Second Motion to Expedite Consideration for Emergency Relief

SECOND MOTION FOR EMERGENCY CONSIDERATION ON SHORTENED NOTICE  
WITH RESPECT TO EMERGENCY MOTION TO STAY PENDING APPEAL  
THE COURT'S NOVEMBER 24, 2010 ORDER APPOINTING RECEIVER - 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.         § 
                        § 
    v.                     §  MOTION FOR EMERGENCY RELIEF 
                        § 
JEFFREY BARON, and      §   
ONDOVA LIMITED COMPANY,    § 
  Defendants.        § 
 
SECOND MOTION FOR EMERGENCY CONSIDERATION ON SHORTENED 
NOTICE WITH RESPECT TO EMERGENCY MOTION TO STAY PENDING APPEAL 
OF THE COURT'S NOVEMBER 24, 2010 ORDER APPOINTING RECEIVER  
 
TO THE HONORABLE ROYAL FURGESON, U.S. DISTRICT COURT JUDGE: 
 COMES NOW, Jeffrey Baron, Appellant, and again requests that the Court consider 
the motion of Jeffrey Baron for Emergency Relief [Docket #137] and the entry of an 
order  staying  the  Court’s  Order  Appointing  Receiver  signed  on  November  24,  2010 
[Docket #124, and Docket #130, Entered 11/30/2010], at the earliest time available to 
the  Court,  and  prior  to  1:00pm  Monday  December  6,  2010.      These  issues  require 
immediate resolution since Jeffrey Baron’s constitutional rights have been unlawfully 
suspended.  The  emotional  and  physical  distress  of being deprived of  his  freedom  of 
movement, right to possess property, right to counsel, right to contract, and access to 
his own assets to seek medical care, transportation and housing, is causing irreparable 
injury to his heath and well-being and requires immediate relief.  
 
USCA5 1724

SECOND MOTION FOR EMERGENCY CONSIDERATION ON SHORTENED NOTICE  
WITH RESPECT TO EMERGENCY MOTION TO STAY PENDING APPEAL  
THE COURT'S NOVEMBER 24, 2010 ORDER APPOINTING RECEIVER - Page 2 
                          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 conferred with Mr. Raymond J. Urbanik, attorney 
for DANIEL J. SHERMAN, Trustee for ONDOVA LIMITED COMPANY, and they do 
not oppose expedited consideration of the motion for stay. 
/s/ Gary N. Schepps      
                          Gary N. Schepps 
 
 
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