Free Motion to Amend/Correct - District Court of Arizona - Arizona

~·’ FILED _____ LODGED l
_____ RECEIVED _______ COPY
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1 P.O.ia3IoxEi26l-i5li5121 MAY 312006
2 Tempe, AZ 85285
Tcl: 480-593-4444 ctenx u s DISTRICT count
3 Fan: 602-268-6644 DISTRICT OF · IZONA
P1a1nt1ff (pro se) BY " DEPUTY
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5 IN THE UNITED STATES DISTRICT COURT
6 FOR THE DISTRICT OF ARIZONA
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8 Ammar Halloum NO. CIV—02-02245-PHX-EHC
9 Plaintiff, PLAINTIFF’S MOTION TO ~
AMEND HIS DAMAGES .
10 vs. COMPUTATION ro A Lesson
11 AMOUNT
Intel Corporation,
I2 Defendant.
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14 Intel Corporation,
1 5 Counterclaimant, A
16 Vs.
17 Ammar Hallotun and Sawsan Hamad
18 Counterdefendants.
19 MOTION
P1aintift7Cou11terdefenda11t Ammar Halloum hereby moves this Court to amend
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21 the computation of his damages computation to a lesser amount.
C 22 DAMAGE COMPUTATION
23 Intel Corporation is a mighty company that used its mighty resources and influence to
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damage Plaintiff. Intel’s net income for 2005 was $8.7 billion (Exhibit A). A small
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26 judgment against Intel will not make it stop damaging and discriminating against
27 employees. A judgment against Intel of 1% of its annual income will be $87 Million
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Case 2:02—cv—02245-EHC Document 161 Filed 05/31/2006 Page 1 of 3

1 dollars, which will not drastically affect Intel.
2 Plaintiff is asking this court to grant him a judgment against Intel that will be
it severe and exemplary. F
5 Plaintiff has offered Intel the opportunity to settle this case out of Court several
6 times, and Intel failed to even reply. i
7 WHEREFORE, Plaintiff Halloum prays for a judgment against Defendant Intel
S ; Corporation as follows:
9 A. Loss of salary $25,000, and 1,000 Intel stocks from 4/29/02 — 7/22/02
IU B. Two and a half year of back pay (for 2003, 2004, and few months in 2005
ll and 2006) for loss of wages, fringe benefits, stock participation plan,
12 { retirement contribution, and bonuses of approximately $250,000, and 10,000
13 Intel Stock Option.
14 C. Front pay for five years of wages, fringe benefits, stock participation plan,
1 5 . retirement contribution, and bonuses of approximately $700,000, and 40,000
16 Intel stock Option.
17 1 D. For compensatory damages in the amount of $300,000 as a minimum.
18 E. Pain and Suffering for live years since 9/ l 1/01 until recovery in the
Amount of $5 Million.
19 r F. Punitive damages in the amount of $10 Million
20 E G. Loss of retirement $200,000
21 1 H. Reinstatement of approximately 8,700 of Intel stock options.
22 l I. Loss of merit bonuses, salary increase, stock participation plan, and stock
23 options based on merit, and grant from 9/ l l/01 — 9/3/02. This is estimated
24 1 to be $21,000, and 3,000 Intel stocks.
25 J. Medical, dental, and life insurance, and out of pocket medical bills for five
26 1 years $75,000.
27 1 K. Attomey’s fees and costs: Approximately ($25,000)
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Case 2:02—cv—02245-EHC Document 161 Filed 05/31/2006 Page 2 of 3

1 L. For other damages: 1 Million
2 1. Loss of fifteen years of marriage, and impact on parents, and children
3 2. Loss of reputation and injury to career
4 3. Loss of education (eight years delay of graduation with a PhD)
5 4. Legal interest and penalties
6 1 Total minimum damages: $17,595,000, and 63,700 Intel stock Ogtions.
s e
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0 RESPECTFULLY SUBMITTED this Q l day of May of 2006.
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B1/=
13 ` a1nt1 ar H oum
14 I
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16 E Original submitted to n
E this §_L day of May, 2006
17 Honorable Judge Earl H. Carroll
is 1 Md
United States District Court
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20 Copy ofthe foregoing mailed to
this QL day of May, 2006
21
22 i Michael D. Moberly
Andrea G. Lisenbee
23 Ryley Carlock & Applewhite 2
24 One North Central Avenue, Suite 1200
Phoenix, Arizona 85004
25 Attorney for Defendant
26 G QQ I .
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Case 2:02-cv-02245-EHC

Document 161

Filed 05/31/2006

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Case 2:02-cv-02245-EHC

Document 161

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Case 2:02-cv-02245-EHC

Document 161

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