Suggestion of Bankruptcy and Notice of Stay Page 1 of 4
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
NETSPHERE, INC. §
MANILA INDUSTRIES, INC.; and §
MUNISH KRISHAN, §
Plaintiffs, §
vs. §
§
JEFFREY BARON and §
ONDOVA LIMITED COMPANY, §§
Defendants, § CIVIL ACTION NO. 3-09-CV-0988-F
vs. §
§
CHARLA G. ALDOUS, ALDOUS §
LAW FIRM, JEFFREY RASANSKY, §
and RASANSKY LAW FIRM, §
Intervenors (proposed). §
§
QUANTEC, LLC, §
IGUANA CONSULTING, LLC, §
and NOVO POINT, LLC, §
Derivative Plaintiffs/Intervenors §
(proposed), §
vs. §
§
JEFF BARON, Individually, and as §
Director of ONDOVA LIMITED §
COMPANY, MUNISH KRISHAN, §
Individually, and as Director §
of MANILA INDUSTRIES, INC., §
ONDOVA LIMITED COMPANY, §
MANILA INDUSTRIES, INC., et al., §
Defendants in Intervention, §
§
QUANTEC, INC., IGUANA §
CONSULTING, INC., and §
NOVO POINT, INC., §
Derivative Corporations in §
Intervention (proposed). §
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Suggestion of Bankruptcy and Notice of Stay Page 2 of 4
SUGGESTION OF BANKRUPTCY AND NOTICE OF STAY
TO: THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, Ondova Limited Company (hereinafter referred to as “Debtor”) and
files this Suggestion of Bankruptcy and Notice of Stay and would respectfully show the Court
the following:
1. On July 27, 2009, Debtor filed its Voluntary Petition under Chapter 11 of the
United States Bankruptcy Code in the United States Bankruptcy Court for the Northern District
of Texas, Dallas Division, Case No. 09-34784-sgj-11 (the “Voluntary Petition”).
2. Pursuant to Section 362 of the Bankruptcy Code, the filing of the Petition
operates as a stay of:
a. The commencement or continuation, including the issuance or
employment of process, of a judicial, administrative, or other proceeding
against the Debtor that was or could have been commenced before the
commencement of the case under this Title, or to recover a claim against
the Debtor that arose before the commencement of the case under this
Title;
b. The enforcement, against the Debtor or against property of the estate, of a
judgment obtained before the commencement of the case under this Title;
c. Any act to obtain possession of property of the estate or property from the
estate;
d. Any act to create, perfect, or enforce any lien against property of the
estate;
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Suggestion of Bankruptcy and Notice of Stay Page 3 of 4
e. Any act to create, perfect, or enforce against property of the Debtor any
lien to the extent that such lien secures a claim that arose before the
commencement of the case under this Title, except to the extent provided
in Section 362(b);
f. Any act to collect assets, or recover a claim against the Debtor that arose
before the commencement of the case under this title;
g. The set off of any debt owing to the Debtor that arose before the
commencement of the case under this Title against any claim against the
Debtor; and
h. The commencement or continuation of a proceeding before the United
States Tax Court concerning the Debtor.
3. As a result of the operation of the automatic stay, all parties are stayed from any
further continuation of these proceedings until such time as the Bankruptcy Court may order
otherwise.
4. Attached hereto and incorporated herein for all purposes as Exhibit “A” is a copy
of the Voluntary Petition dated July 27, 2009, which further confirms the above stated facts.
WHEREFORE, PREMISES CONSIDERED, Debtor prays that this Court take notice
of the Bankruptcy Stay and that further action be stayed and for such other and further relief as
to which it may be justly entitled.
Dated this 27th day of July, 2009
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Suggestion of Bankruptcy and Notice of Stay Page 4 of 4
Respectfully submitted,
WRIGHT GINSBERG BRUSILOW P.C.
By: /s/ E.P. Keiffer
E. P. Keiffer (SBN 11181700)
The Elm Place Building
1401 Elm Street, Suite 4750
Dallas, Texas 75202
(214) 651-6500 - telephone
(214) 744-2615 - facsimile
PROPOSED ATTORNEY FOR ONDOVA
LIMITED COMPANY, DEBTOR
CERTIFICATE OF SERVICE
I hereby certify that the foregoing Suggestion of Bankruptcy and Notice of Stay was
served via the U.S. District Court’s electronic noticing system on July 27, 2009, and via first
class U.S. Mail, postage pre-paid, on July 28, 2009, on the parties listed below:
Peter S. Vogel, Esq.
Gardere Wynne Sewell
1601 Elm Street, Suite 3000
Dallas, TX 75201-4761
Special Master
Charla G. Aldous, Esq.
Aldous Law Firm
2305 Cedar Springs, Suite 200
Dallas, Texas 75201
Pro Se
John W. MacPete, Esq.
Locke, Lord, Bissell & Liddell, LLP
2200 Ross, Suite 2200
Dallas, Texas 75202
Attorneys for Manila Industries, Inc.,
Netsphere, Inc., and Munish Krishan
James Krause, Esq./Ryan K. Lurick, Esq.
Friedman & Feiger
5301 Spring Valley Road, Suite 200
Dallas, Texas 75254
Attorneys for Jeffrey Baron
and Ondova Limited Company
Craig A. Capua, Esq.
West & Associates LLP
320 S. RL Thornton Freeway, Suite 300
Dallas, Texas 75201
Attorney for Quantec, LLC, Iguana
Consulting, LLC, and Novo Point, LLC
Jeffrey H. Rasansky, Esq.
Robert Edward Wolf, Jr., Esq.
Rasansky Law Firm
2525 McKinnon, Suite 625
Dallas, Texas 75201
Pro Se
/s/ E.P. Keiffer
E.P. Keiffer
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Exhibit “A”
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B 1 (Official Form 1) (1/08)
United States Bankruptcy Court
Voluntary Petition
Name of Debtor (if individual, enter Last, First, Middle):
Name of Joint Debtor (Spouse) (Last, First, Middle):
All Other Names used by the Debtor in the last 8 years
(include married, maiden, and trade names):
All Other Names used by the Joint Debtor in the last 8 years
(include married, maiden, and trade names):
Last four digits of Soc. Sec. or Indvidual-Taxpayer I.D. (ITIN) No./Complete EIN
(if more than one, state all):
Last four digits of Soc. Sec. or Indvidual-Taxpayer I.D. (ITIN) No./Complete EIN
(if more than one, state all):
Street Address of Debtor (No. and Street, City, and State):
ZIP CODE
Street Address of Joint Debtor (No. and Street, City, and State):
ZIP CODE
County of Residence or of the Principal Place of Business:
County of Residence or of the Principal Place of Business:
Mailing Address of Debtor (if different from street address):
ZIP CODE
Mailing Address of Joint Debtor (if different from street address):
ZIP CODE
Location of Principal Assets of Business Debtor (if different from street address above):
ZIP CODE
Type of Debtor
(Form of Organization)
(Check one box.)
Individual (includes Joint Debtors)
See Exhibit D on page 2 of this form.
Corporation (includes LLC and LLP)
Partnership
Other (If debtor is not one of the above entities,
check this box and state type of entity below.)
__________________________________________
Nature of Business
(Check one box.)
Health Care Business
Single Asset Real Estate as defined in
11 U.S.C. § 101(51B)
Railroad
Stockbroker
Commodity Broker
Clearing B