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COMES NOW Appellant Jeffrey Baron, by and through his undersigned attorney, and
would show the Court:
1. He has been adjudged an involuntary Chapter 7 debtor under Title 11,
United States Code, in the United States Bankruptcy Court for the Northern District of
Texas, which bears the case number 12-37921-sgj7.
2. An Order for Relief was entered on June 26, 2013 over Baron’s ardent
objections, where an appeal of the Order for Relief is currently pending. Although he is
without bankruptcy counsel because the involuntary petition circumvented the Fifth
Circuit’s December 2012 Order and subsequent mandate to return receivership
property to Baron, and where he cannot access funds sufficient to hire bankruptcy
counsel, the Bankruptcy Court denied Baron’s request for a stay of its Order for Relief.
3. Shortly after Baron’s request for a stay of the Order for Relief was denied
by the Bankruptcy Court, believing the automatic stay applies, attorneys for Baron’s
Chapter 7 trustee have requested Baron suspend his pursuit of the instant appeal. (See
Attached Exh. A).
4. Although Baron disagrees the automatic stay applies to this proceeding
because it is not an action “against the debtor” within the meaning of § 362 of the
bankruptcy code, he has agreed to file the instant Suggestion of Bankruptcy in an effort
to minimize costs to his estate and to preserve judicial economy. Baron, however,
Case: 13-10696 Document: 00512350219 Page: 2 Date Filed: 08/21/2013