What is the test for determining whether a party is adequately represented under Rule of Civil Procedure 19(a)?
The following excerpt is from Timbisha Shoshone Tribe v. U.S. Dep't of the Interior, No. 2:11-cv-00995-MCE-DAD (E.D. Cal. 2013):
"In assessing an absent party's necessity under [Federal Rule of Civil Procedure] 19(a), the question whether that party is adequately represented parallels the question whether a party's interests are so inadequately represented by existing parties as to permit intervention of right under [Federal Rule of Civil Procedure] 24(a)." Shermoen v. United States, 982 F.2d 1312, 1318 (9th Cir. 1992).
Id. (emphasis added) (internal citations and quotations omitted).
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