EMERGENCY MOTION - 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. §
§ EMERGENCY MOTION
v. §
§
JEFFREY BARON, and §
ONDOVA LIMITED COMPANY, §
Defendants. §
EMERGENCY MOTION TO PRESERVE THE STATUS QUO AND
PREVENT THE IMMINENT LOSS OF MR. BARON’S LIFE’S
PROGRAMMING WORK
TO THE HONORABLE ROYAL FURGESON, U.S. DISTRICT JUDGE:
COMES NOW, Appellant Jeffrey Baron, and respectfully request this Court to
order the immediate payment of server bills (expected to be around $200.00)
holding Mr. Baron’s programs and code, so the code will not be deleted and lost
forever.
1. Pursuant to the global settlement agreement, the intellectual property
(computer code, programs, etc.) Mr. Baron developed over his lifetime was
quitclaimed to Mr. Baron.
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2. The backup copies of the software have been seized, and, upon belief,
apparently destroyed. Upon belief, the only remaining copy of Mr. Baron’s life’s
work is located on servers which likely cost around $100.00 per month to maintain.
3. Just as Mr. Sherman has ‘inadvertently’ allowed Mr. Baron’s health
insurance to lapse after Mr. Baron filed the appeal in this case, Mr. Sherman has
now, ‘inadvertently’ allowed the monthly bills to be unpaid for the servers hosting,
upon belief, the apparently only copy of Mr. Baron’s life work.
4. A final notice has been received that at least one of the servers will be
deactivated unless the past due monthly fee is immediately paid.
5. The three servers involved are identified as:
CoreNetworks: Sever ID DS.B06C26.S48LE
CoreNetworks: Server ID B06S48LE
Sego Netwroks: Server ID IP-63.246.144.170
WHEREFORE, Mr. Baron prays this Honorable Court to order the immediate
payment of the server fees, and to order that the servers be backed up and a copy
delivered to counsel for Mr. Baron.
.
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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 called to confer with counsel for Mr.
Sherman and they were not available to speak with counsel.
/s/ Gary N. Schepps
Gary N. Schepps
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