Mr. Grinch, Esq.

Law Offices of Grinch, Heat Miser & Burgermeister Meisterburger LLP

Re:

Rudolph the Red-Nosed Reindeer

Dear Mr. Grinch:

We represent Kris Kringle, Inc. as well as all of its management employees - both elvish
and hooved, with respect to the claims made by your client, Rudolph the Red-Nosed Reindeer.
We have been asked to respond to your letter containing Rudolphs outrageous allegations and
settlement demand. Please cease any and all contact with our clients, and direct all future
correspondence in this matter to me.
It was extremely disappointing to read in your letter that the beloved and most famous
reindeer of all is seeking essentially to extort an organization that devotes itself exclusively to
bringing joy to all the children of the world. Your letter, however, is predicated on an erroneous
interpretation of the facts and the applicable law.
Contrary to the allegations in your letter, no one at Kris Kringle, Inc. was aware of
Rudolphs alleged harassment and abuse. If in fact his fellow reindeers were calling him names
and not letting him join in their reindeer games, he had every opportunity to report those issues
to Human Resources. Like all employees, Rudolph was given a copy of the employee handbook
upon hiring, and told that he should immediately report any harassing or abusive behavior. Our
investigation has revealed that no one identified in your letter is a supervisor or manager therefore, the Company would have no liability unless Rudolph had complained of the hostile
environment and the Company failed to take effective remedial action. If you have any evidence
of complaints made prior to your letter, please provide them to me.
With respect to the allegations of medical condition or perceived disability status by the
Company, please be advised that the Company was aware of Rudolphs nose when he was hired.
In fact, everyone who interviewed him and saw his nose said that it glowed - and it was no
impediment to his hiring. Rudolph neither asked for, nor apparently needed, any accommodation
to accomplish his duties in the reindeer pool. Those claims, therefore, also fail as a matter of
law.
Perhaps the most egregious allegation in your letter is the mischaracterization of
Rudolphs promotion and praise from Santa Claus. Unaware of any alleged past co-worker
mistreatment, but fully recognizing Rudolphs unique and exceptional talents, Santa Claus
bypassed what would normally be years of apprenticeship and training, and promoted Rudolph to
the position of lead reindeer in one night. Apparently, however, despite the gleeful praise heaped
upon him by all of the other reindeer, and the unambiguous accolades publicly extolled by Santa
himself, Rudolph would rather view the entire evening in a negative, self-centered way. He will
have a blue Christmas indeed with this sort of outlook.
As should be apparent from the foregoing, the Company rejects Rudolphs ludicrous
demand for the deed to the Island of Misfit Toys. The fact that Rudolph has no concern for

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making so many psychologically troubled toys homeless at this time of year, simply bolsters the
Companys opinion that Rudolph is being unreasonable and selfish. With respect to your veiled
threat of a jury trial and punitive damages, please consider that jurors may come from various
walks of life, but almost all of them have children. What reaction do you think any jurors will
have to seeing Santa Claus put up on the stand and cross examined by members of your firm?
We hope that your client and your firm re-evaluate this matter in light of the foregoing,
and proceed with a modicum of Christmas cheer. If, however, your client chooses a path of
frivolous litigation, please be advised that we will zealously defend Kris Kringle, Inc. and - it is
not a threat by any means - dont expect anything other than coal in the stockings of every
member of your firm this year. Santa does indeed have a list and a very good memory.
Sincerely,

Todd Wulffson
Todd Wulffson
Carothers DiSante & Freudenberger LLP
Counsel for Kris Kringle, Inc.

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