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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
NETSPHERE, INC., ET. AL. §
Plaintiffs §
§ Civil Action No. 3-09CV0988-F
v. §
JEFFREY BARON, ET. AL. §
Defendants. §
MOTION FOR LEAVE TO FILE MOTION TO RECONSIDER COURT’S
DENIAL [DOC 1028] OF:
BARON’S MOTION FOR CORRECTION OF THE RECORD AND
CLARIFICATION REGARDING THE SECRET EX PARTE
PROCEEDINGS TO INSTALL VOGEL AS RECEIVER OVER BARON
AND TO CONFIRM AND APPROVE A STATEMENT OF THE SECRET
EX PARTE PROCEEDINGS THAT WERE HELD [DOC 974]
JEFFREY BARON respectfully moves this Court reconsider its denial of leave to
file Baron’s motion for the Court to (1) confirm and clarify that an ex parte hearing was
held to install Peter Vogel as receiver over Baron, (2) to clarify certain issues regarding
the ex parte proceedings, and (3) to confirm and approve a statement of the secret ex
parte proceedings which were held.
1. This Honorable Court has ordered [Doc 359] that Baron is required to file
motions for leave in order to file motions.
2. As discussed below, this Honorable Court has erred in believing that an
order declaring the issue moot was appropriate because the Court declined to grant
Baron’s motion [Doc 974] prior to the deadline to file Baron’s principal briefing in the
most recent interim appeal pending before the Fifth Circuit.
3. The necessity for the relief by correction of the record and clarifications
regarding the secret ex parte hearing and proceedings and the confirmation and approval
Case 3:09-cv-00988-F Document 1033 Filed 07/16/12 Page 1 of 2 PageID 60204
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of a statement of the secret ex parte proceedings is relevant not only to the principal
briefing that has already been filed, but is also relevant to future briefings in the Fifth
Circuit Court of Appeals, including (A) reply briefing in the pending appeals, and (B)
briefing in appeals from orders that have not yet been briefed before the Fifth Circuit,
such as from recently granted orders disposing of receivership res.
WHEREFORE Jeffrey Baron respectfully prays that this Honorable Court grant
the relief requested.
Respectfully submitted,
/s/ Gary N. Schepps
Gary N. Schepps
Texas State Bar No. 00791608
(972) 200-0000
(972) 200-0535 fax
Drawer 670804
Dallas, Texas 75367
E-mail: legal@schepps.net
APPELLATE COUNSEL
FOR JEFFREY 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
Case 3:09-cv-00988-F Document 1033 Filed 07/16/12 Page 2 of 2 PageID 60205

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