MOTION FOR EMERGENCY RULING ON MOTION TO STAY PENDING APPEAL - Page 2
Mr. Baron needs experienced and specialized counsel to conduct discovery
and prepare to defend the very serious new charges Mr. Urbanik brings in his
motion. As Mr. Urbanik has maneuvered his motion to be a part of the hearing set
only 4 days from now, Mr. Baron needs an attorney to represent him on these
matters immediately.
The limited scope of Appellate Counsel’s representation is strictly limited to
matters of appeal and does not cover defense of Mr. Urbanik’s newly raised
claims, nor any other matter in the district court beyond staying the order
appointing receiver pending appeal, or declaring that order void.
Mr. Urbanik’s motion seeks determination of matters including whether:
1. Mr. Baron is in breach of an injunction order,
2. Mr. Baron is violation of Federal Rule of 13 (sic),
3. Mr. Baron engaged in a bad faith bankruptcy filing,
4. Mr. Baron refused to testify, and
5. Mr. Baron is the owner of Ondova.
Mr. Urbanik also seeks the determination of substantive rights between Mr.
Baron and former attorneys and judicial determination:
6. Declaring Mr. Baron a vexatious litigant,
7. Finding Mr. Baron in breach of the settlement agreement,
8. Determining Mr. Baron’s liability to attorneys for fees.
Case 3:09-cv-00988-L Document 157 Filed 12/13/10 Page 2 of 5 PageID 3182