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EXPEDITED MOTION TO RESET DUE to PASSOVER

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
NETSPHERE, INC., §
MANILA INDUSTRIES, INC., and §
MUNISH KRISHAN, §
Plaintiffs. §
§ Civil Action No. 3-09CV0988-F
v. §
§ Motion for Expedited Relief
JEFFREY BARON, and §
ONDOVA LIMITED COMPANY, §
Defendants. §
MOTION FOR LEAVE TO FILE: EXPEDITED MOTION TO RESET
APRIL 25 HEARING DATE
TO THE HONORABLE JUDGE ROYAL FURGESON:
COMES NOW JEFF BARON, and moves this Court to grant leave to file the
following expedited motion to reset the hearing currently set for April 25, 2011 because
that date falls on the 21
st
day of Nisan, a religious day of observance for the
undersigned counsel.
The undersigned counsel observes the religious holiday of Passover according to
the lunar calendar. This year, the 15 and 16
th
of Nisan (Nisan is the first month of the
Hebrew calendar, representing God’s freeing the Hebrew nation from slavery in Egypt)
fall on the 19
th
and 20
th
of April. Those are the first two observed days of Passover.
The 21
st
and 22
nd
of Nisan fall this year on the 25
th
and 26
th
days of April. Those are the
second two observed days of Passover. As a matter of religious faith and observance,
the undersigned is prohibited from working on those dates.
Case 3:09-cv-00988-F Document 454 Filed 04/18/11 Page 1 of 3 PageID 17285
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The undersigned has attempted to have another attorney fill in during the
religious holiday. Primarily because they were concerned that they would be ordered to
be counsel for all purposes without pay, as this Court has done to the undersigned, no
attorney was willing to assist in appearing on this matteras appears to be an intended
or unintended purpose of the prior orders of the Court, to prevent Mr. Baron from being
represented by experienced federal trial counsel.
The receiver has refused to agree to resetting the hearing date for their motion.
This is the first time in all of the undersigneds years of practice that a movant has ever
failed to extend the courtesy of making an agreed motion to reset a hearing falling on
the Passover holiday, and has forced the undersigned to file a formal motion seeking
such relief.
Respectfully submitted,
/s/ Gary N. Schepps
Gary N. Schepps
Texas State Bar No. 00791608
5400 LBJ Freeway, Suite 1200
Dallas, Texas 75240
(214) 210-5940 - Telephone
(214) 347-4031 - Facsimile
E-mail: legal@schepps.net
COURT ORDERED TRIAL
COUNSEL FOR JEFF BARON
Case 3:09-cv-00988-F Document 454 Filed 04/18/11 Page 2 of 3 PageID 17286
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CERTIFICATE OF SERVICE
This is to certify that this brief was served this day on all parties who receive
notification through the Court’s electronic filing system.
CERTIFICATE OF CONFERENCE
This is to certify that I contacted counsel for the receiver, and was unable to obtain
their agreement to this motion.
CERTIFIED BY: /s/ Gary N. Schepps
Gary N. Schepps
VERIFICATION
DATED: April 18, 2011.
I declare under penalty of perjury that the cause for continuance stated in this motion
is true and correct.
/s/ Gary N. Schepps
Gary N. Schepps
Case 3:09-cv-00988-F Document 454 Filed 04/18/11 Page 3 of 3 PageID 17287


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