Counsel for Baron’s Report re Movant’s Participation in Psychotherapy Doc 214

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
NETSPHERE, INC., ET AL., §
PLAINTIFFS §
§
V. § Case No. 3:09-CV-0988-F
§
JEFFREY BARON, ET AL., §
DEFENDANTS. §
COUNSEL FOR JEFFREY BARON’S REPORT REGARDING 
MOVANT’S PARTICIPATION IN PSYCHOTHERAPY
1) On January 4, 2011 this Honorable Court conducted a hearing at which time His Honor
became concerned about Movant’s, Jeffrey Baron, mental state.
2) At such time His Honor directed undersigned counsel to make arrangements to ensure that
Mr. Baron received appropriate psychotherapy before the weeks end. 
3) Undersigned Counsel contacted numerous medical providers in an effort to get Jeffrey Baron
into  treatment  on  such short  notice.    The  only  provider  that  Undersigned  Counsel  was
successful in locating, who could accommodate Movant, was a Dr. Randy Ingram, Ph.D.  He
is located in Carrollton, Texas, near Movant’s residence [Movant either walks or takes the
bus for transportation].  Although Dr. Ingram is not a licensed psychologist, he works under
one and is going to receive his license shortly.  He is experienced in treating depression and
anxiety.
4) Movant executed a Waiver of Confidentiality as to between Dr. Ingram and Undersigned
Counsel.  Undersigned Counsel has filled Dr. Ingram in on the case.  Undersigned Counsel
followed up with Dr. Ingram after the Movants scheduled appointment at 10:00 a.m. on
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January  6,  2011,  to  ensure  that  Movant  had  indeed  attended  his  appointment, and was
informed by Dr. Ingram that he had (See Attachment).
5) Undersigned Counsel paid for the forgoing referral appointment out of his pocket with his
credit card, since it was on such short notice, in order to comply with this Court’s directive. 
In the process of setting up this appointment it was determine that the Receivership had
directly  caused  Baron’s  insurance  to  be  canceled.    Undersigned  Counsel  is  presently
cooperating with Mr. Barry M. Golden, counsel for Peter Vogel, the Receiver in this case,
in an effort to determine what caused this lapse in Mr. Baron’s insurance.  Mr. Barrett and
Mr. Golden have agreed to continue cooperating in an ongoing effort to make funds available
to Jeff Baron for any and all medical purposes while his insurance is out of coverage.
RESPECTFULLY SUBMITTED,
      /s/ Peter M. Barrett                 
PETER M. BARRETT
Texas Bar No.: 00790272
MOORE BARRETT & LINDER
3500 Oak Lawn Avenue
Suite 700
Dallas, TX 75219
Office: 214.526.0555
Facsimile: 214.521.0012
ATTORNEY FOR MOVANT
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CERTIFICATE OF SERVICE
On this the 7  day of January, 2011, Undersigned Counsel for Movant hereby certifies that
th
a true and correct copy of the foregoing document, Counsel For Jeffrey Baron’s Report Regarding
Movant’s Participation In Psycho Therapy, was delivered to all parties involved via the electronic
filing of this document.
/s/ Peter M. Barrett                         
ATTORNEY FOR MOVANT
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