Emergency Motion to Preserve the Status Quo Doc 237

EMERGENCY MOTION - 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.         § 
                        §      EMERGENCY MOTION 
    v.                    §   
                        § 
JEFFREY BARON, and      §   
ONDOVA LIMITED COMPANY,  § 
  Defendants.        § 
 
 
EMERGENCY MOTION TO PRESERVE THE STATUS QUO AND 
PREVENT THE IMMINENT LOSS OF MR. BARON’S LIFE’S 
PROGRAMMING WORK  
 
 
TO THE HONORABLE ROYAL FURGESON, U.S. DISTRICT JUDGE: 
COMES NOW, Appellant Jeffrey  Baron, and respectfully request this Court to 
order  the  immediate  payment  of  server  bills  (expected  to  be  around  $200.00) 
holding  Mr.  Baron’s  programs  and  code,  so  the  code  will  not be deleted  and lost 
forever. 
 
1.  Pursuant  to  the  global  settlement  agreement,  the  intellectual  property 
(computer  code,  programs,  etc.)  Mr.  Baron  developed  over  his  lifetime  was 
quitclaimed to Mr. Baron.  
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EMERGENCY MOTION - Page 2 
2.  The  backup  copies  of  the  software  have  been  seized,  and,  upon  belief,  
apparently  destroyed.    Upon belief, the only remaining copy of Mr.  Baron’s  life’s 
work is located on servers which likely cost around $100.00 per month to maintain. 
3.  Just  as  Mr.  Sherman  has  ‘inadvertently’  allowed  Mr.  Baron’s  health 
insurance  to  lapse  after  Mr.  Baron  filed  the  appeal  in this  case,  Mr.  Sherman has 
now, ‘inadvertently’ allowed the monthly bills to be unpaid for the servers hosting, 
upon belief, the apparently only copy of Mr. Baron’s life work.  
4.  A  final  notice  has  been  received  that  at  least  one  of  the  servers  will  be 
deactivated unless the past due monthly fee is immediately paid. 
5. The three servers involved are identified as:  
CoreNetworks: Sever ID     DS.B06C26.S48LE 
CoreNetworks:  Server ID    B06S48LE 
Sego Netwroks:   Server ID    IP-63.246.144.170 
 
WHEREFORE,  Mr.  Baron  prays  this  Honorable  Court to  order  the  immediate 
payment of the server fees, and to order that the servers be backed up and a copy 
delivered to counsel for Mr. Baron.   
. 
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EMERGENCY MOTION - Page 3 
                          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 
 
 
CERTIFICATE OF CONFERENCE 
This  is  to  certify  that  the  undersigned  called  to  confer  with  counsel  for  Mr. 
Sherman and they were not available to speak with counsel. 
/s/ Gary N. Schepps       
                          Gary N. Schepps 
 
 
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