SECOND MOTION FOR EMERGENCY CONSIDERATION ON SHORTENED NOTICE
WITH RESPECT TO EMERGENCY MOTION TO STAY PENDING APPEAL
THE COURT'S NOVEMBER 24, 2010 ORDER APPOINTING RECEIVER - 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. §
§
v. § MOTION FOR EMERGENCY RELIEF
§
JEFFREY BARON, and §
ONDOVA LIMITED COMPANY, §
Defendants. §
SECOND MOTION FOR EMERGENCY CONSIDERATION ON SHORTENED
NOTICE WITH RESPECT TO EMERGENCY MOTION TO STAY PENDING APPEAL
OF THE COURT'S NOVEMBER 24, 2010 ORDER APPOINTING RECEIVER
TO THE HONORABLE ROYAL FURGESON, U.S. DISTRICT COURT JUDGE:
COMES NOW, Jeffrey Baron, Appellant, and again requests that the Court consider
the motion of Jeffrey Baron for Emergency Relief [Docket #137] and the entry of an
order staying the Court’s Order Appointing Receiver signed on November 24, 2010
[Docket #124, and Docket #130, Entered 11/30/2010], at the earliest time available to
the Court, and prior to 1:00pm Monday December 6, 2010. These issues require
immediate resolution since Jeffrey Baron’s constitutional rights have been unlawfully
suspended. The emotional and physical distress of being deprived of his freedom of
movement, right to possess property, right to counsel, right to contract, and access to
his own assets to seek medical care, transportation and housing, is causing irreparable
injury to his heath and well-being and requires immediate relief.
USCA5 1724
SECOND MOTION FOR EMERGENCY CONSIDERATION ON SHORTENED NOTICE
WITH RESPECT TO EMERGENCY MOTION TO STAY PENDING APPEAL
THE COURT'S NOVEMBER 24, 2010 ORDER APPOINTING RECEIVER - Page 2
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 conferred with Mr. Raymond J. Urbanik, attorney
for DANIEL J. SHERMAN, Trustee for ONDOVA LIMITED COMPANY, and they do
not oppose expedited consideration of the motion for stay.
/s/ Gary N. Schepps
Gary N. Schepps
USCA5 1725
