Free Letter - District Court of Delaware - Delaware

’ Case 1:06-cv-00270-SLR Document 40 Filed 10/06/2006 Page 1 of 1
MORRIS, JAMES, HITCHENS & WILLIAMS LLP
222 Delaware Avenue, 10th Floor
Wilmington, Delaware 19801-1621
(302) 888-6800
I Facsimile (302) 571-1751
www.morrisjames.com
Richard K. Herrmann Mailing Address
(302) 888-6816 P.O. Box 2306
[email protected] Wilmington, DE 19899-2306
October 6, 2006
VIA HAND DELIVERY
Dr. Peter T. Dalleo, Clerk of the Court
United States District Court
for the District of Delaware
844 King Street
Wilmington, Delaware 19801
' Re: Red Sonja LLC v. Paradox Entertainment, Inc.,
I D. Del., C.A. N0. 06-270-SLR
Dear Dr. Dalleo:
On September 25, 2006 we filed Plaintiffs Reply Brief In Further Support of
Plaintiff s Motion for Leave to Amend Its Complaint. Attached as Exhibit H to that filing was
the Declaration of Arthur M. Lieberman. As noted in the brief, Mr. Lieberman was unavailable
to sign the declaration at that time as he was concluding personal matters pertaining to the death
of his wife. We now have the original signed declaration and we enclose it for the Court’s files.
Sincerely,
Richard K. gerrmann, No. 405
[email protected]
Enclosure
cc: Thomas Preston, Esq. (via email w/encl.)
Timothy Pecsenye, Esq. (via email w/encl.)
Earl Forte, Esq. (via email w/encl.)
Dover (302) 678-8815 Broom Street (302) 655-2599 Newark (302) 368-4200

“ { Case 1:06-cv-00270-SLR Document 40-2 Filed 10/06/2006 Page1 of2
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
RED SONJA LLC, g
Plaintiff, g
v. g Civil Action No.:
) 06—CV—OO270 (SLR)
PARADOX ENTERTAINMENT, INC., )
Defendant. g

I, ARTHUR M. LIEBERMAN, declare as follows:
1. I am a principal of Plaintiff Red Sonja LLC and submit this declaration in
further support of Plaintiff’s Motion for Leave to Amend its Complaint.
2. I was part of a group that sold the character Conan to Paradox in 2003.
3. I had and have no knowledge whatsoever as to which "pocket" of the
several Paradox and Conan "shelIs" the Conan character was placed.
4. I now have learned that there are at least four Conan entities and two
Paradox entities.
5. I did not know until this litigation which Conan and/or Paradox entity owns
the Conan character.
6. Although I did receive checks for my profit participation in relation to the
Conan character, I never focused on the issuer of such checks, and even the name of
the entity that issued such checks does not mean that such issuer was the owner of the
Conan character, and should have been a defendant herein. In fact, my checks were

‘ l Case 1:06-cv-00270-SLR Document 40-2 Filed 10/06/2006 Page 2 of 2
forwarded under the Paradox letterhead (not under a Conan letterhead), the same entity
to which I believe we sold the Conan character.
7. I only had focused on the entity to which we sold the Howard characters.
Until recently, I similarly never focused on the fact that there is more than one Paradox
entity;
8. This litigation was brought against Paradox, which I believed at the time
acquired the Conan character in 2003 and the remaining Howard characters thereafter.
I declare under the penalties of perjury that the foregoing is true and correct.
Executed this 3rd day of October, 2006
M. LIEBERMAN
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