IN THE UNTED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

D’ANDRE BRADLEY; DAVID D. MOORE; ) 

TARA D. MOORE; BRETT O. SHELTON; ) 

ILLINOIS STATE RIFLE ASSOCIATION; )

and SECOND AMENDMENT )

FOUNDATION, INC. ) 

)

Plaintiffs, ) No. 20-cv-4270

) 

v. ) 

) Hon. Ronald A Guzman,

BRENDAN F. KELLY, in his official ) presiding

capacity as Director of the Illinois State )

Police; and JESSICA TRAME, in her official ) 

capacity as Bureau Chief of the Illinois )

State Police Firearms Services Bureau, ) 

) 

Defendants. )

MOTION FOR LEAVE TO INTERVENE

NOW COME Movants Bruce Davidson, pro se, and Sarah Davidson, by 

attorney Bruce Davidson, and make this their motion for leave to intervene 

pursuant to FRCivP 24(b)(1)(B). In support of their motion, Movants state:

1. Movants have reviewed, and are familiar with, the Complaint filed 

and pending herein. Movants believe the Complaint is well- and trulypleaded, and states one or more valid causes of action against Defendants.

2. The Court has subject matter jurisdiction of the cause, and that 

venue properly lies in the Northern District of Illinois, Eastern Division.

Case: 1:20-cv-04270 Document #: 20 Filed: 09/28/20 Page 1 of 4 PageID #:84
3. Pursuant to Rule 24(C), Movants attach an accompanying pleading 

(Complaint in Intervention) setting forth their claims. That pleading is 

hereby incorporated by reference, as if fully set forth herein. The Complaint 

in Intervention establishes the nearly identical fact situations of Movants 

and the principal Plaintiffs.

4. Movants’ claims share questions-of-law in common with the 

principal complaint, including but not necessarily limited to: (i) whether the 

actions of Defendants, as alleged, violate state law (430 ILCS 65/5); (ii) 

whether the actions of Defendants, as alleged, violate Plaintiffs’ rights under 

the Second Amendment to the United States Constitution, and (iii) whether 

the actions of Defendants, as alleged, violate Plaintiffs’ rights to the Due 

Process of Law under the Fourteenth Amendment to the United States 

Constitution.

5. Allowing Movants to intervene at this early stage of proceedings 

will not unduly burden resolution of the cause, as judgment will depend 

almost exclusively on answering questions of law. Movants anticipate taking 

no discovery; further, there are no material issues of fact.

6. Allowing Movants to intervene may actually expedite resolution of 

the case, as Movants are individuals with unresolved claims, thus obviating 

the need to resolve assertions, raised by Defendants (Motion to Dismiss, 

Docket item No. 13), that the case is moot. See attached Complaint in 

Intervention, ¶¶ 5-7.

Case: 1:20-cv-04270 Document #: 20 Filed: 09/28/20 Page 2 of 4 PageID #:85
7. Defendants have indicated a desire for consolidating SecondAmendment-related claims, as they have moved to “reassign [this case] based 

on relatedness”, Docket item No. 15. 

WHEREFORE, for the reasons stated above, Movants Bruce Davidson 

and Sarah Davidson pray the Court will grant this their motion for leave to 

intervene herein. 

Respectfully submitted, 

Bruce Davidson 

Sarah Davidson 

By______________________ 

 Bruce Davidson, pro se, 

 and attorney for Sarah 

 Davidson 

Bruce Davidson 

 ARDC Registration no. 0583057 

733 North Oak Street 

Hinsdale IL 60521 

630-947-3117 

Akivida@aol.com 

/s/

Case: 1:20-cv-04270 Document #: 20 Filed: 09/28/20 Page 3 of 4 PageID #:86
CERTIFICATE OF SERVICE

I, Bruce Davidson, an attorney, hereby certify that on September 28, 

2020, a true and correct copy of the foregoing Motion for Leave to Intervene, 

including the attached Rule 24(c) proposed pleading, was electronically filed 

with the Clerk of the U.S. District Court of the Northern District of Illinois, 

Eastern Division, via its CM/ECF System and was electronically served to 

each person listed below: 

David G. Sigale, Esq. Mary A. Johnston, Esq. 

Law Firm of David G. Sigale, P.C. Office of the Illinois Attorney General 

799 Roosevelt Road, Suite 207 100 West Randolph Street, 13th Floor 

Glen Ellyn, IL 60137 Chicago, IL 60601 

630-452-4547 312-721-8734 

dsigale@sigalelaw.com mjohnston@atg.state.il.us 

Gregory A. Bedell, Esq. Jacob Huebert, Esq. 

Knabe & Bedell Martha Astor, Esq. 

33 North Dearborn Street Scharf-Norton Center for 

10th Floor Constitutional Litigation at the 

Chicago, Illinois 60602 Goldwater Institute 

312-977-9119 500 E. Coronado Rd. 

gbedell@kkbchicago.com Phoenix, AZ 85004 

 Telephone: 602-462-5000 

 jheubert@goldwaterinstitute.org 

 litigation@goldwaterinstitute.org 

 

DATED: September 28, 2020 

 Bruce Davidson 

Bruce Davidson 

 ARDC Registration no. 0583057 

733 North Oak Street 

Hinsdale IL 60521 

630-947-3117 

Akivida@aol.com

 /s/ 

Case: 1:20-cv-04270 Document #: 20 Filed: 09/28/20 Page 4 of 4 PageID #:87