We hold that the nature of Taxpayers' allegations of impropriety and the opposition of the Commission to both alleged facts and law raised by Taxpayers are sufficient to show that Taxpayers met their factual burden in the trial court and the trial court's order denying the motion to intervene must be reversed Upon State's request, the District Court certified its order for interlocutory appeal and State sought certiorari for its attempted appeal under 12 O.S. 2001, §952; we find appeal does not lie from an order granting habeas corpus and we dismiss the attempted appeal for lack of jurisdiction