Free Motion for Miscellaneous Relief - District Court of Arizona - Arizona

4.-mee _
I P, O §rH£gggg5l ,__ nscciman ___ccr¤v
2 rémbefiz sszss l FEB Ii 7 21107
Tel: 480-593-4444
Fax: 602-268-7733 Ci.t»1ei¤.; i·5L}lLi;1-.--I rrrnmr
3 Plaintiff (pro se) |.21Lj}}1¤Gl- or xx. ..2 ..;i;,·u_
ev
4 ...,_..1..2.“""" YJ.- .--we ——-—-~——····—···"‘"“‘······
5 IN THE UNITED STATES DISTRICT COURT
6 FOR THE DISTRICT OF ARIZONA
7 — .
8 Ammar Halloum NO. C1V—02—U2245-PHX-EHC
9 PlaintiftQ PLAINTlFF’S MOTION TO OBJECT
DEFENDANTI
10 vs. coUNrEcLA1MANr*s
BILL OF COSTS, AND A
U RECONSIDERATION ou THE
Intel Corporation, COURT’S JUDGMENT T0 PAY
12 Defendant. DEFENDANT $955
13
14 Intel Corporation,
I 5 Counterelaimant,
1 6 Vs. ·
17 Ammar Halloum and Sawsan Hamad
Counterdefendants.
1 8
19 _
_ Plaintiff/Counterdefendant Ammar Halloum hereby motions the Court to deny
20
21 Defendaiit/Cou11terclaimant’s motion for bill of costs, and motions the Court to reconsider
22 its judgment of $955 against Plaintiff explained in the following memorandum of points
23 and authorities:
24
Memorandum of Points and Authorities
25
26 Intel submitted to the Court an Amended Bill of Costs for the total amount of
27 $4,164.11, which is made of two parts:
28
Case 2:02-cv-02245-EHC Document 201 Filed O2/O7/2007 Page 1 of 4

I Intel’s Amended Bill of Costs to include: $1,663.40
2 Plaintiff motions the Court to deny Intel this amount which was Intel’s alleged cost
jr for a deposition in the Whistle Blowing Case before an ALI, and was not in connection of
5 this Title IIV case, which was filed at a later date. The Whistle Blowing case is currently
6 under appeal in 9m Circuit.
7 Intel’s Amended Bill of Costs to include: $2,500.71
g Plaintiff motions the Court to deny Intel this amount, which was half of the cost of
10 transcript that Intel had already agreed to pay, and paid by the end of the trial. Plaintiff
11 had already paid equal amount of $2,500.71, and paying Intel’s cost will be excruciating `
I2 to Plaintiff.
13
14 Court’s iudgment to pay Defendant $955 in remaining relocation money:
15 Intel alleged that Plaintiff still owed Defendant $955 from the relocation amount.
I6 In August 2005, Plaintiff Ammar Halloum paid Intel Corporation $7,045 as a full amount.
U This amount was a substitution of the $8,000 that Intel initially requested minus the $955
ig paid by Plaintiff as the termination of the lease (Exhibit A). Plaintiff Ammar Halloum
20 paid $7,045 and Defendant Intel Corporation accepted that amount as a final and complete
21 payment of the relocation issue. Exhibit A was admitted as Exhibit 98 in this case;
22 whereas the Apartment Assistant Manager wrote: “ October 17, 2000, To Whom it May
ji Concern: Ammar Halloum in apartment #6201 moved out October 17, 2000. (accent
I I 25 given to moved out) He is required to pay through his 30-day notice, expiring October 31,
26 2000. In addition, an Early Lease Termination Fee in the amount of $610 is due prior to
27 move-out (accent given to $610 is due prior to move-out). His total out of pocket expense
28
_ Case 2:O2—cv-02245-EHC Document 201 Filed O2/O7/2007 Page 2 of 4

1 is $955.61. If you are in need of further information, don’t hesitate to call me. Sincerely,
2 Mary Lucas, Assistant Manager? Then hand written by the assistant manager:"10-17-00
3 Requested by Resident for Company Reimbursement? The letter indicates that Plaintiff
5 had moved out, and indicates that the apartment had already held $345.61, part of the full
6 month payment that Plaintiff already paid for the month of October. So, the proof of the
7 $345.61 is indicated as withheld by the apartment as part of October’s rent. The letter
g also stated that $610 was due prior to move—out. Plaintiff paid the apartment the $610
10 prior to his move out on October 17, 2000, and before receiving this letter, and more than
11 tive years from the trial date of this case. If the apartment’s management was not satisfied
12 of Plaintiff s full payment, the assistant manager would have not stated "Requested by
fl Resident for Company Reimbtu·sement”. That is another indication that the $610 was also
15 paid. Also Intel received this letter in November 2000, and received it in 2004 as an
16 exhibit of this case, and never requested the apartment nor the Plaintiff to show a copy of
17 a different payment’s receipt of the $610 at issue. Intel accepted the $955 as an offset,
E and cannot ask for more proof more than five years later, and alter it accepted it. Intel is
20 using asking for this amount in retaliation only. Plaintiff motions the Court to reconsider
21 it’s decision regarding the $955 judgment against the Plaintiff, and reverse it with zero
22 judgment against Plaintiff
if Therefore, Plaintiff respectfully motions this court to reconsider its judgment
25 against Plaintiff for $955 and reverse to no judgment; and to deny Intel Corporation its
26 Bill of Costs for the deposition in the whistle blowing case, and its cost of half the cost of
27 the transcript for the trial of this case.
28
-3-
Case 2:O2—cv—O2245-EHC Document 201 Filed O2/O7/2007 Page 3 of 4

1 r
2 RESPECTFULLY SUBMITTED this ifday of February 2007.
3
By:
4 P amti Ammar a ourn
5
6 Original submitted to
7 thismtday of February, 2007
Honorable Judge Earl H. Carroll
8 Aha p
9 United States District Court
10 Copy of the foregoing mailed to
U this mday or Fehmmy, 2007
12 Michael D. Mhheay
One North Central Avenue, Suite 1200
13 Phoenix, AZ 85001-4414
14 Attorney for Defendant Intel Corporation
16
17 -
l 8
19
20
21
22
23
24
25 p I
26
27
28
-4- ’
Case 2:02-cv-02245-EHC Document 201 Filed O2/O7/2007 Page 4 of 4

Case 2:02-cv-02245-EHC

Document 201

Filed 02/07/2007

Page 1 of 4

Case 2:02-cv-02245-EHC

Document 201

Filed 02/07/2007

Page 2 of 4

Case 2:02-cv-02245-EHC

Document 201

Filed 02/07/2007

Page 3 of 4

Case 2:02-cv-02245-EHC

Document 201

Filed 02/07/2007

Page 4 of 4