Objection to Proposed Order of Severance Baron

Page 1 of 5 
No. DC-10-11915 
JEFF BARON, 
    Plaintiff, 
 
v. 
 
GERRIT M. PRONSKE, Individually, 
AND PRONSKE, GOOLSBY & 
KATHMAN, P.C. f/k/a PRONSKE & 
PATEL, P.C., 
    Defendants. 
§ 
§ 
§ 
§ 
§ 
§ 
§ 
§ 
§ 
§ 
IN THE DISTRICT COURT 
 
 
 
OF DALLAS COUNTY, TEXAS    
 
 
 
193
RD
 JUDICIAL DISTRICT 
SECOND OBJECTION TO PROPOSED ORDER OF SEVERANCE 
TO THE HONORABLE CARL GINSBERG: 
  Jeffrey  Baron files this Objection to the Order for Severance proposed  by  Mr.  Pronske 
and his firm for the following reasons: 
 The Order of Severance should specifically identify the pleadings, motions, orders and other 
filings that the Clerk can include them in the severed file.  These pleadings, motions, orders and 
other filings should be included in the severed file, so that, when this case goes up on appeal, the 
appellate court will have a complete record of the proceedings below as it relates to Pronske and 
his firm.  Some of the pleadings, motions, orders and other filings reside in the Removed Case, 
Adversary  No.  10-03281-sgj,  pending  in  the  United  States  Bankruptcy  Court  for  the  Northern 
District of Texas - Dallas Division, prior to remand to this Court in May 2014, and they will have 
to be supplied by the parties to the Clerk.  The pleadings should include the following: 
A.  PLEADINGS FILED IN ADVERSARY NO. 10-03281-SGJ, PENDING IN THE UNIT-
ED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS 
- DALLAS DIVISION, PRIOR TO REMAND TO THIS COURT 
 
1.  2010-09-15 Notice of Removal filed by Pronske and his firm; 
FILED
DALLAS COUNTY
9/25/2014 5:32:59 PM
GARY FITZSIMMONS
DISTRICT CLERK

Page 2 of 5 
2.  2010-09-27  Answer  to  complaint  ,  Counterclaim  &  3rd  Party  Complaint  filed  by 
Pronske and his firm; 
3.  2010-10-15 Motion for remand and Motion to Strike filed by Jeffrey Baron; 
4.  2010-10-15 Brief in support filed by Counter-Defendant-Jeffrey Baron; 
5.  2010-10-15 Appendix in Support of Motion to Remand; 
6.  2010-11-03 Order Abating Adversary Proceeding and Setting Status Conference; 
7.  2011-04-06 Order Abating Adversary and Setting Status Conference hearing; 
8.  2011-11-08 Motion to Enter Scheduling Order filed by Pronske and his lawfirm; 
9.  2011-11-30  Response  and  Opposition  to  Pronske  &  Patel’s  Motion  for  Entry  of 
Scheduling filed by Peter Vogel, Receiver; 
10. 2014-03-13 Application for Prejudgment Garnishment filed by Pronske and his firm; 
11. 2014-03-13 Emergency Motion to Lift Abatement filed by Pronske and his firm; 
12. Motion for Emergency Hearing filed by Pronske and his firm; 
13. 2014-03-14 Order Denying  Emergency Hearing; 
14. 2014-03-15 Order Setting Hearings; 
15. 2014-03-28 Order Setting Hearings; 
16. 2014-04-08 PGK Withdrawal of Motion to Lift Abatement;  
17. 2014-04-28 Notice of Appearance – Pendergraft & Simon, LLP; 
18. 2014-05-05 Order Remanding Case; 
19. Docket Sheets – Adversary No. 10-03281, in the United States Bankruptcy Court for 
the Northern District of Texas - Dallas Division;  
 
 
 

Page 3 of 5 
B.  PLEADINGS,  MOTIONS,  ORDERS  AND  OTHER  PAPERS  FILED  IN  CAUSE 
NO. -10-11915 
 
1.  2010-09-15 Original Petition filed by Jeffrey Baron; 
2.  2014-05-16  Defendants’  First Amended Answer  and  Counterclaim  filed  by  Pronske 
and his firm; 
3.  2014-05-16 Defendants’ First Amended Counterclaim filed by Pronske and his firm; 
4.  2014-05-16 Motion for Partial Summary Judgment filed by Pronske and his firm; 
5.  2014-06-03 Suggestion of Stay filed by Jeffrey Baron; 
6.  2014-06-04 Answer to Pronske's First Amended Counterclaim filed by Jeffrey Baron; 
7.  2014-06-05 Motion to Strike Suggestion of Stay filed by Pronske and his firm; 
8.  2014-06-09 Motion to Transfer Related Case to this Court – Case No. 14-02619; 
9.  2014-06-11 Order Transferring Consolidating Cases; 
10. 2014-06-20 Motion for Clarification Regarding Abatement and District Court Injunc-
tion filed by Jeffrey Baron; 
11. 2014-06-23 Original Counterclaim filed by Jeffrey Baron; 
12. 2014-06-25 Objection to Visiting Judge filed by Pronske and his firm; 
13. 2014-06-30 First Amended Petition filed by Jeffrey Baron; 
14. 2014-06-30 Order Denying Motion to Strike; 
15. 2014-06-30 Response to Motion for Summary Judgment filed by Jeffrey Baron; 
16. 2014-06-30  Supplemental  Answer  to  First  Amended  Counterclaim  filedby  Jeffrey 
Baron; 
17. 2014-07-08 Order Striking Suggestion of Stay Per Federal Injunction; 
18. 2014-07-25 Amended Motion for Summary Judgment filed by Pronske and his firm; 

Page 4 of 5 
19. 2014-08-18 Response to Motion for Summary Judgment filed by Jeffrey Baron; 
20. 2014-08-18 Second Supplemental Answer filed by Jeffrey Baron; 
21. 2014-08-22 Reply to Response to Amended Motion for Summary Judgment filed by 
Pronske and his firm; 
22. 2014-08-28 Jury Demand filed by Jeffrey Baron; 
23. 2014-09-02 Proposed Final Summary Judgment filed by Pronske and his firm; 
24. 2014-09-02 Objection to Proposed Order filed by Jeffrey Baron; 
25. 2014-09-03 Ltr to Judge Ginsberg filed by Pronske and his firm; 
26. 2014-09-03 Second Objection to Proposed Order filed by Jeffrey Baron; 
27. 2014-09-03 Final Summary Judgment; 
28. 2014-09-09 Final Judgment; 
29. 2014-09-11 Turnover Application filed by Pronske and his firm; 
30. 2014-09-11 Motion for Severance filed by Pronske and his firm; 
31. Docket Sheets in Cause No. DC-10-11915 
C.  PLEADINGS,  MOTIONS,  ORDERS  AND  OTHER  PAPERS  FILED  IN  CAUSE 
NO. DC-14-02622 – CONSOLIDATED INTO CAUSE NO. DC-10-11915 
 
1.  2014-03-17 Application for Pre-Judgment Writ of Garnishment filed by Pronske and 
his firm; 
2.  2014-03-17 Order Granting Garnishment; 
3.  2014-03-17 Officer’s Returns on Writ of Garnishment; 
4.  Docket Sheets in Cause No. DC-14-02622 
 
  

Page 5 of 5 
Respectfully Submitted, 
Pendergraft & Simon, LLP 
2777 Allen Parkway, Suite 800 
Houston, TX 77019 
Tel. (713) 528-8555 
Fax. (713) 868-1267 
/s/ Leonard H. Simon 
By: Leonard H. Simon 
Texas Bar No. 18387400 
lsimon@pendergraftsimon.com 
William P. Haddock 
Texas Bar No. 00793875 
whaddock@pendergraftsimon.com 
Counsel for Jeff Baron 
Certificate of  Service 
I  hereby  certify  that  a  true  and  correct  copy  of  the  above  SECOND  Objection  to  Proposed 
ORDER  OF  SEVERANCE  has  been  served  on  the  following  counsel/parties  of  record  in  ac-
cordance with TEX. R. CIV. P. 21a and local rules for electronic filing and service on this 25
th
 day 
of September 2014. 
Gerrit M. Pronske 
Jason P. Kathman 
Melanie P. Goolsby 
Pronske Goolsby & Kathman, PC 
2200 Ross Ave., Suite 5350 
Dallas, TX 75201 
Fax. 214-658-6509 
 
/s/ Leonard H. Simon 
Leonard H. Simon