The following excerpt is from U.S. v. State of Or., 657 F.2d 1009 (9th Cir. 1982):
13 Indeed, the same court that issued the injunction at issue here has held that non-parties may be enjoined from interfering with the res in the court's constructive possession. United States v. Crookshanks, 441 F.Supp. 268, 270 (D.Or.1977). Cf. Mathias v. Lennon, 474 F.Supp. 949, 957 (S.D.N.Y.1979) (New York court in possession of insurance company assets may enjoin non-party policyholders, residing in Illinois, from dissipating assets.) If non-parties may be enjoined from interference, then intervenors, over whom the court has personal jurisdiction, see note 18 infra, may certainly be enjoined from similar acts.
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