`
`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF OKLAHOMA
`
`UNITED STATES OF AMERICA,
`
`Plaintiff,
`
`–v–
`
`JEFFREY LOWE, LAUREN LOWE,
`GREATER WYNNEWOOD EXOTIC
`ANIMAL PARK, LLC, and TIGER KING,
`LLC,
`
`Defendants.
`
`Case No. 6:20-cv-00423-JFH
`
`MOTION TO INTERVENE OF PEOPLE FOR THE ETHICAL TREATMENT OF
`ANIMALS, INC., PROPOSED INTERVENOR-PLAINTIFF
`
`Proposed Intervenor-Plaintiff People for the Ethical Treatment of Animals, Inc. (“PETA”),
`
`through its undersigned counsel, pursuant to Fed. R. Civ. P. 24 and LCvR 7.1, respectfully moves
`
`this Court for leave to intervene as a party plaintiff under Rule 24(a) or, in the alternative, Rule
`
`24(b) in the above-captioned matter. In support of this Motion to Intervene, PETA incorporates
`
`the facts, arguments and authorities set forth in its Brief in Support filed this same date.
`
`Dated: April 28, 2021
`
`1
`
`
`
`6:20-cv-00423-JFH Document 85 Filed in ED/OK on 04/28/21 Page 2 of 2
`
`Respectfully Submitted,
`
`
`PEOPLE FOR THE ETHICAL
`TREATMENT OF ANIMALS, INC.
`
`/s/ Heather L. Hintz
`Thomas G. Wolfe, OBA NO. 11576
`Heather L. Hintz, OBA No. 14253
`Mark E. Hornbeek, OBA No. 33198
`PHILLIPS MURRAH P.C.
`Corporate Tower, 13th Floor
`101 North Robinson Avenue
`Oklahoma City, Oklahoma 73102
`Telephone: (405) 235-4100
`
`Facsimile: (405) 235-4133
`tgwolfe@phillipsmurrah.com
`hlhintz@phillipsmurrah.com
`mehornbeek@phillipsmurrah.com
`
`Attorneys for Proposed Intervenor-Plaintiff
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that the foregoing was served on April 28, 2021, via the Court’s CM/ECF
`system, on the following:
`
`Mary Hollingsworth
`mary.hollingworth@usdov.gov
`Briana Strippoli
`briana.strippoli@usdoj.gov
`Michael J. O’Malley
`Micahel.O’Malley@usdoj.gov
`Robert M. Norway
`robert.m.norway@usdoj.com
`Susan S. Brandon
`susan.brandon@usdoj.gov
`
`Attorneys for Plaintiff the United States of America
`
`Daniel J. Card
`Dan@cardlawok.com
`
`Attorney for Defendants
`
`/s/ Heather L. Hintz
`2
`
`
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