DECHERT LLP

By: Robert C. Heim (Pa. 15758)

Alexander R. Bilus (Pa. 203680)
William T. McEnroe (Pa. 308821)
Joanna L. Barry (Pa. 311438)
Nathaniel T. Hopkins (Pa. 315878)
Cira Centre
2929 Arch Street
Philadelphia, PA 19104-2808
(215) 994-4000

David S. Cohen (Pa. 88811)
3320 Market Street
Philadelphia, PA 19104
(215) 571-4714

Attorneys for Petitioners

IN THE COMMONWEALTH COURT OF PENNSYLVANIA
________________________________

SASHA BALLEN, et al.,
Petitioners,
v.
MICHAEL WOLF, SECRETARY OF
HEALTH OF THE
COMMONWEALTH OF
PENNSYLVANIA,
Respondent.
________________________________


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NO. 481 MD 2013
APPLICATION FOR LEAVE TO INTERVENE
Received 09/16/2014 Commonwealth Court of Pennsylvania
Filed 09/16/2014 Commonwealth Court of Pennsylvania
481 MD 2013


Putative Intervenor Couples (Intervening Couples) are additional same-sex
couples who, like the Petitioners in this case, were granted marriage licenses by
Montgomery County Clerk D. Bruce Hanes (Clerk Hanes) in 2013. Pursuant to
Pa. R.A.P. 1531(b), Intervening Couples seek leave to intervene to join Petitioners
in this lawsuit so that they can become parties to the Stipulation of Settlement and
Dismissal. In support of this Petition, Intervening Couples aver as follows:
1. On July 23, 2013, Clerk Hanes publicly announced that his office would
begin issuing marriage licenses to same-sex couples. Pursuant to this
announcement, the following Intervening Coupleslike Petitionerssought and
obtained marriage licenses from Clerk Hanes:
a) Julius A. Kawarsky and Alexander Soto;
b) Kendra D. Driskill and Regina S. Koilparampil;
c) Alba Martinez and Roberta Trombetta;
d) Jessica Parker and Blair Berger.
2. A person may seek leave to intervene in an original jurisdiction petition for
review before this Court by filing a petition containing a concise statement of his
or her interests and the grounds upon which intervention is sought. See Pa. R.A.P.
1531(b).
3. A person is entitled to intervene in a pending case if the determination of
such action may affect any legally enforceable interests whether or not such person
may be bound by a judgment in the action. Pa. R.C.P. 2327(4). If a putative

intervenor satisfies this requirement, and no grounds for refusing the petition exist
under Pa. R.C.P. 2329, [a]llowance of intervention is mandatory. T.H. Props.,
L.P. v. Upper Salford TShip Bd. of Supervisors, 970 A.2d 495, 499 (Pa. Cmwlth.
2009).
4. Intervening Couples seek to participate in this lawsuit because it may affect
their interests. See Pa. R.C.P. 2327(a).
5. Intervening Couples interests in this lawsuit are identical to those of the
current Petitioners.
6. Counsel for Respondent Michael Wolf does not oppose this Petition.


WHEREFORE, Intervening Couples respectfully ask that this Court grant
their Petition to Intervene and allow them to join in the Stipulation of Settlement
and Dismissal.
Respectfully submitted,
/s/ Robert C. Heim -
Dated: September 16, 2014 Robert C. Heim (Pa. 15758)
Alexander R. Bilus (Pa. 203680)
William T. McEnroe (Pa. 308821)
Joanna L. Barry (Pa. 311438)
Nathaniel T. Hopkins (Pa. 315878)
Dechert LLP
Cira Centre
2929 Arch Street
Philadelphia, PA 19104-2808

David S. Cohen (Pa. 88811)
Drexel University School of Law
3320 Market Street
Philadelphia, PA 19104

Attorneys for Petitioners



CERTIFICATE OF SERVICE
I certify that the foregoing Application for Leave to Intervene was served
upon the interested parties listed below on September 16, 2014 via the PACFile
system and prepaid First Class U.S. Mail, addressed as follows:
William H. Lamb
24 East Market Street
P.O. Box 565
West Chester, PA 19381
(610) 430-8000

Counsel for Defendant Wolf




Dated: September 16, 2014 /s/ Nathaniel T. Hopkins -
Nathaniel T. Hopkins
Dechert LLP
Cira Centre, 2929 Arch St
Philadelphia, PA 19104



IN THE COMMONWEALTH COURT OF PENNSYLVANIA
________________________________

SASHA BALLEN, et al.,
Petitioners,
v.
MICHAEL WOLF, SECRETARY OF
HEALTH OF THE
COMMONWEALTH OF
PENNSYLVANIA,
Respondent.
________________________________


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NO. 481 MD 2013
ORDER
AND NOW, this ______ day of ______________, 2014, upon consideration
of the Application for Leave to Intervene, and any response thereto, it is hereby
ORDERED that said Application for Leave to Intervene is GRANTED.

BY THE COURT:

________________________
, P.J.