Free Motion for Extension of Time - 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. (First Request) INTEL CORPORATION, Counterclaimant, vs. AMMAR HALLOUM and SAWSAN HAMAD, Counterdefendants. Defendant/Counterclaimant Intel Corporation ("Intel" or the "Company") hereby moves for a brief extension of the date by which both parties are required to file their Proposed Findings of Fact and Conclusions of Law and other supporting post-trial submissions from Monday, July 17, 2006 to Friday, July 21, 2006. This motion is not made for the purpose of delay or for any other improper purpose. The motion instead is made to assure that the Court is fully and adequately informed and briefed with respect to this matter. While the Company has been working diligently on its DEFENDANT/COUNTERCLAIMANT'S MOTION FOR EXTENSION OF TIME FOR POSTTRIAL SUBMISSIONS No. CIV-02-02245-PHX-EHC

Case 2:02-cv-02245-EHC

714187.1 7/7/2006

Document 183

Filed 07/07/2006

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anticipated post-trial submissions, the trial transcripts were not available to the parties until June 26, 2006, and they are rather voluminous, reflecting seven days of trial testimony. In addition, the Company's trial counsel is scheduled to be out of state during the week immediately preceding the Monday on which the submissions are presently due. The brief requested extension will provide the Company and its counsel with an opportunity to coordinate and finalize the Company's submissions after counsel's return. Counsel for the Company attempted to contact the plaintiff to ascertain whether he has any objection to the requested extension, but was unable to do so. However, the Company has no reason to believe the plaintiff would object to the extension, which would apply equally to both parties. Indeed, shortly after the conclusion of the trial in this case, the plaintiff himself requested, and was granted without objection from the Company, a one month extension of the time for submitting his Ninth Circuit brief in the related Sarbanes-Oxley case. That requested extension was based in part on the fact that the plaintiff was scheduled to be out of the country for an extended period of time. The Company may have been unable to reach the plaintiff to ascertain his position with respect to its requested extension in this case because he is still out of the country. For the foregoing reasons, the Company respectfully requests that the due date for the parties' respective post-trial submissions be extended from Monday, July 17, 2006 to Friday, July 21, 2006. RESPECTFULLY SUBMITTED this 7th day of July, 2006. RYLEY CARLOCK & APPLEWHITE s/ Michael D. Moberly Michael D. Moberly Andrea G. Lisenbee One N. Central Ave., Ste. 1200 Phoenix, AZ 85004-4417 Attorneys for Defendant/Counterclaimant

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Case 2:02-cv-02245-EHC

Document 183

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CERTIFICATE OF SERVICE I hereby certify that on July 7, 2006, I electronically transmitted the attached document to the Clerk's Office using the CM/ECF System for filing. I hereby certify that on July 7, 2006, 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

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Case 2:02-cv-02245-EHC

Document 183

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