In Re: Seidel et al. v. 18920 NW 11th, LLC et al.

Case No. 22-31641-mvl7

Adv. No. 23-03072–mvl

SUMMONS SERVICE EXECUTED

I, Conor White of** Munsch Hardt Kopf & Harr, P.C.

certify:

That I am, and at all times hereinafter mentioned was, more than 18 years of age;

That on the 8th day of August, 2023 , I served a copy of 

the summons, notice to litigants, and scheduling order attached hereto, together with the 

complaint filed in this proceeding, on:

18920 NW 11th, LLC;

James Goodman;

James Frinzi;

Steven Zakharyayev;

Evelina Pinkhasova;

People NQ, Inc.;

JJC & People, LLC; and 

GDMN Family Investments 2, LLC

the defendants in this proceeding, by 

U.S. mail first class, postage prepaid – and – U.S. certified mail, postage 

prepaid, return receipt requested

the said defendants at:

18920 NW 11th, LLC

c/o Evelina Pinkhasova, Registered Agent

2719 Hollywood Blvd.

Hollywood, FL 33020

James Goodman

103 Tomahawk Trail

San Antonio, TX 78232

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James Frinzi

9204 Eddy Cv.

Austin, TX 78735

Steven Zakharyayev

43 West Canadian Woods Road

Marlboro, NJ 07746

Evelina Pinkhasova

43 West Canadian Woods Road

Marlboro, NJ 07746

People NQ, Inc.

c/o Capital Corporate Services, Inc., Registered Agent

1501 S Mopac Expy 

Suite 220

Austin, TX 78746

JJC & People, LLC

c/o James Goodman, Registered Agent

205 Crest Trl

San Antonio, TX 78232

GDMN Family Investments 2, LLC

c/o John Goodman, Registered Agent

2801 Network Blvd

Suite 300

Frisco, TX 75034

I certify under penalty of perjury that the foregoing is true and correct.

Executed on August 8, 2023 /s/ Conor White

(Date) Conor P. White, Esq.

** 500 N. Akard St., Ste. 3800, Dallas, TX 75201

 State mailing address

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BTXN 117a (rev. 10/02)

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

In Re: §

§

§

§

§

§

§

§

§

§

§

§

§

Goodman Networks, Inc. and Goodman Networks Inc

d/b/a Goodman Solutions

Debtor(s)

 Case No.: 22−31641−mvl7

 Chapter No.: 7

Scott M. Seidel et al.

Plaintiff(s) Adversary No.: 23−03072−mvl

 vs.

18920 NW 11th, LLC; James Goodman; James Frinzi;

Steven Zakharyayev; Evelina Pinkhasova; People NQ

Inc.; JJC & People LLC; and GDMN Family

Investments 2, LLC

Defendant(s)

SUMMONS IN AN ADVERSARY PROCEEDING

To the above−named defendant:

You are hereby summoned and required to serve upon Davor Rukavina, Plaintiff's attorney (or if Plaintiff is not

represented by counsel, upon Plaintiff), whose address is Munsch, Hardt, Kopf & Harr

500 N. Akard Street, Ste 3800

Dallas, TX 75201−6659 , either a motion or an answer to the complaint which is now served upon you. If you elect

to respond first by motion, as you may pursuant to Fed. R. Bankr. P. 7012, that governs the time within which your

answer must be served. Otherwise, you are required to serve your answer upon Plaintiff's attorney (or upon Plaintiff if

Plaintiff is not represented by counsel) within 30 days of the date of issuance of this summons by the clerk (or by the

following date prescribed by the court: N/A) except that the United States or an office or agency thereof shall serve

an answer to the complaint within 35 days after the date of issuance of the summons.

{If this summons and complaint is served in a foreign country} Service of your answer must be made by the following

date prescribed by the court N/A.

The motion or answer served by you must be filed with this court before service or within a reasonable time after

service. IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS SUMMONS, JUDGMENT BY

DEFAULT WILL BE TAKEN AGAINST YOU FOR THE RELIEF DEMANDED IN THE COMPLAINT.

DATED: 8/7/23 FOR THE COURT:

Robert P. Colwell, Clerk of Court

by: /s/D. Harden, Deputy Clerk

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BTXN 117n (rev. 02/2015)

A copy of this Notice to Litigants should be served

on the defendant along with the Summons and Complaint.

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

NOTICE TO LITIGANTS

You have been named as a defendant in an adversary proceeding, the outcome of

which could affect your bankruptcy discharge. Even if you have already received a

discharge, this is a serious matter that you should not ignore.

 Individual litigants are entitled to appear without an attorney and represent themselves in

the Bankruptcy Court. However, the rules can be quite technical and failure to comply with the

rules can have severe consequences. Before deciding to appear on your own, you should consider

consulting an attorney. If you were represented in your chapter 7 or 13 bankruptcy case by

counsel, you should notify that attorney that you have been named as a defendant.

 If you cannot afford an attorney, you may be eligible for free legal representation through

Legal Aid of NorthWest Texas (LANWT) or the Dallas Volunteer Attorney Program (DVAP). To

determine if you are eligible, you must apply for legal representation at a regularly−scheduled

neighborhood legal clinic. In addition, if you were recently represented by an attorney in a chapter

7 or 13 case, you should notify that attorney immediately.

 Upon application at a neighborhood legal clinic, you will be screened for eligibility based

on your current income and the availability of any other assets to pay for legal services. If it is

determined that you are eligible, an attorney may be found who will represent you without

payment of attorneys' fees. Please note that, even if you are eligible, you may still be responsible

for the payment of costs, such as court reporter fees, deposition transcripts, court transcripts,

postage and copies.

 On the last page of this notice, you will find a list of neighborhood legal clinics, their

locations, and the times they meet. When you make contact with DVAP or LANWT, please have

your copy of the summons and complaint with you, as well as a copy of any Schedule of Assets

and Liabilities and Statement of Financial Affairs filed in your bankruptcy case.

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Neighborhood Legal Clinics

EAST DALLAS

1st & 3rd Thursdays at 5:00 pm

Grace United Methodist Church

4105 Junius at Haskell

Dallas, TX 75246

SOUTH DALLAS

1st, 2nd and 4th Tuesdays at 5:00 pm

Martin Luther King, Jr. Center

Core Services Building,

2922 Martin Luther King Blvd.,

Room 122

Dallas, Texas 75215

FRIENDSHIP WEST BAPTIST CHURCH

3rd Wednesday at 5:30 pm

2020 West Wheatland Road

Dallas, Texas 75232

TRIANGLE NEIGHBORHOOD

3rd Tuesdays at 5:00 pm

(excluding summer)

St. Phillip.s Community Center

1600 Pennsylvania Avenue

Dallas, Texas 75215

WEST DALLAS

2nd & 4th Thursdays at 5:00 pm

Wesley−Rankin

Community Center

3107 N. Winnetka

Dallas, Texas 75212

GARLAND

3rd Thursday at 5:00 pm

(excluding December)

Salvation Army

Downtown Garland

457 W. Avenue D

Garland, Texas 75040

FORT WORTH

3rd Tuesday at 5:00 pm

(excluding December)

Legal Aid of NorthWest Texas

600 E. Weatherford St

Fort Worth, TX 76102

PLEASE TAKE NOTE

 Clinics may be cancelled because of bad weather, federal

holidays, or during elections. To confirm that a clinic will occur

as scheduled, contact (214) 243−2247 for Dallas or Garland

clinics, or (800) 955−3959 for Fort Worth clinics.

Please bring proof of income and residency, as well as a copy of

the Schedule of Assets and Liabilities and Statement of Financial

Affairs filed in your bankruptcy case and the summons and

complaint. If you have been sued, please bring your legal

documents.

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BTXN 090 (rev. 12/09)

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

In Re: §

§

§

§

§

§

§

§

§

Goodman Networks, Inc. and Goodman Networks Inc

d/b/a Goodman Solutions

Debtor(s)

 Case No.: 22−31641−mvl7

 Chapter No.: 7

Scott M. Seidel et al.

Plaintiff(s) Adversary No.: 23−03072−mvl

 vs.

18920 NW 11th, LLC et al.

Defendant(s)

ORDER REGARDING ADVERSARY PROCEEDINGS TRIAL SETTING AND

ALTERNATIVE SCHEDULING ORDER

 An adversary complaint is set for trial routinely at the time of its filing. Special settings or pretrial conferences

may be scheduled by contacting the appropriate Courtroom Deputy.

 TRIAL is set before the Honorable Michelle V. Larson at Courtroom #2, 14th Floor, 1100 Commerce

Street, Dallas, TX the week of January 8, 2024. Docket call for this trial will be held on January 2, 2024 at 1:15

P.M. at Courtroom #2, 14th Floor, 1100 Commerce Street, Dallas, TX. A pretrial conference shall be scheduled

by the parties at least seven (7) calendar days prior to trial docket call in a complex adversary proceeding if the

parties anticipate that trial will exceed one day or if there are preliminary matters that should be addressed by the

Court prior to the commencement of trial.

PART I: INSTRUCTIONS

1. Plaintiff is responsible for ensuring that proper service is provided to each defendant. The Clerk shall issue one original summons, which

shall be conformed by the plaintiff for service on multiple defendants. Federal Bankruptcy Rule 7004(e) requires you to serve the fully

completed SUMMONS form and a copy of the COMPLAINT on each defendant within seven (7) days of issuance. In addition, the Court

also directs that this ORDER be served with the SUMMONS and COMPLAINT.

2. Plaintiff shall file a RETURN on the SUMMONS with a CERTIFICATE OF SERVICE that provides the name

and address of each party served and the manner of service.

3. If a trial setting is passed for settlement at trial docket call and no written request is filed to retain the case on the

Court's docket, an automatic Dismissal Without Prejudice shall be entered on or after four (4) weeks. The Court's

Trial Calendar is available on the court's web site at www.txnb.uscourts.gov.

PART II: GENERAL PROVISIONS GOVERNING DISCOVERY

1. Unless otherwise ordered by the Court, the disclosures required by Federal Bankruptcy Rule 7026(a) shall be made within fourteen (14)

days of the entry of a scheduling order, including the Alternative Scheduling Order contained in Part III below (which shall become effective

on the forty−sixth day following the entry of this Order.

2. Unless the parties agree or the Court orders otherwise, Federal Bankruptcy Rule 7026(f) requires that parties shall

confer to consider the nature and basis of their claims and defenses and the possibilities for a prompt settlement or

resolution of the case, to make or arrange for the disclosures required by Federal Bankruptcy Rule 7026(a)(1), to

develop a proposed discovery plan, and to submit a proposed scheduling order. The parties shall confer with each

other regarding these matters within thirty (30) days of the service of the Summons unless the Court orders otherwise.

3. During such conference, the parties may agree to waive the requirement of submitting their own proposed

scheduling order and may follow the terms and deadlines contained in the Alternative Scheduling Order set forth in

Part III below (the "Alternative Scheduling Order"). If the parties do not submit a proposed scheduling order or do

not schedule a status conference with the Court to discuss the provisions and deadlines of a scheduling order within

forty−five days of the filing of this adversary proceeding, then the parties are deemed to have consented to the terms

of the Alternative Scheduling Order.

PART III: ALTERNATIVE SCHEDULING ORDER

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The Court directs compliance with the following schedule:

1. Discovery must be completed forty−five (45) days prior to Docket Call. The names and addresses of experts must

be exchanged sixty (60) days prior to Docket Call.

2. A Joint Pretrial Order in compliance with Local District Court Rule 16.4 shall be filed, served, and uploaded for

Court entry seven (7) days prior to Docket Call. All counsel (or a pro se party) are responsible for preparing the Joint

Pretrial Order, which shall contain the following: (a) a summary of the claims and defenses of each party; (b) a

statement of stipulated facts; (c) a list of the contested issues of fact; (d) a list of contested issues of law; (e) an

estimate of the length of trial; (f) a list of additional matters which would aid in the disposition of the case; and (g) the

signature of each attorney (or pro se party).

3. Each exhibit shall be marked with an exhibit label. Except for impeachment documents, all exhibits, along with a list of witnesses to be

called, shall be exchanged with opposing counsel (or pro se party) fourteen (14) days prior to Docket Call. Each party shall also file a list of

exhibits and witnesses fourteen (14) days prior to Docket Call. All exhibits not objected to in writing by Docket Call shall be admitted into

evidence at trial without further proof, except for objections to relevance. Written objections to exhibits will be taken up either at the

beginning or during the course of the actual trial or at any pretrial conference.

4. Written Proposed Findings of Fact and Conclusions of Law shall be filed seven (7) days prior to Docket Call. Trial

briefs shall be filed addressing contested issues of law seven (7) days prior to Docket Call.

5. Unless otherwise directed by the Presiding Judge, all dispositive motions must be heard no later than fourteen (14) days prior to Docket

Call. Accordingly, all dispositive motions must be filed no later than forty−five (45) days prior to Docket Call, unless the Court modifies this

deadline.

6. All parties and counsel must certify to full compliance with this Order at Docket Call. If a resetting is allowed by

the Court, the plaintiff or plaintiff's attorney shall notify all other parties and shall file with the Clerk a certificate of

service indicating the manner, date, and to whom notice was given.

7. If the case is reset, all the deadlines in Part III nos. 1 through 5 will be shifted to the newly scheduled Docket Call

date in the absence of a contrary Court order.

8. Sanctions may be imposed for failure to comply with this Order.

DATED: 8/7/23 FOR THE COURT:

Robert P. Colwell, Clerk of Court

by: /s/D. Harden, Deputy Clerk

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