JORDAN, LYNCH & CANCIENNE PLLC

Michael Cancienne (SBN 24055256)

Joseph W. Golinkin II (SBN 24087596)

Brittainie J. Zinsmeyer (SBN 24115981)

1980 Post Oak Blvd., Ste. 2300

Houston, Texas 77056

Telephone: 713.955.4025

Counsel for 18920 N 11th LLC,

Steven Zakharyayev,

and Evelina Pinkhasova

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

SCOTT M. SEIDEL, TRUSTEE; and 

GNET ATC, LLC

Plaintiffs,

v.

18920 NW 11th, LLC; JAMES 

GOODMAN; JAMES FRINZI; STEVEN 

ZAKHARYAYEV; EVELINA 

PINKHASOVA; PEOPLE NQ INC.; JJC 

& PEOPLE LLC; GDMN FAMILY 

INVESTMENTS 2, LLC,

Defendants.

Case No. 22-31641-mvl-7

Adversary Proceeding No. 

23-03072-mvl

DEFENDANT EVELINA PINKHASOVA’S FIRST AMENDED OBJECTIONS AND 

RESPONSES TO TRUSTEE’S FIRST SET OF INTERROGATORIES

To: Trustee, Scott M. Seidel, by and through his attorneys of record, Davor Rukavina, Esq., 

Thomas D. Berghman, Esq., Julian P. Vasek, Esq., and Conor P. White, Esp., Munsch 

Hardt Kopf & Harr, P.C., 500 N. Akard Street, Suite 4000, Dallas, Texas 75201.

Evelina Pinkhasova, Defendant in this Adversary Proceeding, hereby serves upon 

Scott M. Seidel (“Trustee”), Plaintiff in this Adversary Proceeding, Defendant Evelina 

Pinkhasova’s First Amended Objections and Responses to Trustee’s First Set of Interrogatories

pursuant to Rule 33 of the Federal Rules of Civil Procedure as follows.

Trustee's

Exhibit 11

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Exhibit 11 Page 1 of 8
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OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS

1. Pinkhasova objects to the instructions and requests to the extent references to 

Pinkhasova or any other party or entity include that entity’s employees, officers, directors, agents, 

representatives, members, attorneys, departments, sections, affiliates, subsidiaries, parents, and all 

other persons acting on its behalf. To the extent a request references a particular entity, Pinkhasova 

intends to respond based solely on the entity itself, and not the laundry list of other agents, 

representatives, or other related entities listed.

2. Pinkhasova objects to the definition of the term “Document(s)” to the extent it 

exceeds the ordinary use of the term and that which is contemplated by Federal Rule of Civil 

Procedure 34 and in that it is overbroad as defined. Pinkhasova will therefore respond to these 

requests which reference or seek “Document(s)” in accordance with the ordinary use of the term 

and the Federal Rules of Civil Procedure.

3. Pinkhasova objects to the definition of “18920” to the extent it includes its present 

and former parents, subsidiaries, affiliates, agents, employees, representatives, assigns, attorneys, 

predecessors-in-interest, or all others acting on its behalf. Pinkhasova will respond to requests 

referencing “18920” as only the entity 18920 NW 11th, LLC.

4. Pinkhasova objects to the definition of “GDMN” to the extent it includes its present 

and former parents, subsidiaries, affiliates, agents, employees, representatives, assigns, attorneys, 

predecessors-in-interest, or all others acting on its behalf. Pinkhasova will respond to requests 

referencing “GDMN” as only the entity “GDMN Family Investments 2, LLC.”

5. Pinkhasova objects to the definition of “GDMN” to the extent it includes its present 

and former parents, subsidiaries, affiliates, agents, employees, representatives, assigns, attorneys, 

predecessors-in-interest, or all others acting on its behalf. Pinkhasova will respond to requests 

referencing “GDMN” as only the entity “GDMN ATC, LLC.”

6. Pinkhasova objects to the definition for “You” and “Your” as it includes responses 

on behalf of Pinkhasova’ s agents, representatives, assigns, attorneys, or others acting on her 

behalf. Pinkhasova will respond to requests referencing “You” or “Your” as referencing only 

herself.

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Exhibit 11 Page 2 of 8
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INTERROGATORIES

INTERROGATORY NO. 1. Who drafted or prepared the Redemption Notice? Your 

answer should include all people who drafted the Redemption Notice. 

RESPONSE: Pinkhasova objects that this request seeks information that is more properly 

sought through 18920. Subject to the foregoing, Steven Zakharyayev drafted the Redemption 

Notice.

INTERROGATORY NO. 2. Did You transmit the Redemption Notice to the Debtor and, 

if so, how, when, and to whom?

RESPONSE: Pinkhasova objects that this request seeks information that is more properly 

sought through 18920. Subject to the foregoing, no. The Redemption Notice was sent by 

Steven Zakharyayev, on my behalf as signatory for 18920.

INTERROGATORY NO. 3. At the time of the Redemption Notice, who did You 

understand Frinzi to be with respect to the Debtor and GNET, including whether You 

understood him to be a director, officer, or manager of the Debtor and GNET?

RESPONSE: Pinkhasova objects that this request seeks information that is more properly 

sought through 18920. Subject to the foregoing, see documents produced by 18920 showing 

Frinzi representing himself as a member an officer of Debtor and GNET.

INTERROGATORY NO. 4. Explain What did You mean in the Redemption Notice by 

"[a]s you know ... " In other words, why did You believe that the Debtor knew that 18920 

owned the Transaction Shares and why did You believe that the person You transmitted the 

Redemption Notice to would know that, in that the Redemption Notice is addressed to "whom 

it may concern."

RESPONSE: Pinkhasova objects that this request assumes facts, namely that she drafted the 

Redemption Notice. Pinkhasova objects that this request seeks information that is more 

properly sought through 18920. 

INTERROGATORY NO. 5. At the time of the Redemption Notice, what was the factual 

basis for the statement in the Redemption Notice that "l8920 NW 11th LLC, (the 

"Shareholder") is owner of 4.032,918 Series A-1 Preferred Shares" as of the date of the 

Redemption Notice? Your answer should address whether, by that date, 18920 had paid for the 

Transaction Shares, whether You believed that it needed to pay for the same in order to then 

own the same, why You may have believed that it need not have paid for the same in order to 

then own the same, and whether any steps had then been taken for 18920 to take any action to 

evidence its ownership of the Transaction Shares and what any such action would have been 

and whether and when it was taken.

RESPONSE: Pinkhasova objects to this request to the extent it seeks information protected 

from disclosure by the attorney client or work product doctrine. Pinkhasova also objects that 

this information is more properly sought through 18920. See 18920 Obj. & Resp. to Trustee’s 

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1st Interrog. at Interrog. No. 8. Pinkhasova is personally unaware of the factual basis for the 

statements in the Redemption Notice which were drafted by other parties. 

INTERROGATORY NO. 6. At the time of the Redemption Notice, how did You believe 

or understand that 18920 paid, or would pay, for the Transaction Shares, and when it would do 

so or when it had done so?

RESPONSE: Pinkhasova objects to this request to the extent it seeks information protected 

from disclosure by the attorney client or work product doctrine. Subject to the foregoing, see 

Zakharyayev’s Resp. to Trustee’s 1st Interrog. at Interrog. No. 11. Pinkhasova does not have 

any personal knowledge as to the mechanics of the Redemption Notice and relied on other 

parties for the drafting and contents of the Redemption Notice. 

INTERROGATORY NO. 7. At the time of the Redemption Notice, what was the factual 

basis for the statement in the Redemption Notice that the "Preferred Shares are subject to 

mandatory redemptions at their liquidation value on a quarterly basis?"

RESPONSE: Pinkhasova objects to this request to the extent it seeks information protected 

from disclosure by the attorney client or work product doctrine. Pinkhasova also objects that 

this information is more properly sought through 18920. See 18920 Obj. & Resp. to Trustee’s 

1st Interrog. at Interrog. No. 9. Pinkhasova does not have any personal knowledge as to the 

mechanics of the Redemption Notice and relied on other parties for the drafting and contents 

of the Redemption Notice.

INTERROGATORY NO. 8. Explain what steps You took, including any due diligence 

You undertook, to state in the Redemption Notice that the "Preferred Shares are subject to 

mandatory redemptions at their liquidation value on a quarterly basis," including by identifying 

any documents You reviewed or relied on to state the same, and including any communications 

You reviewed. made. had, were given, or You relied on, to state the same. Identify any such 

documents or communications in Your production to the Trustee's Requests for Production 

served concurrently herewith.

RESPONSE: Pinkhasova objects to this request to the extent it seeks information protected 

from disclosure based on attorney client or work product privileges. Pinkhasova objects to this 

request as overbroad. Pinkhasova further objects that this information is more properly sought 

from 18920. See 18920 Obj. & Resp. to Trustee’s 1st Interrog. at Interrog. Nos. 9, 10.

Pinkhasova took no steps but instead relied on other parties regarding diligence for the 

transactions. 

INTERROGATORY NO. 9. At the time of the Redemption Notice, did You believe or 

understand that the "Preferred Shares are subject to mandatory redemptions at their liquidation 

value on a quarterly basis," as stated therein, and, if You so believed, why did You so believe?

RESPONSE: Pinkhasova objects to this request to the extent it seeks information protected 

from disclosure based on attorney client or work product privileges. Pinkhasova objects to this 

request as overbroad. Pinkhasova further objects that this information is more properly sought 

from 18920. See 18920 Obj. & Resp. to Trustee’s 1st Interrog. at Interrog. Nos. 9, 10. 

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Pinkhasova did not have any belief or understanding regarding the obligations related to the 

rights of redemption but instead relied on the advice and counsel of other parties. 

INTERROGATORY NO. 10. Why did You transmit the Redemption Notice to the Debtor?

RESPONSE: Pinkhasova also objects that this information is more properly sought through 

18920. See also Response to Interrogatory No. 2 above. Subject to the foregoing, 18920 

owned the preferred shares and had mandatory redemption rights.

INTERROGATORY NO. 11. At the time of the Redemption Notice, what did You believe 

or understand was the "liquidation value [ of the Preferred Shares] on a quarterly basis" as 

stated in the Redemption Notice?

RESPONSE: Pinkhasova objects to this request to the extent it seeks information protected 

from disclosure based on attorney client or work product privileges. Pinkhasova further 

objects that this information is more properly sought from 18920. See Steven Zakharyayev’s

February 10, 2023 deposition testimony, given as 18920’s corporate representative, at 34:4–

16, 37:16–38:5. Pinkhasova did not have any personal belief or understanding regarding the 

obligations related to the rights of redemption but instead relied on the advice and counsel of 

other parties.

INTERROGATORY NO. 12. What was the factual basis for any belief or understanding of 

Yours as answered in response to Interrogatory No. 11.

RESPONSE: Pinkhasova objects to this request to the extent it seeks information protected 

from disclosure based on attorney client or work product privileges. Pinkhasova further 

objects that this information is more properly sought from 18920. See Steven Zakharyayev’s

February 10, 2023 deposition testimony, given as 18920’s corporate representative, at 34:4–

16, 37:16–38:5. As indicated in response to Interrogatory No. 11, Pinkhasova did not have any 

personal belief or understanding regarding the obligations related to the rights of redemption 

but instead relied on the advice and counsel of other parties.

INTERROGATORY NO. 13. At the time of the Redemption Notice, did you believe or 

understand that the Debtor had the funds necessary to pay the “mandatory redemptions” as 

stated in the Redemption Notice?

RESPONSE: Pinkhasova objects to this request to the extent it seeks information protected 

from disclosure by the attorney client or work product doctrine. Pinkhasova also objects that 

this information is better obtained through 18920. See 18920 Obj. & Resp. to Trustee’s 1st 

Interrog. at Interrog. No. 9. Pinkhasova did not have any personal belief or understanding 

regarding the Debtor’s financial situation. 

INTERROGATORY NO. 14. If Your answer to Interrogatory No. 13 is "yes' in whole or 

in part, then explain the factual basis of Your belief or understanding. If Your answer to 

Interrogatory No. 13 is "no" in whole or in part, then explain what belief or understanding You 

had as to how the Debtor would pay or satisfy the "mandatory redemption.'"

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RESPONSE: Pinkhasova objects to this request to the extent it seeks information protected 

from disclosure by the attorney client or work product doctrine. Pinkhasova also objects that 

this information is better obtained through 18920. See 18920 Obj. & Resp. to Trustee’s 1st 

Interrog. at Interrog. No. 9. Pinkhasova did not have any personal belief or understanding 

regarding the Debtor’s financial situation.

INTERROGATORY NO. 15. At the time of the Redemption Notice, did You have a belief 

or understanding as to the Debtor's solvency and, if so, state the factual basis for any such 

belief or understanding. As used herein. "solvency" means both that the assets of the Debtor 

exceeded its liabilities, including any debt payable on the Redemption Notice, and that the 

Debtor was paying its debts as they became due, including any debt payable on the Redemption 

Notice.

RESPONSE: Pinkhasova objects to this request to the extent it seeks information protected 

from disclosure based on attorney client or work product privileges. Pinkhasova further 

objects that this information is more properly sought from 18920. See Steven Zakharyayev’s

February 10, 2023 deposition testimony, given as 18920’s corporate representative, at 71:4–

16. Pinkhasova did not have any personal belief or understanding regarding the Debtor’s 

solvency.

INTERROGATORY NO. 16. Did the Debtor ever sign and deliver to 18920 the 

Promissory Note?

RESPONSE: Pinkhasova objects that this information is better obtained through 18920. See 

18920 Obj. & Resp. to Trustee’s 1st Interrog. at Interrog. No. 17. Pinkhasova believes the 

Promissory Note was signed and delivered. 

INTERROGATORY NO. 17. As of the date of the Settlement Agreement, what value did 

You believe or understand that 18920 gave to the Debtor for the Settlement Agreement, or 

what the "value received"' stated in the Promissory Note or "good and valuable consideration" 

stated in the Settlement Agreement was?

RESPONSE: Pinkhasova objects to this request to the extent it seeks information protected 

from disclosure based on attorney client or work product privileges. Pinkhasova further 

objects that this information is more properly sought from 18920. Because this Interrogatory

requests information from 18920 and not Pinkhasova, see 18920 Obj. & Resp. to Trustee’s 1st 

Interrog. at Interrog. No. 15. Pinkhasova has no additional information other than what was 

provided by 18920 in response to the same or similar Interrogatories.

INTERROGATORY NO. 18. As of the date of the Settlement Agreement, state the factual 

basis for Your belief or understanding in answer to Interrogatory No. 17.

RESPONSE: Pinkhasova objects that this request is vague and lacks specificity as to the 

information sought. Pinkhasova further objects that this information is more properly sought 

from 18920. See 18920 Obj. & Resp. to Trustee’s 1st Interrog. at Interrog. No. 15.

INTERROGATORY NO. 19. Who negotiated the Settlement Agreement on behalf of 

18920, and who was it negotiated with on behalf of the Debtor?

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RESPONSE: Pinkhasova objects that this information is more properly sought from 18920. 

Subject to the foregoing, Zakharyayev negotiated the Settlement Agreement on behalf of 

18920 with Goodman Networks, Inc. representatives Goodman and Frinzi, as well as counsel 

for Debtor.

INTERROGATORY NO. 20. As of when you sent the Redemption Notice, did you intend 

or, to your knowledge, did 18920 intend, to enter into the Promissory Note and the Settlement 

Agreement in whole or in partial satisfaction of the Redemption Notice?

RESPONSE: Pinkhasova objects that this request assumes facts, namely that Pinkhasova

specifically sent the Redemption Notice. Pinkhasova objects that this information is more 

properly sought from 18920. Pinkhasova further objects to this request to the extent the 

documents speak for themselves. Subject to the foregoing, Pinkhasova refers the trustee to the 

Corporate Representative deposition given by Steven Zakharyayev on February 10, 2023. 

Pinkhasova does not have any personal knowledge regarding the intentions of 18920 or the 

mechanics of the Redemption Notice, and relied on other parties for the drafting and contents 

of the Redemption Notice.

INTERROGATORY NO. 21. Identify each and every professional or advisor, including 

each attorney, accountant, or financial advisor, involved in negotiating, drafting, or executing 

any of the agreements: by which 18920 purchased the Transaction Shares; the Redemption 

Notice, the Promissory Note; or the Settlement Agreement.

RESPONSE: Pinkhasova objects that this information is more properly sought from 18920. 

Subject to the foregoing, Pinkhasova is only aware of Steven Zakharyayev providing legal 

services to 18920 as part of these transactions. 

INTERROGATORY NO. 22. Why did You think, at the time of the Redemption Notice, 

that the holders of the Transaction Shares simply did not demand the redemption thereof as 

such redemption is referenced in the Redemption Notice, as opposed to transferring the same 

to 18920 and then 18290 demanding the redemption thereof? Your answer should include any 

information regarding this question You may have received from any other person and the 

identify of any such person.

RESPONSE: Pinkhasova objects that this request calls for speculation. Pinkhasova further 

objects that this information is more properly sought from 18920. See 18920 Obj. & Resp. to 

Trustee’s 1st Interrog. at Interrog. No. 21.

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Exhibit 11 Page 7 of 8
Dated this 19th day of July, 2024.

JORDAN, LYNCH & CANCIENNE PLLC

By: s/ Michael Cancienne

Michael Cancienne

State Bar No. 24046330

Joseph (“Jeb”) W. Golinkin II

State Bar No. 24087596

Brittainie Zinsmeyer

State Bar No. 24115981

1980 Post Oak Blvd., Ste. 2300

Houston, Texas 77056

713-955-4020 (Telephone)

713-955-9644 (Fax)

mcancienne@jlcfirm.com

jgolinkin@jlcfirm.com

bzinsmeyer@jlcfirm.com

ATTORNEYS FOR 18920 NW 11th LLC, 

STEVEN ZAKHARYAYEV, AND EVELINA 

PINKASHOVA

CERTIFICATE OF SERVICE

I hereby certify that on this 19

th day of July, 2024, I electronically served the 

foregoing to counsel of record.

/s/ Brittainie Zinsmeyer

Brittainie Zinsmeyer

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