MOTION FOR SETTING AND
REQUEST FOR EXPEDITED HEARING
BTXN 146 (rev. 03/03)
UNITED STATES BANKRUPTCY COURT
NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
In Re:
Ondova Limited Company
Debtor(s)
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Case No.: 09-34784-sgj-11
1. Jeff Baron hereby requests that a hearing be set on the Amended Motion to Substitute and
TO RECONSIDER EMPLOYMENT OF not later than September 30, 2010. Hearing by
such date is necessary because Show Cause Hearing set for this date.
2. Notice of proposed expedited hearing will be provided to Daniel Sherman, Trustee by Jeff
Baron. This notice will be sufficient because Agreement by Trustee and all other interested
parties (if any) will be present.
3. A hearing was not requested earlier because Show Cause ordered entered Sepbember 27,
2010 and just received agreement from Trustee not to oppose the motion or the substitution.
Martin K. Thomas
Counsel for
Jeff Baron
Se
p
tember 30, 2010
CERTIFICATE OF CONFERENCE
The undersigned counsel hereby certifies that he conferred with Ray Urbanik on September 30,
2010 and that Mr. Urbanik said that the Trustee, Daniel Sherman, will not oppose the relief
requested in this motion. The Trustee was the only party who objected to the withdrawal of Mr.
Pronske (on the basis that he objected to any replacement attorney) and therefore appears to be
the only party with an interest in this motion. Mr. Gary Lyon does not oppose this Motion nor the
Amended Motion to Substitute he opposes the motion. Additionally, under Local Bankruptcy
Rule 9014-1 a conference is not required when it is reasonably anticipated that the number of
opposing parties may be too numerous to contact prior to the filing of the motion. Because of the
large number of signatories to the Global Settlement Agreement, Baron does not believe that
further conferences are required on this motion.
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(BTXN 146)
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Case 09-34784-sgj11 Doc 462 Filed 09/30/10 Entered 09/30/10 13:17:47 Desc
Main Document Page 1 of 1
/s/ Martin K. Thomas
/s/ Martin K. Thomas

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