- 7 - A A B “Locus C D E F G 32. The questions and issues outlined above arise out of or relate to or are connected with the relief or remedy claimed in this Action and/or the interim relief or remedy claimed in the Summons. It would be just and convenient for the said questions and issues to be determined between the Opposing Party and the Plaintiff as well as between the Plaintiff and the Defendants. C 33. It is unlikely that any of the Defendants will reveal himself or herself and appear to defend the Action against them or oppose the Summons. F 34. There are aspects of the public interest in the legal questions and issues raised by the Opposing Party and outlined above which are of general importance and are not sufficiently represented by either the Plaintiff or the Defendants (who are likely to be absent). H I 35. The decision to be made in the Action and the Summons involves strong public interest elements and the Opposing Party may, through her participation in the Summons, assist this Honourable Court and enable it to strike the right balance between competing considerations.” J K L M 17. The document concluded as follows : “AND FURTHER TAKE NOTICE that, by opposing the [Injunction Summons] pursuant to paragraphs 2 and 3 of the [Service Order], the Opposing Party does not admit that she is one of the Defendants described in the Writ of Summons.” O P E G H I J K M N O P 18. On 5 July 2023, OTC issued a Notice to Act for the “Opposing Q Party”. R R 19. S D L N Q B On 6 July 2023, “to avoid delaying the [Hearing]”, DOJ wrote to the Court (copied to OTC) with enclosed submissions seeking an urgent S T T U U V V

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