DEREK SCHMIDT

Attorney General of Kansas

Brant M. Laue (KS Bar No. 16857)

Solicitor General

STATE OF KANSAS

OFFICE OF THE ATTORNEY GENERAL

120 SW 10th Ave., 2nd Floor

Topeka, KS 66612

Telephone: (785) 368-8539

Fax: (785) 296-3131

brant.laue@ag.ks.gov

Counsel for Proposed Defendant-Intervenor 

State of Kansas

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON

EUGENE DIVISION

KELSEY CASCADIA ROSE JULIANA, et al., 

Plaintiffs,

v.

UNITED STATES OF AMERICA, et al.,

Defendants. 

Case No. 6:15-cv-01517-AA

PROPOSED DEFENDANTINTERVENOR STATE OF 

KANSAS’S MOTION FOR 

LIMITED INTERVENTION AND 

MEMORANDUM IN SUPPORT

Case 6:15-cv-01517-AA Document 499 Filed 06/23/21 Page 1 of 4
Proposed Defendant-Intervenor’s Motion for 

Limited Intervention and Memo. in Support 1

MOTION

Pursuant to Local Rule 7-1(a), lead counsel for the other Proposed Defendant-Intervenor

States have indicated that they do not oppose this motion. The other parties already have indicated 

their opposition to the states’ motion. Doc. 475.

Pursuant to Federal Rule of Civil Procedure 24, Proposed Defendant-Intervenor the State 

of Kansas moves this Court for an order allowing it to intervene as defendant in this case as of 

right, or in the alternative permissibly, for the limited purposes of participating in settlement negotiations; if necessary, objecting to any proposed settlement; and opposing Plaintiffs’ motion for 

leave to amend and file a second amended complaint. Doc. 462.

The same motion (Doc. 475) was filed on June 8, 2021, by a group of states, and it is the 

intent of this Proposed Defendant-Intervenor to join in that motion and the arguments in support 

of it, without any further separate filings, briefing, or argument on this motion filed by the State 

of Kansas. 

MEMORANDUM

This Proposed Defendant-Intervenor hereby joins in and adopts the arguments made in the 

“Proposed Defendant-Intervenors’ Motion for Limited Intervention and Memorandum in Support” 

filed in this case on June 8, 2021. Doc. 475. Although the State of Kansas is reassured by the recent 

statement of the United States that the climate change executive order “did not alter the United 

States’ view that this case is non-justiciable and should be dismissed,” Doc. 498 at p. 4, it still 

wishes to join the other states as an intervenor in this matter. 

Case 6:15-cv-01517-AA Document 499 Filed 06/23/21 Page 2 of 4
Proposed Defendant-Intervenor’s Motion for 

Limited Intervention and Memo. in Support 2

CONCLUSION

The State of Kansas respectfully requests that the Court grant its motion to intervene for 

the limited purposes of participating in settlement negotiations; if necessary, objecting to any 

proposed settlement; and opposing Plaintiffs’ motion for leave to amend and file a second 

amended complaint. 

Respectfully submitted,

Dated: June 23, 2021

DEREK SCHMIDT

Attorney General of Kansas

/s/ Brant M. Laue 

Brant M. Laue (KS Bar No. 16857)

Solicitor General

STATE OF KANSAS

OFFICE OF THE ATTORNEY GENERAL

120 SW 10th Ave., 2nd Floor

Topeka, KS 36130

Telephone: (785) 368-8539

Fax: (785) 296-3131

brant.laue@ag.ks.gov

Counsel for Proposed Defendant-Intervenor

State of Kansas

Case 6:15-cv-01517-AA Document 499 Filed 06/23/21 Page 3 of 4
Proposed Defendant-Intervenor’s Motion for 

Limited Intervention and Memo. in Support 3

CERTIFICATE OF SERVICE

I hereby certify that on June 23, 2021, I electronically filed the foregoing with the Clerk of 

the Court for the United States District Court for the District of Oregon by using the CM/ECF 

system, which will send notification of such to the attorneys of record.

/s/ Brant M. Laue 

Counsel for State of Kansas

Case 6:15-cv-01517-AA Document 499 Filed 06/23/21 Page 4 of 4