MOTIONTOSTAYTHEIMPOSITIONOFSANCTIONSPENDINGAPPEALAND.pdfVIP

Case 3:10-cv-01900-N Document 23 Filed 10/26/11 Page 1 of 13 PageID 428 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION MICK HAIG PRODUCTIONS, e.K., § § Plaintiff, § § VS. § C.A. NO.: 3:10-CV-1900-N § DOES 1-670, § § Defendants. § MOTION TO STAY THE IMPOSITION OF SANCTIONS PENDING APPEAL AND BRIEF IN SUPPORT TO THE HONORABLE JUDGE OF SAID COURT: Evan Stone, Counsel for Plaintiff, hereby files this Motion to Stay the Imposition of Sanctions Pending Appeal and Brief in Support, and states as follows: I. INTRODUCTION Counsel, acting pro se , and only on his own behalf, moves this Court to stay the imposition of sanctions pending an appeal of this Court’s Order. If Counsel is required to file a copy of said order in every currently-ongoing proceeding in which he represents a party, it will result in irreparable harm, both to Counsel and his clients. Even if the subject matter of litigation is similar between two cases, there is no reason why Counsel’s error in one case should poison the well in any other. Stone remains responsible for any unethical conduct independent of the Order, and if another court believes Stone has acted improperly, it may impose sanctions independently. Therefore, the only likely effect of Case 3:10-cv-01900-N Document 23 Filed 10/26/11 Page 2 of 13 PageID 429 the req