Memorandum and Order — No. 4:21-cr-00532 (Dkt. 607, E.D. Mo.)
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Memorandum and order of November 18, 2025 by Judge Sarah E. Pitlyk in the Eastern District of Missouri, United States v. Christopher Carroll et al., case 4:21-cr-00532, Dkt. 607. LouAnn Reed asked to intervene in garnishment proceedings, saying she has an interest in a spousal trust the government seeks to garnish. The government did not oppose, and the court granted the motion to intervene under Rule 24.
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“Memorandum and Order — No. 4:21-cr-00532 (Dkt. 607, E.D. Mo.).”
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Case: 4:21-cr-00532-SEP Doc. #: 607 Filed: 11/18/25 Page: 1 of 1 PageID #:
8126
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
UNITED STATES OF AMERICA, )
)
Plaintiff, )
v. ) Case No. 4:21-cr-00532-SEP
)
CHRISTOPHER CARROLL, et al., )
)
Defendants. )
MEMORANDUM AND ORDER
Before the Court is LouAnn Reed’s Motion to Intervene in Garnishment Proceedings,
Doc. [535]. Federal Rule of Civil Procedure 24(a) permits intervention as of right to any party
who “claims an interest relating to the property or transaction that is the subject of the action, and
is so situated that disposing of the action may as a practical matter impair or impede the
movant’s ability to protect its interest, unless existing parties adequately represent that interest.
Fed. R. Civ. P. 24(a)(2). Rule 24(b) allows for permissive intervention for any individual who
“has a claim or defense that shares with the main action as a common question of law or fact.”
Mrs. Reed alleges that she holds an interest in the spousal trust against which garnishment is
sought and thus satisfies both Rule 24(a) and 24(b)’s requirements as to that issue. The
Government does not contest that claim or oppose intervention.
Accordingly,
IT IS HEREBY ORDERED that LouAnn Reed’s Motion to Intervene in Garnishment
Proceedings, Doc. [535], is GRANTED.
Dated this 18th day of November, 2025.
SARAH E. PITLYK
UNITED STATES DISTRICT JUDGE
1
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