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Appellants Joint Response to Receiver's 1st App for Fees Doc 244

RESPONSE TO [DOC#196] - Page 1
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
NETSPHERE, INC., § Civil Action No. 3-09CV0988-F
MANILA INDUSTRIES, INC., and §
MUNISH KRISHAN, §
Plaintiffs. §
§
v. §
§
JEFFREY BARON, and §
ONDOVA LIMITED COMPANY, §
Defendants. §
APPELLANTS JOINT RESPONSE TO THE RECEIVER'S FIRST
APPLICATION FOR REIMBURSEMENT OF FEES INCURRED BY
RECEIVERSHIP PROFESSIONAL JAMES M. ECKELS [DOC#196]
TO THE HONORABLE ROYAL FURGESON, U.S. DISTRICT JUDGE:
COMES NOW, Appellant, defendant Jeffrey Baron and Appellants
NovoPoint, LLC and Quantec, LLC and make this joint response and objection to
the Receiver's First Application For Reimbursement Of Fees Incurred By
Receivership Professional James M. Eckels [Doc#196].
1. Respondents adopt and incorporate by reference the objections and
responses made in Appellants Limited Objection To The Receiver's First
Application For Reimbursement Of Fees Incurred By Receivership Professional
Joshua Cox [Doc#190] and in Appellants Joint Objection And Response To (1)
The Receiver's First Application For Reimbursement Of Fees And Expenses
Incurred By The Receiver [Doc#192] And (2) The Receiver's First Application For
USCA5 72
RESPONSE TO [DOC#196] - Page 2
Reimbursement Of Fees And Expenses Incurred By Gardere Wynne Sewell LLP
[Doc#193].
2. To the extent that the requested fees are bona fide expenses incurred by
the LLC entities in the ordinary course of their business activities, (and so long as the
LLC entities are paying the bill), the Court clearly has jurisdiction to ensure the
ongoing operation of the LLC entities as that is the status quo. Accordingly, no
objection is made to that portion of the requested fees which are bona fide expenses
incurred by the LLC entities in the ordinary course of business and to be paid for
by those entities.
Respectfully submitted,
/s/ Gary N. Schepps
Gary N. Schepps
State Bar No. 00791608
Drawer 670804
Dallas, Texas 75367
(214) 210-5940
(214) 347-4031 Facsimile
APPELLATE COUNSEL FOR
JEFFREY BARON, NOVO POINT,
LLC, and QUANTEC, LLC
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RESPONSE TO [DOC#196] - Page 3
CERTIFICATE OF SERVICE
This is to certify that this was served on all parties who receive notification
through the Courts electronic filing system.
/s/ Gary N. Schepps
Gary N. Schepps
USCA5 74


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