Baron’s Statement of Issues on Appeal and Designation of Record

PAGE 1
Gary N. Schepps
Texas State Bar No. 00791608
5400 LBJ Freeway, Suite 1200
Dallas, Texas 75240
(214) 210-5940 - Telephone
(214) 347-4031 - Facsimile
Email: legal@schepps.net
Counsel for Appellant
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
In re:  §
§  Case No. 09-34784-SGJ
ONDOVA LIMITED COMPANY,  § (Chapter 11)
§
§
Debtor §
APPELLANT’S STATEMENT OF ISSUES ON APPEAL AND DESIGNATION OF 
ITEMS FOR THE RECORD
NOW COMES Appellant, in accordance with Rule 8006 of the Bankruptcy Rules and 
files  this,  Appellant’s  Statement  of  Issues  on  Appeal  and  identifies  the  following  issues  for 
Appeal:
1. Whether the Bankruptcy Court erred in granting the motion to sell the domain name 
servers.com.
2. Whether the Movant carried its burden of proof of ownership of the asset authorized 
sold.
3. Whether the debtor or bankruptcy estate is the owner of the asset authorized sold.
4. Whether the Bankruptcy Court had subject matter jurisdiction to enter its order.
5. Whether the Bankruptcy Court erred in refusing  to allow Mr. Schepps to represent 
Jeffrey  Baron’s  interests  and/or  to  appear on behalf  of  Mr.  Baron  to object  to the 
motion for authority to sell the asset.
6. Whether  the  Bankruptcy  Court  had  authority  to  make  a  determination  as  to  the 
ownership interest in the property outside of an adversary proceeding.
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7. Whether the  Bankruptcy  Court  has authority  or  power  pursuant to the doctrine  of 
Stern  v.  Marshall,  the  U.S.  Constitution  and/or  the  Bankruptcy  Code  or  Rules  to 
adjudicate or determine title and ownership of the property authorized to be sold.
8. Whether the description of the property sold is legally sufficient to have effect under 
the law.
9. The validity of any sale pursuant to the order.
Appellant,  in  accordance  with  Rule  8006  of  the  Bankruptcy  Rules  also  files  this 
Appellant’s Designation of Items for Record on Appeal and designates the following items for 
the Record on Appeal:
Item No Description Document No.
1 10-7-2011 Motion to sell property under Section 363(b) Filed by 
Trustee Daniel J. Sherman (Attachments_ _ (1) Proposed Order) 
(Pannier, Lee)  [658]
658
2 11-9-2011  Support-supplemental  document  The  Receiver's 
Supplement  to  Response  and  Reservation  of  Rights  Related  to 
Trustee's  Motion  for  Authority  to  Sell  Property  of  the  Estate-
Servers.com filed by Other [682]
682
3 Transcript  regarding  Hearing  Held  11/09/2011  RE:  Motions  to 
Sell Property.
687
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
Email: legal@schepps.net
Counsel for Appellant
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Certificate of  Service
On this date I electronically served the foregoing document using the electronic case filing system of the Bankruptcy 
Court, and served every party receiving service through the official PACER system.
/s/ Gary N. Schepps
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