Motion to Seal Settlement Agreement by Pronske

JOINT MOTION TO FILE SETTLEMENT AGREEMENT UNDER SEAL - Page 1 of 1 
Gerrit M. Pronske 
State Bar No. 16351640 
Melanie P. Goolsby 
State Bar No. 24059841 
PRONSKE & PATEL, P.C. 
2200 Ross Avenue, Suite 5350 
Dallas, Texas 75201 
(214) 658-6500 - Telephone 
(214) 658-6509 – Telecopier 
Email: gpronske@pronskepatel.com 
Email: mgoolsby@pronskepatel.com 
 
COUNSEL FOR THE PETITIONING 
CREDITORS 
Mark Stromberg 
State Bar No. 19508830 
Stromberg Stock, PLLC 
Two Lincoln Centre 
5420 LBJ Freeway, Suite 300 
Dallas, Texas 75240 
Telephone 972/458-5335 
Facsimile 972/770-2156 
Email: mark@strombergstock.com 
 
ATTORNEYS FOR JEFFREY BARON, 
ALLEGED DEBTOR 
 
IN THE UNITED STATES BANKRUPTCY COURT 
FOR THE NORTHERN DISTRICT OF TEXAS 
DALLAS DIVISION 
 
In re:  
 
JEFFREY BARON, 
 
Debtor. 
§ 
§ 
§ 
§ 
§ 
 
CASE NO. 12-37921-7 
 
INVOLUNTARY CHAPTER 7 
PROCEEDING 
 
JOINT MOTION TO FILE SETTLEMENT AGREEMENT UNDER SEAL 
 
TO THE HONORABLE STACEY G.C. JERNIGAN, 
UNITED STATES BANKRUPTCY JUDGE: 
 
Pronske  &  Patel,  P.C.,  Shurig  Jetel  Beckett  Tackett,  Dean  Ferguson,  Gary  G.  Lyon, 
Robert Garrey, Powers Taylor, LLP, Jeffrey Hall, and David Pacione (together, the “Petitioning 
Creditors”)  and  Jeffrey  Baron,  the  Alleged  Debtor  (“Baron”  and  together  with  the  Petitioning 
Creditors,  the  “Parties”)  file  this  Joint  Motion  to  File  Settlement  Agreement  Under  Seal  (the 
“Motion”)  pursuant to  Sections  105(a)  of  the  United  States  Bankruptcy  Code  and  11  U.S.C.  §§ 
101 et. seq. (the “Bankruptcy Code”), for the entry of an order authorizing the Parties to file their 
proposed  settlement  agreement containing  personal  and  confidential  information  under  seal.  In 
support of this Motion, the Parties respectfully represents as follows: 
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JOINT MOTION TO FILE SETTLEMENT AGREEMENT UNDER SEAL - Page 2 of 2 
1.  As  more  fully  set  forth  in  the  motion  to  approve  settlement  agreement  filed 
contemporaneously  with  this  motion  (the  “Settlement  Agreement”),  the  Petitioning  Creditors, 
Baron,  and  potentially  other  parties  have  reached  a  settlement  and  agreed  wind-down  plan  to 
finally resolve the disputes underlying the Receivership and involuntary matter that provides for 
the  payment  in  full  of  the  Receivership  professional  claims  allowed  by  the  District  Court, 
payment  of  the  claims  of  the  Petitioning  Creditors’  and  other  attorney  claimants  at  an  agreed 
percentage,  and  return  of  Baron’s  remaining  assets  to  Baron  or  the  appropriate  Receivership 
party. 
2.  The Parties believe that the Settlement Agreement contains confidential, sensitive 
information  that  should  not  be  made  publicly  available  until  after  the  expedited  hearing 
requested  on  Monday,  June  24,  2013,  including  details  related  to  the  sale  of  a  portfolio  of 
domain names and the terms of a proposed compromise between Baron and his current lawyers. 
There  is  a  risk  that,  should  these  sensitive  details  become  publicly  available,  the  terms  of  the 
Settlement Agreement may no longer be viable. 
3.  The  Parties  respectfully  request  this  Court’s  permission  to  file  the  Settlement 
Agreement under seal prior to the requested expedited hearing on Monday, June 24, 2013. 
WHEREFORE,  PREMISES  CONSIDERED,  the  Petitioning  Creditors  and  Baron 
respectfully  request  that  the  Court  enter  an  order  authorizing  the  Parties  to  file  the  Settlement 
Agreement under seal and grant the Petitioning Creditors and Baron such other and further relief 
to which they may be justly entitled. 
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JOINT MOTION TO FILE SETTLEMENT AGREEMENT UNDER SEAL - Page 3 of 3 
Dated: June 21, 2013. 
Respectfully submitted, 
 
 
/s/ Melanie P. Goolsby 
Gerrit M. Pronske 
State Bar No. 16351640 
Melanie P. Goolsby 
State Bar No. 24059841 
PRONSKE & PATEL, P.C. 
2200 Ross Avenue, Suite 5350 
Dallas, Texas 75201 
(214) 658-6500 - Telephone 
(214) 658-6509 – Telecopier 
Email: gpronske@pronskepatel.com 
Email: mgoolsby@pronskepatel.com 
 
COUNSEL FOR THE PETITIONING 
CREDITORS 
 
And 
 
 
/s/ Mark Stromberg* 
Mark Stromberg 
State Bar No. 19508830 
Stromberg Stock, PLLC 
Two Lincoln Centre 
5420 LBJ Freeway, Suite 300 
Dallas, Texas 75240 
Telephone 972/458-5335 
Facsimile 972/770-2156 
Email: mark@strombergstock.com 
 
*with permission /s/ Melanie P. Goolsby 
 
ATTORNEYS FOR JEFFREY BARON, 
ALLEGED DEBTOR 
 
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JOINT MOTION TO FILE SETTLEMENT AGREEMENT UNDER SEAL - Page 4 of 4 
CERTIFICATE OF SERVICE 
 
  The undersigned does hereby certify that, on June 21, 2013, a true and correct copy of the 
above and foregoing pleading was served upon the counsel and parties listed below via email and 
also via ECF email upon all parties accepting such service. 
 
David J. Schenck 
Jeffrey R. Fine 
Dykema Gossett, PLLC 
1717 Main Street, Suite 4000 
Dallas, Texas 75201 
Email: dschenck@dykema.com 
            jfine@dykema.com 
 
Peter Vogel 
Gardere Wynne Sewell 
1601 Elm Street, Suite 3000 
Dallas, Texas 75201-4761 
Email: pvogel@gardere.com 
 
Richard M. Roberson 
Gardere Wynne Sewell, LLP 
1601 Elm Street, Suite 3000 
Dallas, Texas 75201 
Email: rroberson@gardere.com 
 
Raymond J. Urbanik 
Munsch, Hardt, Kopf & Harr, P.C. 
500 N. Akard Street, Ste. 3800 
Dallas, Texas 75201-6659 
Email: rurbanik@munsch.com 
John W. MacPete 
MacPete IP Law 
P.O. Box 224762 
Dallas, Texas 75222 
Email: jmacpete@macpeteiplaw.com 
 
 
 
/s/ Melanie P. Goolsby 
Melanie P. Goolsby 
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