Free Redacted Document - District Court of Delaware - Delaware

Case 1:06-cv-00270-SLR Document 112 Filed 07/13/2007 Page 1 of 3
MORRIS JAMES LLP
500 Delaware Avenue, Suite 1500
P.O. Box 2306
Wilmington, Delaware 19899-2306
(302)'888-6800
Facsimile (302) 571-1750
www.mor1·isjames.com
Richard K. Herrmann Mailing Address
(302) 888-6816 P.O. Box 2306
[email protected] Wilmington, DE 19899-2306
CONFIDENTIAL — FILED UNDER SEAL
Original Date: July 5, 2007
Redacted Date: July 13, 2007
VIA E-FILING AND HAND DELIVERY
The Honorable Sue L. Robinson
United States District Court
District of Delaware
844 King Street
Wilmington, Delaware 19801
Re: Red Sonja LLC v. Paradox Entertainment, Inc.
D.Del., C.A. N0. 06-CV-270
Your Honor:
We write conceming Your Honor’s Order dated July 3, 2007 in order to bling to
the Court’s attention certain matters that we believe to be important and that may effect Your
Honor’s ruling. Specifically, Your Honor ordered that the so-called Lasman report need not be
produced to plaintiff Red Sonja LLC in an unredacted format as the redacted portions of the
Lasman report "are privileged and, in any event, irrelevant to the issues in dispute."
We respectfully submit that, to the extent the redacted portions of the Lasman
report were privileged, the protection Hom disclosure was waived 1
Dover (302) 678-8815 `Broom Street (302) 655-2599 Newark (302) 368-4200

Case 1 :06-cv—00270-SLR Document 112 Filed 07/13/2007 Page 2 of 3
The Honorable Sue L. Robinson
July 5, 2007
Page 2
In addition, we respectfully wish to stress to the Court Red Sonja LLC’s position
in this case that it was Mr. Sederowsky, and his intentionally wrongful conduct as the head of
Paradox, that largely contributed to the infringement upon our client’s trademark of the Red
Sonja character. We believe that any and all evidence of Mr. Sederowsky’s wrongful and
dishonest conduct while the head of Paradox is relevant to show his intent to be wrongiiil and
dishonest as to our client and it rights.
In light of this, we respectfully ask Your Honor to reconsiderthe Court’s Order of
July 3. l l
` J Respectfully,
Richard
cc: Dr. Peter T. Dalleo, Clerk of the Court (via electronic filing)
Maryellen Noreika, Esq. (via email and electronic tiling) _

ENTIRE
ATTACHMENT
REDACTED