Motion to Intervene

MOTION FOR LEAVE TO INTERVENE AND FILE INTERVENOR'S COMPLAINT

IN THE CIRCUIT COURT OF COUNTY, MISSISSIPPI

, BY AND THROUGH HIS/HER

FATHER/MOTHER AND NEXT FRIEND, PLAINTIFF

VS.

DEFENDANT

INTERVENOR

NO.

(""), moves this Court for an Order granting it leave to intervene in the above styled and numbered cause pursuant to Rule 24(a) of the Mississippi Rules of Civil Procedure, 'and would respectfully show the Court the following;

1. Plaintiff herein has alleged that Defendant negligently operated a motor vehicle and that as a result Plaintiff has incurred damages.

2. Pursuant to a contract issued by which provides hospital and health/medical benefits for the Plaintiff or on his/her behalf (Contract No. ), Petitioner herein has paid, to date, $ in benefits on behalf of the Plaintiff under said contract.

3. Pursuant to the terms of the contract under which said payments have been made, has a right of subrogation and is entitled to repayment of all amounts paid by it to or on behalf of Plaintiff

WHEREFORE, PREMISES CONSIDERED, respectfully moves this Court for leave to intervene in this cause as a Party-Plaintiff, and it be allowed to file its Intervenor's Complaint, a true copy of which is attached hereto as Exhibit "A", for the protection of its rights under the contract referred to hereinabove.

RESPECTFULLY SUBMITTED, this the day of

BY:

OF COUNSEL:

CERTIFICATE OF SERVICE

I, , do hereby certify that I have on this date mailed by the United States Mail, postage prepaid, a true and correct copy of the above foregoing document to the following counsel of record:

This the day of