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e-mail: Iov§[email protected]
May 22, 2006
VIA .PDF EMAIL AND TELECOPY
Michael P. Lehmann, Esq. Michael Hausfeld, Esq.
The Forth Finn LLP Cohen Milstein Hausfeld & Toll
225 Bush Street, Fifteenth Floor 1100 New York Ave., NQW.
San Francisco, Cali.t`orr1ia 94l0·=l West Tower, Suite 500
Washington, DC 20005
Guido Saveri, Esq. Anthony D. Shapiro, Esq.
Saveri & Saveri., Inc. Hageus Berrnari Sohol Shapiro, LLP
ll l Pine Street, Suite 1700 130l Fifth Avenue, Suite 2900
San Francisco, California 94l ll Seattle, Washington 98101
Re: In re Intel Corporation Microprocessor Antitrust Litigation
MDL Docket N0. 05-·l\fID—17I7 JJ F
Civil Action No.: §:05-CV—00485 JJF {D. Hel.)
Dear Counsel,
At almost 9:00 pm (EDT) this past Friday evening, interim Class Counsel
sent its proposed "First Amended Consolidated Complaint" (the "l’roposed
Amended Complaint? to us, requesting that we forward our comments to you
"pret`erahly over the weet
Although your communication arrived after vveeltend began, we have had
an opportunity to review it. lt does not solve the issues which we described to you
in some detail in our earlier correspondence on this matter. ln particular, we had a
conference call with you relating to these very issues more than eight days earlier
-— on the very last day that the Court provided for us to solve these issues prior to
the conarnencement of your time to respond to our elients’ motion. At your
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Case 1:05-cv-00486;,JJF Document 68-6 Filed 06/Q5/2006 Page 2 of 2
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May 22, 2066
Page 2. of 2
request and invitation, we sent a followup letter to you the following day again
explaining our concerns with Interim Class Connsel’s Consolidated Complaint
and the perceived flaws therein, and setting forth language that we believe
addresses many of the National Plaintiffs Group’s concerns with respect thereto.
While we have not had a chance to exhaustively compare your Proposed
Amended Complaint with your initial Consolidated Complaint or each of our
suggested revisions thereto, it appears, from our review, that lnterirn Class
Counsel has taken none of the steps nor has made any of the substantive revisions
that we have repeatedly suggested to you. The Proposed Amended Complaint
does not take any steps to deal with our concerns about the problems that we
believe are endemic throughout your earlier pleadings in this case. Moreover you
have failed to include our clients in your Proposed Amended Complaint, thereby
recognizing their right to proceed as class representatives for their claims with
counsel of their choice
tn sum, we do not authorize you to seek leave to tile --·· or otherwise tile Y
the Proposed Amended Complaint on our clients’ hehaii as it does not protect
their interests or the interests of the class(es) ~ both of which you are obligated to
do as interim Class Counsel under Rule 23(g).
In li ght ofthe fact that interim Class Counsel is clearly unwilling to
protect our clients? claims and interests in this litigation, we await your opposition
to The National Plaintiffs Group’s Motion for Leave to Pile Their Consolidated
Complaint, which, by our calculation, is due on or before Friday, May 26, 2006.
Sincerely,
Adarnnljlgevitt
cc: Frederick L. Cottrell, Esq. (via .pdf email)
Charles P. Diamond, Esq. (via pdf email)
Richard L. Horowitz, Esq. (via .pdt` email.)
Christopher B. Hoclcett, Esq. (vin .pdt`eniail)
Fred Taylor lsquith, Esq. (via pdf ernail)
Francis A. Bottini, lr., Esq. {via pdf email)
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