In Nunn v. The Lockformer Company (Nov. 19, 1998), 8th Dist. No. 73505, 1998 Ohio App, the insurer moved to intervene to present a declaratory judgment action with the plaintiff's product liability claim. In affirming the trial court's denial of the motion, the court held: "Relevant factors in deciding the timeliness of a motion to intervene include the delay that intervention will have on the disposition of the pending case, the point to which the action has progressed, the length of time the appellant knew or should have known about the pending suit, and the reason for the delay in attempting to intervene. "When the motion was filed, the existing parties had completed discovery, filed their dispositive motions, and filed replies to the dispositive motions. The motion to intervene was filed just two days before a scheduled settlement conference, and just two months before the set trial date. If the motion to intervene was granted, the trial court would have had to allow additional discovery, which would inevitably have delayed the trial date." Further, in Nunn the insurer gave no reason for its delay in seeking intervention, and did not dispute that it had knowledge of the plaintiff's claims for some three years before it filed its motion.