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  Appellant’s  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 
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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 Court’s electronic filing system.
/s/ Gary N. Schepps
Gary N. Schepps
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