Rosado v. Bridgeport Roman Catholic Diocesan Corp
In Rosado v. Bridgeport Roman Catholic Diocesan Corp., 60 Conn. App. 134, 758 A.2d 916 (2000), the court initially denied the motion of the seven John Doe priests, who previously had been granted permission to use the fictitious names of the Reverend John Does one through seven, for permission to intervene as of right. See Rosado v. Bridgeport Roman Catholic Diocesan Corp., supra, 60 Conn. App. at 135 n.3.
The John Doe priests then appealed to the Court, which reversed the trial court's decision. Id., at 153.
The Court concluded that there was "clearly no party charged by law with representing their interests" and remanded the matter with direction to grant the nonparty priests intervention as of right. Id., at 153.
The court granted the John Doe priests intervenor status, and the intervening priests filed a motion to quash subpoenas, for a protective order and for a stay to prevent disclosure of private and personal information contained in their personnel files. At the time the Rosado case was withdrawn, the court had not yet ruled on the motion to quash.
The Court observed that Connecticut appellate cases often have relied on rule 24 of the Federal Rules of Civil Procedure in determining issues of intervention and, in those decisions, the courts have spoken approvingly of the rule.
The Court stated in Rosado: "Cases involving rule 24 (a) establish four requirements that an intervenor must show to obtain intervention as of right. The motion to intervene must be timely, the movant must have a direct and substantial interest in the subject matter of the litigation, the movant's interest must be impaired by disposition of the litigation without the movant's involvement and the movant's interest must not be represented adequately by any party to the litigation." Rosado v. Bridgeport Roman Catholic Diocesan Corp., supra, at 160.