COMES NOW St. Louis Post-Dispatch L.L.C., by and through its undersigned attorneys, and pursuant to Rule 24 of the Federal Rules of Civil Procedure, moves this Court for leave to intervene in the above-styled action for the sole and limited purpose of opposing Defendants’ Motion for Protective Order for Deposition Transcripts and Recordings. In support of its Motion to Intervene, St. Louis Post-Dispatch L.L.C. states as follows:

1.  St. Louis Post-Dispatch L.L.C. (“Post-Dispatch”) is a limited liability company

registered to do business and in good standing in the State of Missouri, with its principal

business office and place of business in the City of St. Louis, Missouri.

2.  Post-Dispatch publishes the St. Louis Post-Dispatch, a newspaper of general

circulation throughout Missouri. The St. Louis Post-Dispatch covers events and reports on

proceedings in the courts of Missouri.

3.  The above-styled action involves claims of battery, false imprisonment, violations

of the Fair Labor Standards Act, and civil rights violations pursuant to 42 U.S.C. § 1983, § 1985,

and § 1988.

4.  Defendants Bob Wills, Betty Sue Wills, Sam Gerhardt, Deborah Gerhardt, Bo

Gerhardt, Julie Gerhardt, Drew Parrish, Bill Cavitt, Robert O’Briant, Aaron Smith, Robert

Kennedy, and Mike Pardos, d/b/a Mountain Park Boarding Company and Palm Lane Baptist

Church, Inc. (“Defendants”) have filed a Motion for Protective Order for Deposition Transcripts

and Recordings.

5.  In the Motion for Protective Order for Deposition Transcripts and Recordings,

Defendants ask the Court to place all recordings of the depositions of Defendants under seal,

maintain the seal on the deposition transcripts throughout the litigation, and prevent disclosure of

the substance of the depositions in any form to any persons or entities.

6.  Post-Dispatch seeks to intervene for the sole and limited purpose of opposing

Defendants’ Motion for Protective Order for Deposition Transcripts and Recordings.

7.  Granting Defendants’ Motion would infringe upon Post-Dispatch’s First

Amendment rights.

8.  Media entities such as Post-Dispatch have standing and a right to intervene and be

heard when a party attempts to restrict dissemination of information.

9.  A Memorandum in Support of Post-Dispatch’s Motion to Intervene is attached

hereto and incorporated herein.

10.  Contemporaneously herewith, Post-Dispatch files its Memorandum in Opposition

to Defendants’ Motion for Protective Order for Deposition Transcripts and Recordings.

WHEREFORE, St. Louis Post-Dispatch L.L.C. respectfully moves for an Order of this

Court granting its Motion to Intervene for the sole and limited purpose of opposing Defendants’

Motion for Protective Order for Deposition Transcripts and Recordings.