Free MEMORANDUM in Support - District Court of Delaware - Delaware

Case 1 :05-cv-00485-JJF Document 68-2 Filed 06/05/2006 Page 1 of 3
{N THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
IN RE INTEL CORP. MICROPROCESSOR i MDL Docket No. 05-·1'?§’7—-JJF
LITIGATION E

This Pleading Pertains to:
Plelil; PAUL, on behalf of himself and on behalf of Cage Nqr 05-485-jjF
all others similarly situated,
Plaintiffs, §
vs.
INTEL CORPORATION,
Defendant.
DECLARATION OF ADAM J. LEVITT IN SUPPORT
OF THE NATIONAL PLAINTIFFS GROUP’S REPLY
IN FURTHER SUPPORT OF THEIR MOTION FOR
LEAVE TO FILE THEIR CONSOLTDATEI} COMPLAINT
ADAM J. LEVXTT declares and states as follows:
1. I ain a partner inthe law {inn of Wolf Haidenstein Adler Freeman & Herz (“WoIf
Haldenstein" or the "Firm"), counsel for the plaintiffs comprising the National Plaintiffs Group.
I make this cieciaration in support of The National Plaintiffs Group’s Reply in Further Support of
Their Motion for Leave to File Their Consolidated Complaint (the "RepEy Memorandinn").
2. Attached hereto as Exhibit A is a tme and correct copy of Wolf Haldenstein’s
May 8, 2006 letter to the attorneys comprising the Court-appointed Interim Class Counsel group
in this case, discussing the National Flaintiffs Grougfs availability for a meet and confer
teleconference, per the Court’s May 4, 2006 directive, as soon as practicable.

Case 1:05-cv-00485-JJF Document 68-2 Filed 06/05/2006 Page 2 of 3
3. Attached hereto as Exhibit B is a true and correct copy of Wolf Haldenstein’s
May 12, 2006 letter to the attorneys comprising the Courvappointed Interim Class Counsel
group in this case, cataloging their concerns with interim Class Counsei’s consolidated
complaint, again attaching proposed revisions to lnterim Class Counsel’s consolidated
complaint, and suggesting additional revisions to the consolidated complaint which, if adopted as
alternative claims, would have substantially cured the National Plaintiffs Group’s concerns
relating thereto.
4. Attached hereto as Exhibit C is a true and correct copy ot` a draft of Interim Class
Con.nsei’s new amended complaint that Interim Class Counsel sent to Wolf Haldenstein after
business hours on May 19, 2006.
S. Attached hereto as Exhibit I) is a true and correct copy of Wolf `lelaldenstein’s
May 22, 2006 letter to the attorneys comprising the Court-appointed Interim Class Counsel
group in this case, advising Interim Class Counsel them that their proposed new aniended
complaint neither addressed the National Plaintiffs Group’s concerns nor cured the deticiencies
that led to the National ldaintiffs Group’s initial criticisms thereof and proposed revisions
thereto.
6. Attached hereto as Exhibit E is a true and correct copy of the draft of Interim
Class Counsei’s consolidated complaint, that Interim Class Counsel sent to Wolf Haldenstein on
April 26, 2006.
7. Attached hereto as Exhibit F is a true and correct copy of lnterirn Class Counsel’s
April 28, 2006 email message to Fred T. Isquith, one of the counsel representing the National
Plaintiffs Group, advising Mr. lsquith of Interim Class Counsel’s decision to exclude the
National Plaintiffs Group’s plaintiffs, proposed alternative classes, and clairns from their
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Case 1:05-cv-00485-JJF Document 68-2 Filed 06/05/2006 Page 3 of 3
consolidated complaint and Mt. Isqutttfs response email of even date advising Interim Class
Counsel that they were not authorized to do so.
8. I declare the foregoing to be true and correct under penalty of perjury under the
laws of the United States ofAme1·ica.
.Executed at Chicago, Hlinois, this Sth day of June, 2006.

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Adam J. Levitt; i
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