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 NW 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 18920 N 11TH, LLC’S FIRST AMENDED OBJECTIONS AND 

RESPONSES TO TRUSTEE’S FIRST SET OF REQUESTS FOR PRODUCTION 

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.

18920 NW 11th, LLC (“18920”), Defendant in this Adversary Proceeding, hereby 

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

18920 NW 11th, LLC’s First Amended Objections and Responses to Trustee’s First Set of Requests 

Trustee's

Exhibit 1

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Exhibit 1 Page 1 of 14
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for Production (the “Requests”) pursuant to Rule 34 of the Federal Rules of Civil Procedure as 

follows.

OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS

1. 18920 objects to the instructions and requests to the extent they require 18920 to 

produce documents outside his possession, custody, or control, and go beyond the requirements 

provided for by Federal Rule of Civil Procedure 34. See Harper v. City of Dall., Tex., No. 3:14-

CV-2647-M, 2017 WL 3674830, at *17 (N.D. Tex. Aug. 25, 2017) (discussing the scope of Rule 

34’s definition of “possession, custody, or control”). 18920 will produce documents in his 

possession, custody, or control, as contemplated by the Federal Rules of Civil Procedure. 

2. 18920 objects to the instructions and requests to the extent references to 18920 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, 18920 intends to respond 

based solely on the entity itself, and not the laundry list of other agents, representatives, or other 

related entities listed.

3. 18920 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. 18920 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.

4. 18920 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. 18920 will respond to requests 

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

5. 18920 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. 18920 will respond to requests 

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

6. 18920 objects to the definition for “You” and “Your” as it includes responses on 

behalf of its present and former parents, subsidiaries, affiliates, agents, employees, representatives, 

assigns, attorneys, predecessor-in-interest, and all other persons or entities acting on its behalf. 

18920 will respond to requests referencing “You” or “Your” as referencing only 18920. 

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REQUEST FOR PRODUCTION

REQUEST FOR PRODUCTION NO. 1. Any and all bank statements for any bank 

accounts held in Your name or for Your benefit since January 1, 2021 through the present.

RESPONSE: 18920 objects to this request as overbroad as it seeks documents from a 

timeframe prior to any alleged misconduct in this case and is harassing because the documents 

requested may contain commercial business information. 18920 also objects to this request to 

the extent it seeks documents not relevant nor reasonably calculated to lead to the discovery of 

admissible evidence. 

REQUEST FOR PRODUCTION NO. 2. Each of your corporate governance 

documents, including limited liability agreement, bylaws, agreements of members, resolutions, 

member consents, or any other document that governs You as an artificial entity, including any 

amendment or supplement thereof.

RESPONSE: 18920 will produce responsive documents, if any, located after a reasonable 

search. 

REQUEST FOR PRODUCTION NO. 3. Each of your Financial Documents for any 

period of time beginning January 1, 2021.

RESPONSE: 18920 objects to this request as overbroad as it seeks documents from a 

timeframe prior to any alleged misconduct in this case and is harassing because the documents 

requested may contain commercial business information. 18920 also objects to this request to 

the extent it seeks documents not relevant nor reasonably calculated to lead to the discovery of 

admissible evidence. 

REQUEST FOR PRODUCTION NO. 4. Each tax return filed by You at any time since 

January 1, 2021 with any taxing authority, including any Kl, K2. or W2 issued by You.

RESPONSE: 18920 objects to this request as overbroad as it seeks documents from a 

timeframe prior to any alleged misconduct in this case. 18920 also objects to this request to 

the extent it seeks documents not relevant nor reasonably calculated to lead to the discovery of 

admissible evidence. 

REQUEST FOR PRODUCTION NO. 5. Each of the Purchase Agreements, and any 

drafts thereof or amendments thereto.

RESPONSE: 18920 has produced responsive documents located after a reasonable search.

REQUEST FOR PRODUCTION NO. 6. All Communications and Documents related 

to. referring to, or referencing any negotiations of, or drafting of, or execution of, or 

performance under, the Purchase Agreements, including the quantities of shares or stock 

acquired thereunder and the price(s) paid thereunder.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

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

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18920 will produce responsive documents. 18920 is not producing privileged, responsive 

documents or communications involving undersigned counsel. 

REQUEST FOR PRODUCTION NO. 7. The Redemption Notice, and any drafts 

thereof or amendments thereto.

RESPONSE: 18920 has produced responsive documents located after a reasonable search.

REQUEST FOR PRODUCTION NO. 8. All Communications and Documents related 

to, referring to, or referencing any negotiations of, or drafting of, or execution of, or 

performance under, the Redemption Notice.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

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

18920 has produced responsive documents located after a reasonable search. 18920’s 

investigation into responsive documents is still ongoing and it will supplement in accordance 

with Federal Rules of Civil Procedure. 18920 is not producing privileged, responsive 

documents or communications involving undersigned counsel. 

REQUEST FOR PRODUCTION NO. 9. The Promissory Note, and any drafts thereof 

or amendments thereto.

RESPONSE: 18920 has produced responsive documents located after a reasonable search.

18920’s investigation into responsive documents is still ongoing and it will supplement in 

accordance with Federal Rules of Civil Procedure.

REQUEST FOR PRODUCTION NO. 10. All Communications and Documents related 

to referring to, or referencing any negotiations of, or drafting of, or execution of. or 

performance under, the Promissory Note.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, common interest, joint defense, or work product 

privileges. Subject to the foregoing, 18920 will produce responsive documents, if any, located 

after a reasonable search. 18920’s investigation into responsive documents is still ongoing and 

it will supplement in accordance with Federal Rules of Civil Procedure. 18920 is not 

producing privileged, responsive documents or communications involving undersigned 

counsel. 

REQUEST FOR PRODUCTION NO. 11. The Settlement Agreement, and any drafts 

thereof or amendments thereto.

RESPONSE: 18920 has produced responsive documents located after a reasonable search.

REQUEST FOR PRODUCTION NO. 12. All Communications and Documents related 

to, referring to, or referencing any negotiations of. or drafting of, or execution of, or 

performance under, the Settlement Agreement.

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RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, common interest, joint defense, or work product 

privileges. Subject to the foregoing, 18920 has produced responsive documents located after 

a reasonable search. 18920’s investigation into responsive documents is still ongoing and it 

will supplement in accordance with Federal Rules of Civil Procedure. 18920 is not producing 

privileged, responsive documents or communications involving undersigned counsel. 

REQUEST FOR PRODUCTION NO. 13. All Communications and Documents related 

to, referring to, or referencing any payment or transfer by You for the Transaction Shares or 

pursuant to the Purchase Agreements, including any such payment or transfer to Goodman, 

JJC, GDMN, and People, or to any other person for or on behalf of any of the foregoing.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, common interest, joint defense, or work product 

privileges. Subject to the foregoing, 18920 has produced responsive documents located after 

a reasonable search. 18920’s investigation into responsive documents is still ongoing and it 

will supplement in accordance with Federal Rules of Civil Procedure. 18920 is not producing 

privileged, responsive documents or communications involving undersigned counsel. 

REQUEST FOR PRODUCTION NO. 14. Any Document that You contend or assert 

provided for the redemption of the Transaction Shares the subject of the Redemption Notice 

as of March, 2022.

RESPONSE: 18920 has produced responsive documents located after a reasonable search.

REQUEST FOR PRODUCTION NO. 15. All Communications and Documents related 

to any due diligence undertaken by you or by any person on your behalf related to the Purchase 

Agreements, the Redemption Notice, or Your acquisition of stock or shares of the Debtor, 

including: (i) all such Communications and Documents provided to you by the Debtor. Frinzi, 

or Goodman; (ii) all such Communications and Documents created internally by your or 

created for you; and (iii) all such Communications and Documents relied on by You in deciding 

to enter into the Purchase Agreements or sending the Redemption Notice.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

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

18920 has produced responsive documents located after a reasonable search. 18920’s 

investigation into responsive documents is still ongoing and it will supplement in accordance 

with Federal Rules of Civil Procedure. 18920 is not producing privileged, responsive 

documents or communications involving undersigned counsel. 

REQUEST FOR PRODUCTION NO. 16. All Communications and Documents related 

to or evidencing the transfer of any stock or shares of the Debtor to You or to any other person 

at Your direction or assignment. including the Transaction Shares.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, common interest, joint defense, or work product 

privileges. Subject to the foregoing, 18920 has produced responsive documents located after 

a reasonable search. 18920’s investigation into responsive documents is still ongoing and it 

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will supplement in accordance with Federal Rules of Civil Procedure. 18920 is not producing 

privileged, responsive documents or communications involving undersigned counsel. 

REQUEST FOR PRODUCTION NO. 17. All Documents and Communications 

between You and the Debtor at any time related to, referencing, or referring to the Debtor. 

GNET. the Transaction Shares, the Purchase Agreements, the Redemption Notice, the 

Promissory Note, the Settlement Agreement, any Transfer pursuant to any of the foregoing, or 

any performance or lack thereof of any party under any of the foregoing.

RESPONSE: 18920 has produced responsive documents located after a reasonable search. 

18920’s investigation into responsive documents is still ongoing and it will supplement in 

accordance with Federal Rules of Civil Procedure.

REQUEST FOR PRODUCTION NO. 18. All Documents and Communications 

between You and Frinzi at any time related to, referencing, or referring to the Debtor, GNET, 

the Transaction Shares, the Purchase Agreements, the Redemption Notice, the Promissory 

Note, the Settlement Agreement, any Transfer pursuant to any of the foregoing, or any 

performance or lack thereof of any party under any of the foregoing.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, common interest, joint defense, or work product 

privileges. Subject to the foregoing, 18920 has produced responsive documents located after 

a reasonable search. 18920’s investigation into responsive documents is still ongoing and it 

will supplement in accordance with Federal Rules of Civil Procedure.

REQUEST FOR PRODUCTION NO. 19. All Documents and Communications 

between You and GNET at any time related to, referencing, or referring to the Debtor, GNET, 

the Transaction Shares, the Purchase Agreements, the Redemption Notice, the Promissory 

Note, the Settlement Agreement, any Transfer pursuant to any of the foregoing, or any 

performance or lack thereof of any party under any of the foregoing.

RESPONSE: 18920 has produced responsive documents, if any, located after a reasonable 

search. 18920’s investigation into responsive documents is still ongoing and it will supplement 

in accordance with Federal Rules of Civil Procedure.

REQUEST FOR PRODUCTION NO. 20. All Documents and Communications 

between You and Goodman at any time related to, referencing, or referring to the Debtor, 

GNET, the Transaction Shares, the Purchase Agreements, the Redemption Notice, the 

Promissory Note, the Settlement Agreement, any Transfer pursuant to any of the foregoing, or 

any performance or lack thereof of any party under any of the foregoing.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, common interest, joint defense, or work product 

privileges. Subject to the foregoing, 18920 has produced responsive documents located after 

a reasonable search. 18920’s investigation into responsive documents is still ongoing and it 

will supplement in accordance with Federal Rules of Civil Procedure. 18920 will not produce 

privileged, responsive documents involving undersigned counsel.

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REQUEST FOR PRODUCTION NO. 21. All Documents and Communications 

between You and GDMN, JJC. or People at any time related to. referencing, or referring to the 

Debtor, GNET, the Transaction Shares, the Purchase Agreements, the Redemption Notice, the 

Promissory Note, the Settlement Agreement, any Transfer pursuant to any of the foregoing, or 

any performance or lack thereof of any party under any of the foregoing.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, common interest, joint defense, or work product 

privileges. Subject to the foregoing, 18920 has produced responsive documents located after 

a reasonable search. 18920’s investigation into responsive documents is still ongoing and it 

will supplement in accordance with Federal Rules of Civil Procedure. 18920 will not produce 

privileged, responsive documents involving undersigned counsel.

REQUEST FOR PRODUCTION NO. 22. All Documents and Communications 

between You and any person not identified in Requests 17 through 21 above at any time related 

to, referencing, or referring to the Debtor, GNET, the Transaction Shares, the Purchase 

Agreements, the Redemption Notice, the Promissory Note, the Settlement Agreement, any 

Transfer pursuant to any of the foregoing, or any performance or lack thereof of any party 

under any of the foregoing, including Shalom Auerbach, Neil Auerbach, or John Goodman. 

You may exclude from this Request, without privilege log. any Documents and 

Communications after the date of the filing of this Adversary Proceeding and all mediation 

Documents and Communications.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. 18920 also objects to this request as overbroad in that it does not specify an 

applicable timeframe, instead including “any time” and to the extent it is duplicative of Request 

for Production No. 20. Subject to the foregoing, 18920 has produced responsive documents, if 

any, located after a reasonable search. 18920’s investigation into responsive documents is still 

ongoing and it will supplement in accordance with Federal Rules of Civil Procedure. 18920 

will not produce privileged, responsive documents involving undersigned counsel.

REQUEST FOR PRODUCTION NO. 23. All Documents and Communications relating 

to, referring to, or evidencing any Transfer by You of any property to Zakharyayev since 

January 1, 2021, including by way of loan, dividend, distribution, or reimbursement.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. 18920 also objects to this request as overbroad in that it seeks documents and 

communications from outside the timeframe of the alleged misconduct and does not specify 

an applicable subject matter. 18920 also objects that this request seeks document that are not 

relevant nor reasonably calculated to lead to the discovery of admissible evidence.

REQUEST FOR PRODUCTION NO. 24. All Documents and Communications relating 

to, referring to, or evidencing any Transfer by You of any property to Pinkhasova since January 

1, 2021, including by way of loan, dividend, distribution, or reimbursement.

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RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. 18920 also objects to this request as overbroad in that it seeks documents and 

communications from outside the timeframe of the alleged misconduct and does not specify 

an applicable subject matter. 18920 also objects that this request seeks document that are not 

relevant nor reasonably calculated to lead to the discovery of admissible evidence.

REQUEST FOR PRODUCTION NO. 25. All Documents and Communications relating 

to, referring to, or evidencing any Transfer or investment You made from any of the funds 

received from the Debtor or GNET, including pursuant to the Settlement Agreement, including 

any such Transfer to Goodman, GDMN, JJC, or People, and including any assets You 

purchased, investments you acquired, or transfers to any person for any reason You made from 

such funds.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. 18920 also objects that this request seeks documents that are not relevant nor 

reasonably calculated to lead to the discovery of admissible evidence.

REQUEST FOR PRODUCTION NO. 26. All Documents and Communications relating 

to or between You and any entity owned by, controlled by, or affiliated with Frinzi, or of which 

James Frinzi was an affiliate or insider, including but not limited to Multiband Global 

Resources, LLC, American Metals Recovery and Recycling, Inc. n/k/a MBG Holdings. Inc .. 

and World Conquest, LLC, including any Transfers or payments made to You by any of the 

same or made by You to any of the same.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. 18920 also objects to this request as overbroad as it does not provide a relevant 

time frame or applicable subject matter for the documents and communications sought, and 

lacking in specificity as to the documents requested. Subject to the foregoing, 18920 has 

produced responsive documents, if any, located after a reasonable search. 18920’s 

investigation into responsive documents is still ongoing and it will supplement in accordance 

with Federal Rules of Civil Procedure. 18920 will not produce privileged, responsive 

documents involving undersigned counsel.

REQUEST FOR PRODUCTION NO. 27. All Documents and Communications relating 

to, referring to, or evidencing any transfer or payment made to You or to anyone else for You 

or on Your behalf under or pursuant to the "Licensing Agreement" referenced in the Settlement 

Agreement.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. 18920 also objects that this request seeks document that are not relevant nor 

reasonably calculated to lead to the discovery of admissible evidence. 18920 will produce 

responsive documents, if any, located after a reasonable search. 

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REQUEST FOR PRODUCTION NO. 28. All Documents and Communications relating 

to, referring to, or evidencing any assignment, further assignment, extension, amendment, 

supplement, renewal, or termination of “Licensing Agreement” referenced in the Settlement 

Agreement.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. Subject to the foregoing, 18920 will produce responsive documents, if any, located 

after a reasonable search. 18920’s investigation into responsive documents is still ongoing and 

it will supplement in accordance with Federal Rules of Civil Procedure. 18920 will not 

produce privileged, responsive documents involving undersigned counsel.

REQUEST FOR PRODUCTION NO. 29. All Documents and Communications relating 

to, referring to, or evidencing any asset, equipment, or property, whether tangible or intangible, 

related to the "Licensing Agreement" referenced in the Settlement Agreement transferred or 

assigned to You with said Licensing Agreement. including cell towers and network equipment, 

and related to any disposition or present status of any such asset, equipment, or property.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. 18920 also objects to this request as vague in the use of the term “and related to 

any disposition or present status” and because it is a compound request. 18920 also seeks 

documents that are not relevant or reasonably calculated to lead to the discovery of admissible 

evidence. Subject to the foregoing, 18920 will produce responsive documents, if any, located 

after a reasonable search. 18920’s investigation into responsive documents is still ongoing and 

it will supplement in accordance with Federal Rules of Civil Procedure. 18920 will not 

produce privileged, responsive documents involving undersigned counsel.

REQUEST FOR PRODUCTION NO. 30. All Documents and Communications 

evidencing or relating to a potential Transfer of a $4.500,000 note payable, for the benefit of 

Multi band Field Services, Inc. by Multiband Global Resources, LLC, to You, including any 

Transfers made in satisfaction of the same, and including any Transfers or payments made to 

You pursuant to the same.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. 18920 also objects to this request as vague and lacking in specificity. Subject to 

the foregoing, 18920 has produced responsive documents located after a reasonable search. 

18920’s investigation into responsive documents is still ongoing and it will supplement in 

accordance with Federal Rules of Civil Procedure. 18920 will not produce privileged, 

responsive documents involving undersigned counsel.

REQUEST FOR PRODUCTION NO. 31. All Documents and Communications relating 

to a revision of the Purchase Agreements executed on June 8, 2022.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

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privileges. Subject to the foregoing, 18920 will produce responsive documents, if any, located 

after a reasonable search. 18920’s investigation into responsive documents is still ongoing and 

it will supplement in accordance with Federal Rules of Civil Procedure. 18920 will not 

produce privileged, responsive documents involving undersigned counsel.

REQUEST FOR PRODUCTION NO. 32. All insurance policies held in Your name 

which You were a payee or loss payee since January 1, 2021, including any director’s and 

officer’s coverage.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. 18920 also objects to this request as overbroad as it seeks insurance policies from 

outside the applicable timeframe of the alleged misconduct and relating to subject matter that 

is not at issue, and that it seeks documents that are not relevant nor reasonably anticipated to 

lead to the discovery of admissible evidence. 18920 also objects to this request as it duplicates 

and exceeds the required disclosure of insuring agreements under Federal Rule of Civil 

Procedure 26. 18920 will produce documents sufficient to meet its obligations under the 

Federal Rules of Civil Procedure. 

REQUEST FOR PRODUCTION NO. 33. All Documents and Communications related 

to, referring to, or asserted by You to evidence, any value or return consideration You gave to 

the Debtor in exchange for the Promissory Note, the Settlement Agreement, and all payments 

and transfers under the Settlement Agreement.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. Subject to the foregoing, 18920 has produced responsive documents located after 

a reasonable search. 18920’s investigation into responsive documents is still ongoing and it 

will supplement in accordance with Federal Rules of Civil Procedure. 18920 will not produce 

privileged, responsive documents involving undersigned counsel.

REQUEST FOR PRODUCTION NO. 34. All Documents and Communications related 

to, referring to, or asserted by You to evidence, any value or return consideration You gave to 

GNET in exchange for the Promissory Note, the Settlement Agreement. and all payments and 

transfers under the Settlement Agreement.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. Subject to the foregoing, 18920 has produced responsive documents located after 

a reasonable search. 18920’s investigation into responsive documents is still ongoing and it 

will supplement in accordance with Federal Rules of Civil Procedure. 18920 will not produce 

privileged, responsive documents involving undersigned counsel.

REQUEST FOR PRODUCTION NO. 35. All documents related to Your answer to 

Interrogatory No. 3 served concurrently herewith.

RESPONSE: 18920 objects to this request as vague and lacking in specificity as to the 

documents requested. 18920 also objects to this request as overbroad (see 18920 Am. Obj. & 

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Resp. to Interog. No. 3), and that it seeks documents that are not relevant or reasonably 

calculated to lead to the discovery of admissible evidence. Subject to the foregoing, none. 

REQUEST FOR PRODUCTION NO. 36. All Documents related to Your answer to 

Interrogatory No. 5 served concurrently herewith.

RESPONSE: 18920 objects to this request as vague in that it only references other discovery 

requests and is lacking in specificity as to the documents requested. Subject to the foregoing, 

18920 has produced responsive documents relating to the transaction shares that were located 

after a reasonable search. 18920’s investigation into responsive documents is still ongoing and 

it will supplement in accordance with Federal Rules of Civil Procedure. 18920 will not 

produce privileged, responsive documents involving undersigned counsel.

REQUEST FOR PRODUCTION NO. 37. All Documents related to Your answer to 

Interrogatory No. 6 served concurrently herewith.

RESPONSE: 18920 objects to this request as vague in that it only references other discovery 

requests and is lacking in specificity as to the documents requested. Subject to the foregoing, 

18920 has produced responsive documents relating to the Debtor’s documents that provided 

redemption rights that were located after a reasonable search. 18920’s investigation into 

responsive documents is still ongoing and it will supplement in accordance with Federal Rules 

of Civil Procedure. 18920 will not produce privileged, responsive documents involving 

undersigned counsel.

REQUEST FOR PRODUCTION NO. 38. All Documents related to Your answer to 

Interrogatory No. 9 served concurrently herewith.

RESPONSE: 18920 objects to this request as vague in that it only references other discovery 

requests and is lacking in specificity as to the documents requested. Subject to the foregoing, 

18920 has produced responsive documents relating to the redemption notice and the mandatory 

redemption provided by the preferred shares that were located after a reasonable search. 

18920’s investigation into responsive documents is still ongoing and it will supplement in 

accordance with Federal Rules of Civil Procedure. 18920 will not produce privileged, 

responsive documents involving undersigned counsel.

REQUEST FOR PRODUCTION NO. 39. All Documents related to Your answer to 

Interrogatory No. 12 served concurrently herewith.

RESPONSE: 18920 objects to this request as vague in that it only references other discovery 

requests and is lacking in specificity as to the documents requested. Subject to the foregoing, 

18920 does not have any responsive documents, as no payments were made by 18920 for 

anything other than the Transaction Shares.

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REQUEST FOR PRODUCTION NO. 40. All Documents related to Your answer to 

Interrogatory No. 14 served concurrently herewith.

RESPONSE: 18920 objects to this request as vague and lacking in specificity as to the 

documents requested. 18920 hereby incorporates its objections and responses to Interrogatory 

No. 14. 

REQUEST FOR PRODUCTION NO. 41. All Documents related to Your answer to 

Interrogatory No. 16 served concurrently herewith.

RESPONSE: 18920 objects to this request as vague and lacking in specificity as to the 

documents requested. 18920 hereby incorporates its objections and responses to Interrogatory 

No. 16. 

REQUEST FOR PRODUCTION NO. 42. All Documents related to Your answer to 

Interrogatory No. 18 served concurrently herewith.

RESPONSE: 18920 objects to this request as vague and lacking in specificity as to the 

documents requested. 18920 hereby incorporates its objections and responses to Interrogatory 

No. 18. 

REQUEST FOR PRODUCTION NO. 43. All Documents related to Your answer to 

Interrogatory No. 23 served concurrently herewith.

RESPONSE: 18920 objects to this request as vague and lacking in specificity as to the 

documents requested. Subject to the foregoing, 18920 will produce responsive documents, if 

any, located after a reasonable search. 18920 objects to this request as vague in that it only 

references other discovery requests and is lacking in specificity as to the documents requested. 

Subject to the foregoing, 18920 will produce responsive documents, if any, located after a 

reasonable search. 18920’s investigation into responsive documents is still ongoing and it will 

supplement in accordance with Federal Rules of Civil Procedure.

REQUEST FOR PRODUCTION NO. 44. All Documents and Communications You 

assert or contend support Your Affirmative Defense No. 2 filed in response to the Trustee's 

Amended Complaint in this Adversary Proceeding.

RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. 18920 also objects to this request in that it lacks specificity as to the documents 

requested and is an improper request for production (as it is more akin to a contention 

interrogatory). 18920 will supplement as discovery proceeds and in accordance with the 

Federal Rules of Civil Procedure.

REQUEST FOR PRODUCTION NO. 45. All Documents and Communications You 

assert or contend support Your affirmative Defense No. 4 filed in response to the Trustee’s 

Amended Complaint in this Adversary Proceeding.

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Exhibit 1 Page 12 of 14
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RESPONSE: 18920 objects to this request to the extent it seeks documents that are protected 

from disclosure by the attorney client, work product, common interest, or joint defense 

privileges. 18920 also objects to this request in that it lacks specificity as to the documents 

requested and is an improper request for production (as it is more akin to a contention 

interrogatory). 18920 will supplement as discovery proceeds and in accordance with the 

Federal Rules of Civil Procedure.

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Exhibit 1 Page 13 of 14
14

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

Case 23-03072-mvl Doc 54-1 Filed 07/22/24 Entered 07/22/24 13:12:23 Desc

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