Free Memorandum - District Court of Arizona - Arizona

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RYLEY CARLOCK & APPLEWHITE One North Central Avenue, Suite 1200 Phoenix, Arizona 85004-4417 Telephone: 602/258-7701 Telecopier: 602/257-9582 Michael D. Moberly ­ 009219 Andrea G. Lisenbee - 019882 Attorneys for Defendant/Counterclaimant IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA
AMMAR HALLOUM, Plaintiff, vs. INTEL CORPORATION, Defendant. INTEL CORPORATION, DEFENDANT/ COUNTERCLAIMANT'S STATEMENT OF CONSULTATION No. CIV-02-02245-PHX-EHC

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Counterclaimant,

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vs.

17 18 19 20 21 22 23 24 25 26 27 28 Defendant/counterclaimant Intel Corporation ("Intel" or the "Company") hereby advises the Court pursuant to LRCiv 54.2(d)(1) that it made a good faith but unsuccessful effort to resolve the disputed attorneys' fee issues that are the subject of Defendant/Counterclaimant's Motion for Attorneys' Fees. Specifically, undersigned counsel for Intel contacted the plaintiff by telephone on Monday, February 5, 2007. During that conversation, undersigned
AMMAR HALLOUM and SAWSAN HAMAD, Counterdefendants.

counsel and the plaintiff discussed whether there was a mutually acceptable basis upon which the pending attorneys' fee application might be resolved and, alternatively,
745327.1

Case 2:02-cv-02245-EHC 3/06/07

Document 207-2

Filed 03/16/2007

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whether there might be a mutually acceptable basis for resolving the parties' disputes on a "global" basis. However, no agreement was reached as to either issue at that time. On Tuesday, February 6, 2007, the undersigned received from the plaintiff a written proposal for resolving the parties' disputes, which the undersigned conveyed to the Company. The Company responded to the plaintiff's proposal by telecopier on Wednesday, February 7, 2007, with a proposal of its own for resolving its claim for attorneys' fees. The plaintiff responded to the Company's transmission, in writing, almost immediately. Although his written response did not directly address the Company's proposal for resolving the attorneys' fee dispute, the content of his communication suggested by implication that he was rejecting it. The undersigned telephoned the plaintiff again on the following morning, Thursday, February 8, 2007, and specifically confirmed that the plaintiff was rejecting the Company's proposal. The plaintiff did not make a counter-offer at that time. Based on the foregoing, the undersigned advises the Court that despite good faith efforts, no resolution of the attorneys' fee issue has been reached. DATED this 16th day of March, 2007. RYLEY CARLOCK & APPLEWHITE

By s/ Michael D. Moberly Michael D. Moberly Andrea G. Lisenbee One North Central Avenue, Suite 1200 Phoenix, Arizona 85004-4417 Attorneys for Intel Corporation

Case 2:02-cv-02245-EHC

Document 207-2 -2- Filed 03/16/2007

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Case 2:02-cv-02245-EHC

CERTIFICATE OF SERVICE I hereby certify that on March 16, 2007, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing. I hereby certify that on March 16, 2007, I served the attached document by mail on the following, who are not registered participants of the CM/ECF System:

Ammar Halloum P.O. Box 26662 Tempe, AZ 85285 Plaintiff/Counterdefendant Sawsan Hamad 260 W. Buena Vista Dr. Tempe, Arizona 85284 Counterdefendant s/ Michael D. Moberly Michael D. Moberly

Document 207-2 -3- Filed 03/16/2007

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