Obj to Second App for Fee Reimbursement by Peter Vogel Doc 352

RESPONSE TO [DOC#314]  - Page 1 
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.   §   
  § 
JEFFREY BARON, and      §   
ONDOVA LIMITED COMPANY,    § 
  Defendants.          § 
 
RESPONSE TO THE RECEIVER'S SECOND APPLICATION FOR 
REIMBURSEMENT OF FEES INCURRED BY  
RECEIVERSHIP PROFESSIONAL JAMES M. ECKELS [DOC#314]  
 
  Defendant Jeffrey Baron and make this response and objection to the Receiver's 
Second  Application  For  Reimbursement  Of  Fees  Incurred  by  Receivership 
Professional James M. Eckels [Doc#314], as follows: 
1.  The  fees  requested  are  not  reasonable  and  were  not  incurred  in  the 
ordinary course of business of the LLCs.  The fees are clearly duplicative of other 
fees  paid.    The  argument  raised  in  the  Emergency  Motion  for  clarification  of 
receivership  order  filed  by  Novo  Point  LLC  and  Quantec  LLC  [Doc#269],  is 
adopted and incorporated by reference herein. 
2.  Respondent  also  adopts  and  incorporate  by  reference  the  objections  and 
responses  made  in  Appellant’s  Limited  Objection  To  The  Receiver's  First 
Application  For  Reimbursement  Of  Fees  Incurred  By  Receivership  Professional 
USCA5 736

RESPONSE TO [DOC#314]  - Page 2 
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 
Reimbursement  Of  Fees  And  Expenses  Incurred  By  Gardere  Wynne  Sewell  LLP 
[Doc#193]. 
 
 
 
                          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 
 
 
CERTIFICATE OF SERVICE 
This  is  to  certify  that  this  was  served  on  all  parties  who  receive  notification 
through the Court’s electronic filing system. 
/s/ Gary N. Schepps       
                          Gary N. Schepps 
 
USCA5 737