MOTION FOR EMERGENCY CONSIDERATION ON SHORTENED NOTICE
WITH RESPECT TO EMERGENCY MOTION TO STAY PENDING APPEAL
THE COURT'S NOVEMBER 24, 2010 ORDER APPOINTING RECEIVER - 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. § MOTION FOR EMERGENCY RELIEF
§
JEFFREY BARON, and §
ONDOVA LIMITED COMPANY, §
Defendants. §
MOTION FOR EMERGENCY CONSIDERATION ON SHORTENED
NOTICE WITH RESPECT TO EMERGENCY MOTION TO STAY PENDING APPEAL
THE COURT'S NOVEMBER 24, 2010 ORDER APPOINTING RECEIVER
TO THE HONORABLE ROYAL FURGESON, U.S. DISTRICT COURT JUDGE:
COMES NOW, Jeffrey Baron, Appellant, and requests that the Court consider the
motion of Jeffrey Baron for Emergency Relief and the entry of an order staying the
Courts Order Appointing Receiver signed on November 24, 2010 [Docket #124, and
Docket #130, Entered 11/30/2010], at the earliest time available to the Court. The
request for relief involves unlawful and unconstitutional deprivations of Mr. Barons
most basic civil rights, and the irreparable injury and suffering being inflicted upon
Mr. Baron. To protect and defend the constitution, immediate relief is sought.
USCA5 1715
MOTION FOR EMERGENCY CONSIDERATION ON SHORTENED NOTICE
WITH RESPECT TO EMERGENCY MOTION TO STAY PENDING APPEAL
THE COURT'S NOVEMBER 24, 2010 ORDER APPOINTING RECEIVER - Page 2
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 Courts electronic filing system.
/s/ Gary N. Schepps
Gary N. Schepps
CERTIFICATE OF CONFERENCE
This is to certify that the undersigned conferred with Mr. Raymond J. Urbanik, attorney
for DANIEL J. SHERMAN, Trustee for ONDOVA LIMITED COMPANY, and Mr.
Urbanik is not opposed.
/s/ Gary N. Schepps
Gary N. Schepps
USCA5 1716

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