G A R Y N. S C H E P P S
A T T O R N E Y & C O U N S E L O R
DALLAS, TEXAS 75367
April 17, 2012
VIA EMAIL (and PACER)
Hon. Judge W. Royal Furgeson, Jr.
United States District Judge
1100 Commerce Street, Room 1359
Dallas, Texas 75242-1001
Re: 3-09CV0988-F In Re Jeffrey Baron Receivership Order
This letter is intended to raise to Your Honor’s attention that Jeffrey Baron is not
represented by counsel with respect to the underlying, settled lawsuit. As has been
frequently raised to Your Honor’s attention, the scope of my retention with respect to Mr.
Baron is limited to specific appellate matters. Accordingly, unless retained to do so, I am
not representing Mr. Baron with respect to the underlying Complaint or “the issues, if
any, needed to be addressed in order to close the underlying case”. As currently set, the
rights of Mr. Baron with respect to those matters are being represented by Mr. Vogel in
his fiduciary capacity.
If helpful, I note that I would be willing to undertake the responsibility of
representing Mr. Baron with respect to the underlying Complaint, as discussed below. I
would require a $50,000.00 non-refundable initial retainer with a $30,000.00 evergreen,
plus a refundable (to the extent unexpended) $15,000.00 initial expense retainer with a
$5,000.00 minimum expense retainer balance maintained. An additional non-refundable
trial retainer of $200,000.00 would be due upon the setting of any matter within the scope
of the representation for trial, should that occur. I would require a short postponement of
the current hearing setting by about 14 days in order to review the underlying and
operative materials and to get up to speed on the relevant legal issues. If Your Honor
desires to allow Mr. Baron to be represented by counsel on the matter, for me to get
started all that is needed is Court approval, Mr. Baron’s execution of a retainer contract,
and a check from Mr. Baron’s funds.
Case 3:09-cv-00988-F Document 866 Filed 04/17/12 Page 1 of 2 PageID 44975