-2-

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. §

§ Motion for Expedited Relief

JEFFREY BARON, and §

ONDOVA LIMITED COMPANY, §

Defendants. §

MOTION FOR LEAVE TO FILE: EXPEDITED MOTION TO RESET

APRIL 25 HEARING DATE

TO THE HONORABLE JUDGE ROYAL FURGESON:

COMES NOW JEFF BARON, and moves this Court to grant leave to file the

following expedited motion to reset the hearing currently set for April 25, 2011 because

that date falls on the 21

day of Nisan, a religious day of observance for the

undersigned counsel.

The undersigned counsel observes the religious holiday of Passover according to

the lunar calendar. This year, the 15 and 16

of Nisan (Nisan is the first month of the

Hebrew calendar, representing God’s freeing the Hebrew nation from slavery in Egypt)

fall on the 19

and 20

of April. Those are the first two observed days of Passover.

The 21

and 22

of Nisan fall this year on the 25

and 26

days of April. Those are the

second two observed days of Passover. As a matter of religious faith and observance,

the undersigned is prohibited from working on those dates.

Case 3:09-cv-00988-F Document 454 Filed 04/18/11 Page 1 of 3 PageID 17285

-3-

The undersigned has attempted to have another attorney fill in during the

religious holiday. Primarily because they were concerned that they would be ordered to

be counsel for all purposes without pay, as this Court has done to the undersigned, no

attorney was willing to assist in appearing on this matter– as appears to be an intended

or unintended purpose of the prior orders of the Court, to prevent Mr. Baron from being

represented by experienced federal trial counsel.

The receiver has refused to agree to resetting the hearing date for their motion.

This is the first time in all of the undersigned’s years of practice that a movant has ever

failed to extend the courtesy of making an agreed motion to reset a hearing falling on

the Passover holiday, and has forced the undersigned to file a formal motion seeking

such relief.

Respectfully submitted,

/s/ Gary N. Schepps

Gary N. Schepps

Texas State Bar No. 00791608

5400 LBJ Freeway, Suite 1200

Dallas, Texas 75240

(214) 210-5940 - Telephone

(214) 347-4031 - Facsimile

E-mail: legal@schepps.net

COURT ORDERED TRIAL

COUNSEL FOR JEFF BARON

Case 3:09-cv-00988-F Document 454 Filed 04/18/11 Page 2 of 3 PageID 17286

-4-

CERTIFICATE OF SERVICE

This is to certify that this brief was served this day on all parties who receive

notification through the Court’s electronic filing system.

CERTIFICATE OF CONFERENCE

This is to certify that I contacted counsel for the receiver, and was unable to obtain

their agreement to this motion.

CERTIFIED BY: /s/ Gary N. Schepps

Gary N. Schepps

VERIFICATION

DATED: April 18, 2011.

I declare under penalty of perjury that the cause for continuance stated in this motion

is true and correct.

/s/ Gary N. Schepps

Gary N. Schepps

Case 3:09-cv-00988-F Document 454 Filed 04/18/11 Page 3 of 3 PageID 17287