3.
The statements
in
paragraph 3 of the Response are also false. There
is
no
"special relationship· between Judge Ferguson and the Trustee, and there have been
no
ex
parte secret proceedings of any kind.
4. Mr. Schepps, the attorney who filed this appeal, has filed dozens of papers
in
the
Bankruptcy Court, the District Court and the Fifth Circuit Court of Appeals
in
which
he
repeats
these and other
ties
. They are all part of a strategy
by
which
Mr
. Schepps and his client, Jeffrey
Baron, are attempting
to
interfere with the administration of justice and continue a series of
frauds
on
the courts that has been
in
progress for at least six years, the highlights of which are
described below.
5.
On
February 4,
2011
Judge Ferguson entered his order confirming the
appointment of a receiver for
all of Jeffrey Baron's assets, finding that Baron had engaged
in
fraud and vexatious litigation conduct over a peri
od
of many years. (Docket
No.
268
in
Case
Number 3:09-cv-00988-F).
6.
On
June
27,
2011 the Fifth Circuit Court of Appeals deni
ed
one of several
Motions
to
Stay filed
by
Mr.
Schepps
on
behalf of Mr. Baron and cautioned him that further
frivolous
filings might lead
to
the imposition of sanctions. (Order of June
27,
2011
in
Consolidated Appeals 10-11202 and 11-10113).'
7. During a hearing before Bankruptcy Judge Jernigan held
on
December 5,
2011
,
Mr.
Schepps refused
to
answer questions about his deliberately obstructive conduct, pleading
the Fifth Amendment. A few of the questions and his answers
allow the Court
to
infer, as Judge
Jernigan inferred, that Mr.
Schepps' conduct was and is
in
deliberate defiance
of
the orders of
the court and done with the worst possible motives:
2 The Court should note that these appeals are part
of
Mr. Schepps efforts
to
create confusion and delay.
At present
Mr.
Schepps has filed seven appeals from more than 60 orders entered
in
Case No. 3:09-cv·
00988-F.
He
files a notice of appeal for every order,
no
matter what its substance
in
that case. More
recently Mr.
Schepps began filing appeals from orders
in
the Bankruptcy - this is one
of
six such appeals.
Three were struck
by
Judge Ferguson because Mr. Schepps had no authority
to
file them. One of the
remaini
ng
three has already been transferred to Judge Ferguson. The other was only recently docketed
and the Trustee has not yet filed a Motion
to
Transfer, though a motion will
be
fil
ed
shortly.
APPELLEE'S NOTICE OF RELATED CASE AND REQUEST TO TRANSFER CASE - Page 2
Case 3:12-cv-00387-B Document 4 Filed 02/17/12 Page 2 of 5 PageID 1419Case 3:09-cv-00988-F Document 974 Filed 06/11/12 Page 7 of 12 PageID 58836