[Based upon the Complaint, Form 15]

IN THE CIRCUIT COURT OF ______________ COUNTY, MISSISSIPPI

A . B., Plaintiff

v.

Civil Action, File No. _____________________

C. D., Defendant

E. F., Applicant for Intervention

MOTION TO INTERVENE AS A DEFENDANT

E. F. moves to intervene as a defendant in this action to assert the defenses set forth in his proposed answer, a copy of which is attached hereto, on the ground that he is the owner of the automobile alleged in the Complaint to have collided with the vehicle occupied by the plaintiff and as such as a defense to plaintiffs claim presenting both questions of law and of fact which are common to the main action.

________________________________

Attorney for E. F.

Applicant for Intervention

__________________________

__________________________

Address

NOTICE OF MOTION

[Contents the same as in Form 22]

IN THE CIRCUIT COURT OF __________________ COUNTY, MISSISSIPPI

A. B., Plaintiff

v.

Civil Action, File No. __________________

C. D., Defendant

E. F., Intervener

INTERVENER’S ANSWER

First Defense

Intervener denies the allegations stated in paragraphs 1 and 2 of the Complaint in so far as they assert negligence on the part of the defendant.

Second Defense

Intervener asserts that at the time of the collision stated in the Complaint the plaintiff was operating his vehicle under the influence of alcohol and in a wantonly negligent manner.

Third Defense

Intervener asserts that at the time of the collision stated in the Complaint defendant was operating intervener’s vehicle without intervener’s authority, permission, or license.