Schepps 3rd Submission of Evidence for Fake Fee Claims

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
NETSPHERE, INC.,  §
MANILA INDUSTRIES, INC., and  §
MUNISH KRISHAN,  § 
Plaintiffs.  §
§ Civil Action No. 3-09CV0988-F
v.  §
§ 
JEFFREY BARON, and §
ONDOVA LIMITED COMPANY, §
Defendants. §
MOTION FOR LEAVE TO FILE: THIRD MOTION TO SUPPLEMENT 
RECORD WITH NEWLY DISCOVERED EVIDENCE 
TO THE HONORABLE JUDGE ROYAL FURGESON:
COMES NOW JEFF BARON, and moves this Court to grant leave to file 
the  following  motion  to  supplement  the  record  with  the  evidence  attached  as 
Exhibit A:
A. WHAT THIS EVIDENCE PROVES
EXHIBIT A - THE CRANDALL INVOICE
This invoice:
(1) This invoice establishes once again the fraudulent basis of once again an 
attorney's false claim.  Mr. Crandall falsely stated under oath that during 
the course of her representation her fees were fixed at an hourly rate.  
That is false, untrue.   As proved by Exhibit A, Ms. Crandall billed at 
a flat rate. Contrary to Ms. Crandall’s claim that her signed agreement 
Case 3:09-cv-00988-F   Document 523    Filed 05/06/11    Page 1 of 5   PageID 18694

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was  to  receive  $300.00  per  hour  (an  agreement  she  never  produced),  
page  two  of  her  own  invoice  states  unequivocally,  “(Flat  Rate) 
$5,000.00”.    There is no ambiguity about it. 
(2) Once again, the receiver invited an attorney to make a ‘claim’, clearly 
false, that the attorney was to be  paid $300.00 per hour, but was paid 
less.   Exhibit A proves that, just as with one after another of the attorney 
‘claimants’, the attorneys agreed to flat or capped rates, and were paid at 
their agreed rate.  The ‘claims’ against Jeff Baron, as demonstrated by 
yet another false and fraudulent affidavit filed by yet another ‘claimant’ 
attorney solicited by the receiver, are false.   Clearly, attorneys do not 
just show up at a court's doorstep with false claims– someone solicited 
them to come.
(3) Notably, we have asked the receiver to produce the complete billings,  all 
demand  letters,  all  response  correspondence  for  each  attorney  claim.  
The receiver has refused.   As this invoice establishes, the reason is clear.   
With  all  due  respect  these  ‘claims’  are  garbage.    For  example,  from 
Pronske,  who  was  paid  a  $75,000.00  fee  up  front,  never  sent  out  an 
engagement letter or contract, never sent out an invoice, never sent out a 
billing statement, never sent out a report as to any 'retainer' or retainer 
balance,  but  when  the  settlement  agreement  was  to  be  finalized, 
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demanded a quarter million dollar bonus, claiming the $75,000.00 was a 
retainer that had long ago been used up (just Pronske didn’t get around 
to sending out any billing or notice of that at the time), to Stan Broome 
who claimed the limit on his work was merely a per  month invoicing 
limit  that  rolled  over  to  the  next  month-–  but  where,  contrary  to  his 
sworn  testimony,  his  contract  clearly  capped  incurring  fees  to 
$10,000.00 per month without express written content to exceed that cap 
in  any  month,  to  Lyon  who  fraudulently  claimed  his  billing  rate  was 
$300 per hour and $75,000.00 in fees were past due, when his rate was 
really $40.00 per hour, and he had been paid, to Taylor who now claims 
a large 'contingency' fee, but who did not mention such a fee to his client 
when the settlement was entered, and represented to his client that “We'll 
probably have a very small bill that will go out at the first of September, 
but that should be the last one.”, and now to Crandall who fraudulently 
makes the claim that during the course of her representation of Jeff, her 
fees  were  at  an  hour  rate.    Her  own  invoice  clearly  establishes  that 
during the course of the representation her rates were fixed at a flat rate, 
not an hourly rate.   Out and out false factual claims made under oath.
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  The  attorneys’  claims  have  now  been  shown  over  and  over  and  over  to  be  based  on  the 
attorneys’ false  sworn statements. But, it is Jeff Baron who is in receivership, based on these 
'claims'.  In retrospect, a receivership should never have been imposed based on mere ‘claims’.  
To cover up the fraudulent nature of the attorney’s claims there is now an attempt to burn a hole 
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B. WHY THE EVIDENCE WAS NOT RAISED EARLIER
The  undersigned  counsel  is  a  solo  practitioner.     As  a  physical  matter  of 
available time in the day,  it is not possible for counsel to have reviewed all the 
materials relevant to each of the multiple claims.
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   The receiver was requested to 
provide  key  materials  to  make  review  of  the  ‘claims’  more  efficient,  but  the 
receiver  after  first  promising  to  produce,  refused  to  produce.   Accordingly,  the 
undersigned counsel has not physically had the available hours to review all of the 
material at hand (let alone material in the possession of the receiver and claimant 
attorneys which has been withheld), and can only raise that evidence once counsel 
has, as a matter of physical time, been able to review and find the material.  
in the Constitution and cut out Jeff's Seventh Amendment right to a trial by jury.   The attorneys 
know their claims are garbage.   Although they all swore to uphold the constitution, now they 
don't want due process when it comes to investigating and testing their claims.  Jeff has been 
prevented from  hiring an investigator, Jeff has been prevented from  hiring an expert, Jeff has 
been denied discovery and denied access to the underlying evidence that clearly relates to the 
‘claims’.   As time is allowed counsel to review the material carefully: over and over the claims 
are revealed to be false and fraudulent.  The receiver and the attorneys yell at the Court that due 
process is not necessary, that rushed ‘summary proceedings’ are a good idea. But due process, in 
large and liberal quantities, is exactly what is necessary here.
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 In addition to counsel’s duties as appellate counsel (which were undertaken by the agreement 
of counsel), and counsel’s duties as trial counsel (which was placed upon counsel by this Court, 
over objection,  for which this Court has not paid for those services nor provided  funding for 
expenses or support), counsel still has pre-existing duties to other clients. If counsel had no other 
work to perform, that would mean still that only approximately one work day was allowed to 
investigate, review all the material and search for relevant evidence, research, and respond to 
each of the ‘claims’.   Since the receiver and trustee have flooded counsel with an avalanche of
paperwork, both in the trial court and in the court of appeals, the available time to review each 
claim has amounted to a fractional part of a day, per claim.   In such circumstance, it is simply 
not possible as a matter of available time to review much of the available material for each case. 
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C. RELIEF REQUESTED
Jeff Baron requests the Court to consider this evidence with respect to the 
Court’s consideration of the receiver’s motions.  
Respectfully submitted,
/s/ Gary N. Schepps
Gary N. Schepps
Texas State Bar No. 00791608
Drawer 670804
Dallas, Texas 75367
(214) 210-5940 - Telephone
(214) 347-4031 - Facsimile
E-mail: legal@schepps.net
COURT ORDERED TRIAL 
COUNSEL FOR JEFF BARON
CERTIFICATE OF SERVICE
This is to certify that this document was served this day on all parties who receive 
notification through the Court’s electronic filing system.
CERTIFIED BY: /s/ Gary N. Schepps
Gary N. Schepps
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