD-WGC (D. Nev. Apr. 2, 2014) (Attach. 2 to Roy Decl.).

Applicant Intervenor the Cloud Foundation is also dedicated to preserving wild horses on

the range. See Decl. of Ginger Kathrens, Ex. B 1. The Foundations Executive Director,

Ginger Kathrens, is an Emmy Award-winning producer, cinematographer, and writer who filmed

and produced three acclaimed PBS documentaries on wild horses in the West. Id. 3. Since

1994, Ms. Kathrens has been studying, photographing and filming wild horses in all ten western

states. Id. The Foundation, its executive director, and its supporters have educational, aesthetic,

photographic, and recreational interests in preserving the wild horses in Utah. Id. 2. Based on

these interests, the Foundation was granted intervention in another case involving the protection

of wild horse interests. See Order Granting Motion to Intervene, Rock Springs Grazing Assn v.


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Salazar, Civ. No. 2:11-CV-00263-NDF (D. Wyo. Nov. 2, 2011) (Attach. 1 to Roy Decl.).

Applicant Intervenor Return to Freedom also advocates for the protection of wild horses.

See Decl. of Neda DeMayo, Ex. C 1. In 1997, RTFs founder, Neda DeMayo, established the

sanctuary for relocating intact families of wild horses. Id. RTF also provides leadership

concerning the preservation of wild horses, focusing specifically on long-term genetic viability

and social well-being. Id. 3. RTF has pioneered the implementation of solution-based, non-

intrusive wild horse management methods at its sanctuary, such as the use of native PZP, a non-

hormonal birth control method that preserves the wild horses natural behavior. Id. Through

public outreach efforts at its sanctuary, such as hiking tours and photography clinics, RTF has

increased public awareness of wild horse issues and made progress toward shifting the wild

horse management paradigm. Id. 4. RTF and its members have interests in keeping wild

horses on the range so that they can continue viewing, studying, and photographing wild horses

in the West in their natural habitats, expressing the natural behaviors that stem from the horses

social interactions on the range. Id. 5.

Applicant Intervenor John Steele is an award-winning photographer who has been

photographing wild horses in Utah for the past fifteen years. See Decl. of John Steele, Ex. D

2, 4. Mr. Steele has sold his images as a result of his wild horse photographs being featured in art

exhibits and winning awards. Id. 5. Mr. Steele uses his photography as a tool for bringing

awareness to what is happening with our countrys wild horses in order to protect them. Id. 6.

In addition to his creative, economic, and conservation interests, Mr. Steele derives much

aesthetic enjoyment from watching wild horses run free on the range in Utah. Id. 7.

Applicant Intervenor Lisa Friday is a member of the Board of Directors of the applicant

Intervenor organization the Cloud Foundation. See Decl. of Lisa Friday, Ex. E 1. Inspired by a


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book chronicling the life of the wild horse Cloudthe Foundations namesakeMs. Friday has

devoted her time and energy to advocating for the protection of wild horses, with a particular

focus on the wild horses in Utah. Id. 2, 4. Ms. Friday has devoted much time and energy to

protecting these national treasures. Id. 3. She records video of and photographs wild horse

round-ups; attends meetings of the BLMs National Wild Horse and Burro Advisory Board;

discusses industry practices with contractors who conduct wild horse round-ups; meets with

Congressional representatives of the Appropriations Committee; and provides presentations on

wild horse issues at hunt clubs, riding clubs, and schools. Id. She has also adopted several wild

horses from the BLMs adoption program, including a direct descendant of Cloud. Id. Ms.

Friday derives great aesthetic enjoyment from viewing wild horses on the range. She has visited

several HMAs in Utah to view the wild horses, and she will be making her annual visits again in

June 2014. Id. 5-6.

All of the applicant Intervenors interests are more than sufficient to qualify for

intervention as of right under Rule 24(a). See Clinton, 255 F.3d at 1251-52; Coal. of Ariz., 100

F.3d at 841; San Juan Cnty., 503 F.3d at 1201.

C. Disposition of This Case May Impair The Ability Of The Applicant Intervenors To Protect Their Interests.

As to the third factor for intervention as of right under Rule 24, disposition of this lawsuit

may certainly impair [the applicant Intervenors] ability to protect their interest[s]. Clinton,

255 F.3d at 1253. This requirement presents a minimal burdenthe applicant intervenor must

show only that impairment of its substantial legal interest is possible if intervention is denied.

WildEarth Guardians v. Natl Park Serv., 604 F.3d at 1199 (emphasis added) (citations omitted).

Further, because the rule refers to impairment as a practical matter, the Court is not limited to

[considering] consequences of a strictly legal nature when determining whether the applicant


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Intervenors have fulfilled this requirement, though the stare decisis effect of a judgment is

sufficient impairment for intervention under Rule 24(a)(2). Clinton, 255 F.3d at 1253-54.

Here, Plaintiffs requested relief, if granted, will undoubtedly impair or impede the

applicant Intervenors interest in preserving wild horses in Utah, including areas addressed by

the Complaint. See id. at 1254. Indeed, the Plaintiffs requested reliefa court order compelling

BLM to immediately remove wild horses from the HMAs and HA at issue, as well as the public

lands and SITLA lands outside of these HMAs and HAs, Compl. 20-21poses a direct threat to

the proposed Intervenors interests in preserving these wild horses in their current habitat. See

Utahns for Better Transp., 295 F.3d at 1116 (examining plaintiffs complaint and requested relief

to determine whether applicant intervenors interests will be impaired by cases disposition).

As explained supra, the applicant Intervenors aesthetic, recreational, educational,

photographic, and economic interests depend on the presence of wild horses on the range in

Utah. The Plaintiffs requested relief, if granted, would not only impair these interests but would

also preclude the applicant Intervenors from advocating that the same horses Plaintiffs seek to

have removed should be preserved on the range. See Clinton, 255 F.3d at 1253-54 (citations

omitted). Thus, the applicant Intervenors fulfill the minimal burden of showing the possibility

that disposition of this lawsuit could harm their ability to protect their interests. WildEarth

Guardians v. Natl Park Serv., 604 F.3d at 1199 (citations omitted).

D. The Existing Parties Do Not Adequately Represent The Interests Of The Applicant Intervenors.

The interests of the applicant Intervenors also satisfy the fourth requirement for

intervention as of right under Rule 24their interests may not be adequately represented by

existing parties. Albert Inv. Co., 585 F.3d at 1391. The burden of demonstrating inadequacy for

intervention as of right is also a minimal one, requiring only a showing that representation


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may be inadequate. Utahns for Better Transp., 295 F.3d at 1117 (quoting Clinton, 255 F.3d at

1254); accord WildEarth Guardians v. Natl Park Serv., 604 F.3d at 1200 (explaining the

possibility that the interests of the applicant [intervenor] and the parties may diverge need not

be great in order to satisfy this . . . burden) (citation omitted); WildEarth Guardians v. U.S.

Forest Serv., 573 F.3d 992, 996 (10th Cir. 2009).

The applicant Intervenors interests in protecting wild horses by preserving their presence

on the range in Utah are not represented by the other parties to the litigation. The Plaintiffs seek

a court order for immediate removal of wild horses from one Herd Area, several Herd

Management Areas, and other public and SITLA lands. Compl. 20-21. The requested relief is

directly adverse to applicant Intervenors professional, aesthetic, and educational interests, which

depend upon maintaining wild horses in their natural habitat. The Plaintiffs therefore do not

represent any of the applicant Intervenors interests in this litigation.

The government Defendants also do not adequately represent the proposed Intervenors

interests in this action. As the Court of Appeals has explained, the government's representation

of the public interest generally cannot be assumed to be identical to the individual parochial

interest of a particular member of the public merely because both entities occupy the same

posture in the litigation. Clinton, 255 F.3d at 1255-56. Rather, when litigating on behalf of the

general public, the government is obligated to consider a broad spectrum of views, many of

which may conflict with the particular interest of the would-be intervenor. Id. at 1256. As a

result, [w]here a government agency may be placed in the position of defending both public and

private interests, the burden of showing inadequacy of representation is satisfied. WildEarth

Guardians v. Natl Park Serv., 604 F.3d at 1200 (emphasis added) (citation omitted).

BLM is responsible for balancing the public and private interests in the public lands


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under its jurisdiction under various statutes.2 These statutes require the Defendants to consider a

broad spectrum of interests, many of which conflict with the particular interests of the applicant

Intervenors in this litigation. Indeed, for these very reasons, AWHPC, the Cloud Foundation, and

other individuals with similar interests in preserving wild horses on the range were granted

intervention in other suits initiated by grazing interests against BLM. See Order Granting Motion

to Intervene, Rock Springs Grazing Assn v. Salazar, Civ. No. 2:11-CV-00263-NDF (D. Wyo.

Nov. 2, 2011) (Attach. 1 to Roy Decl.); Order, Nev. Assn of Counties v. U.S. Dept of the

Interior, Civ. No. 3:13-cv-00712-MMD-WGC (D. Nev. Apr. 2, 2014) (Attach. 2 to Roy Decl.).

Because of these various statutory mandates, the government Defendants simply cannot

be counted on to make the same legal and factual arguments that will be advanced by the

applicant Intervenors. See WildEarth Guardians v. Natl Park Serv., 604 F.3d at 1200 (We have

repeatedly recognized that it is on its face impossible for a government agency to carry the task

of protecting the public's interests and the private interests of a prospective intervenor.)

(citations omitted). In fact, the BLM has shown a propensity in the past to settle lawsuits brought

by interests adverse to the applicant Intervenors in ways that do not protect wild horses. See, e.g.,

Consent Decree, Wyoming v. U.S. Dept. of Interior, Civ. No. 2:03-00169 (D. Wyo. Aug. 29,

2003) (Attach. 2 to Steele Decl.). The proposed Intervenors seek to intervene in this case to

ensure not only that Plaintiffs do not obtain the unwarranted court-ordered relief they request,

but also to prevent the government from settling with Plaintiffs in ways that would be adverse to

their interests.

2 These statutes include (1) the Wild Horse Act, 16 U.S.C. 1331 et seq., which requires the

preservation of wild horses on public lands; (2) the Taylor Grazing Act, 43 U.S.C. 315 et seq.,

which authorizes the government to issue permits allowing livestock to graze on public lands;

and (3) the Federal Land Policy Management Act, 43 U.S.C. 1701 et seq., which requires

BLM to manage the public lands under its jurisdiction pursuant to multiple use principlesi.e., for a wide range of recreational and economic uses. See 43 U.S.C. 1702(c).


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Mr. Steele also has private economic, professional, and artistic interests in preserving

wild horses on the range that do not belong to the public at large, and Defendants do notand

cannotrepresent these private interests. See WildEarth Guardians v. U.S. Forest Serv., 573

F.3d at 997 ([T]he Tenth Circuit has recognized that the federal government is inherently

responsible for protecting and representing the public interest and that, therefore, its public

mission and necessary public neutrality inherently conflict with the interests of intervening

private parties.) (citation omitted); id. at 996 (explaining the intervenors showing of inadequate

representation is easily made when the party upon which the intervenor must rely is the

government, whose obligation is to represent not only the interest of the intervenor but the public

interest generally, and who may not view that interest as coextensive with the intervenor's

particular interest) (emphasis added) (citation omitted).

The applicant Intervenors will also contribute necessary factual and legal elements to this

case that the existing parties may very well neglect or avoid. AWHPC, the Cloud Foundation,

RTF, Mr. Steele, and Ms. Friday represent a diverse set of organizations and individuals whose

professional, aesthetic, recreational, educational, economic, and other interests depend on the

protection and preservation of free-roaming wild horses. They will bring their distinct

perspectives to this litigation, as well as their vast expertise and first-hand experience concerning

wild horse protection, BLMs management practices, and the devastating impact livestock

grazing has on lands used by wild horses and burros. See, e.g., Roy Decl., Ex. A 1-3, 6. This

knowledge may well prove invaluable to the Courts resolution of this case.

Therefore, because not all interests implicated by the issues raised by the Complaint will

be presented by the existing parties, the applicant Intervenors easily meet the final prong for

intervention as of right under Rule 24(a).


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II. IN THE ALTERNATIVE, THE APPLICANT INTERVENORS SHOULD BE

GRANTED PERMISSIVE INTERVENTION.

Although the proposed Intervenors amply satisfy all of the criteria for intervention as of

right under Rule 24(a), in the alternative this Court should exercise its discretion to allow the

applicants to intervene in this action as a permissive matter under Rule 24(b). Rule 24(b)

provides that such intervention should be granted when, on timely motion the applicant, has a

claim or defense that shares with the main action a common question of law or fact.

The requirements for permissive intervention are readily met here. As already

established, the motion to intervene is timely. See supra p. 5. In addition, applicant Intervenors

easily satisfy the common question prong for permissive intervention, as they intend to rely on

the same laws as the other parties regarding the management of public lands and wild horses, as

well as many of the same facts cited in the Complaint, albeit to argue that the Court should not

grant the requested relief. As a result, the Court should exercise its discretion and allow the

proposed Intervenors to intervene here. See United States ex rel. Precision Co. v. Koch Indus.,

Inc., 31 F.3d 1015, 1017 (10th Cir. 1994) (interpreting Rule 24(b)).

CONCLUSION

For all of the foregoing reasons, the motion to intervene should be granted.

Respectfully submitted,

/s/____________________________

Joel Ban

(Utah Bar No. 10114)

BAN LAW OFFICE P.C.

170 S. Main #250

Salt Lake City, UT 84101

(801) 532-2447


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/s/____________________________

Katherine A. Meyer (pro hac vice forthcoming)

(D.C. Bar No. 244301)

Caitlin T. Zittkowski (pro hav vice forthcoming)

(California Bar No. 290108)

Michelle D. Sinnott (pro hac vice forthcoming)

(Virginia Bar No. 85563)

MEYER GLITZENSTEIN & CRYSTAL

1601 Connecticut Ave., N.W. Suite 700

Washington, D.C. 20009

(202) 588-5206

Counsel for Defendant-Intervenors, American Wild

Horse Preservation Campaign, The Cloud

Foundation, Return to Freedom, John Steele, and

Lisa Friday

Date: June 17, 2014


Documents

Legal Utah Motion to Intervene