JOINT MOTION TO FILE SETTLEMENT AGREEMENT UNDER SEAL - Page 1 of 1
Gerrit M. Pronske
State Bar No. 16351640
Melanie P. Goolsby
State Bar No. 24059841
PRONSKE & PATEL, P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
(214) 658-6500 - Telephone
(214) 658-6509 – Telecopier
Email: gpronske@pronskepatel.com
Email: mgoolsby@pronskepatel.com
COUNSEL FOR THE PETITIONING
CREDITORS
Mark Stromberg
State Bar No. 19508830
Stromberg Stock, PLLC
Two Lincoln Centre
5420 LBJ Freeway, Suite 300
Dallas, Texas 75240
Telephone 972/458-5335
Facsimile 972/770-2156
Email: mark@strombergstock.com
ATTORNEYS FOR JEFFREY BARON,
ALLEGED DEBTOR
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
In re:
JEFFREY BARON,
Debtor.
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CASE NO. 12-37921-7
INVOLUNTARY CHAPTER 7
PROCEEDING
JOINT MOTION TO FILE SETTLEMENT AGREEMENT UNDER SEAL
TO THE HONORABLE STACEY G.C. JERNIGAN,
UNITED STATES BANKRUPTCY JUDGE:
Pronske & Patel, P.C., Shurig Jetel Beckett Tackett, Dean Ferguson, Gary G. Lyon,
Robert Garrey, Powers Taylor, LLP, Jeffrey Hall, and David Pacione (together, the “Petitioning
Creditors”) and Jeffrey Baron, the Alleged Debtor (“Baron” and together with the Petitioning
Creditors, the “Parties”) file this Joint Motion to File Settlement Agreement Under Seal (the
“Motion”) pursuant to Sections 105(a) of the United States Bankruptcy Code and 11 U.S.C. §§
101 et. seq. (the “Bankruptcy Code”), for the entry of an order authorizing the Parties to file their
proposed settlement agreement containing personal and confidential information under seal. In
support of this Motion, the Parties respectfully represents as follows:
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JOINT MOTION TO FILE SETTLEMENT AGREEMENT UNDER SEAL - Page 2 of 2
1. As more fully set forth in the motion to approve settlement agreement filed
contemporaneously with this motion (the “Settlement Agreement”), the Petitioning Creditors,
Baron, and potentially other parties have reached a settlement and agreed wind-down plan to
finally resolve the disputes underlying the Receivership and involuntary matter that provides for
the payment in full of the Receivership professional claims allowed by the District Court,
payment of the claims of the Petitioning Creditors’ and other attorney claimants at an agreed
percentage, and return of Baron’s remaining assets to Baron or the appropriate Receivership
party.
2. The Parties believe that the Settlement Agreement contains confidential, sensitive
information that should not be made publicly available until after the expedited hearing
requested on Monday, June 24, 2013, including details related to the sale of a portfolio of
domain names and the terms of a proposed compromise between Baron and his current lawyers.
There is a risk that, should these sensitive details become publicly available, the terms of the
Settlement Agreement may no longer be viable.
3. The Parties respectfully request this Court’s permission to file the Settlement
Agreement under seal prior to the requested expedited hearing on Monday, June 24, 2013.
WHEREFORE, PREMISES CONSIDERED, the Petitioning Creditors and Baron
respectfully request that the Court enter an order authorizing the Parties to file the Settlement
Agreement under seal and grant the Petitioning Creditors and Baron such other and further relief
to which they may be justly entitled.
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Dated: June 21, 2013.
Respectfully submitted,
/s/ Melanie P. Goolsby
Gerrit M. Pronske
State Bar No. 16351640
Melanie P. Goolsby
State Bar No. 24059841
PRONSKE & PATEL, P.C.
2200 Ross Avenue, Suite 5350
Dallas, Texas 75201
(214) 658-6500 - Telephone
(214) 658-6509 – Telecopier
Email: gpronske@pronskepatel.com
Email: mgoolsby@pronskepatel.com
COUNSEL FOR THE PETITIONING
CREDITORS
And
/s/ Mark Stromberg*
Mark Stromberg
State Bar No. 19508830
Stromberg Stock, PLLC
Two Lincoln Centre
5420 LBJ Freeway, Suite 300
Dallas, Texas 75240
Telephone 972/458-5335
Facsimile 972/770-2156
Email: mark@strombergstock.com
*with permission /s/ Melanie P. Goolsby
ATTORNEYS FOR JEFFREY BARON,
ALLEGED DEBTOR
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JOINT MOTION TO FILE SETTLEMENT AGREEMENT UNDER SEAL - Page 4 of 4
CERTIFICATE OF SERVICE
The undersigned does hereby certify that, on June 21, 2013, a true and correct copy of the
above and foregoing pleading was served upon the counsel and parties listed below via email and
also via ECF email upon all parties accepting such service.
Peter Vogel
Gardere Wynne Sewell
1601 Elm Street, Suite 3000
Dallas, Texas 75201-4761
Email: pvogel@gardere.com
Raymond J. Urbanik
Munsch, Hardt, Kopf & Harr, P.C.
500 N. Akard Street, Ste. 3800
Dallas, Texas 75201-6659
Email: rurbanik@munsch.com
/s/ Melanie P. Goolsby
Melanie P. Goolsby
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