Randall A. Pulman 

State Bar No. 16393250 

Leslie Sara Hyman 

State Bar No. 00798274 

Anna K. MacFarlane 

State Bar No. 24116701 

PULMAN CAPPUCCIO & PULLEN, LLP 

2161 NW Military Hwy., Suite 400 

San Antonio, Texas 78213 

Telephone: (210) 222-9494 

Facsimile: (210) 892-1610 

rpulman@pulmanlaw.com 

Ihyman@pulmanlaw.com 

amacfarlane@pulmanlaw.com 

COUNSEL FOR UNIFIED FIELD SERVICES, INC 

 

 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

 

DALLAS DIVISION 

IN RE: § CASE NO. 22-31641-MVL-7 

§ GOODMAN NETWORKS, INC., § 

§ 

DEBTOR. § CHAPTER 7 

SCOTT M. SEIDEL, TRUSTEE, § 

PLAINTIFF § 

§ V. § 

§ ADVERSARY NO. 23-03088-MVL 

UNIFIED FIELD SERVICES, INC. § 

 

DEFENDANT § 

DEFENDANT UNIFIED FIELD SERVICES, INC.’S RESPONSES TO TRUSTEE’S FIRST SET OF 

 

Post-JUODGMENT INTERROGATORIES 

TO: Scott M. SEMEL, TRUSTEE, Plaintiff herein, by and through his attorneys of record, 

Davor Rukavina, Munsch Hardt Kopf & Harr, PC, 500 N. Akard St., Suite 4000, Dallas, 

Texas 75201 

Comes now Unified Field Services, Inc. Defendant herein (hereinafter “UFS” or 

“Defendant”) and serves upon Scott M. Seidel, Trustee (“Trustee” or “Plaintiff’), its Responses to 

Trustee ’s First Set of Post-Judgment Interrogatories to Defendant. 

4860-1730-8342, v. 1

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Exhibit D Page 1 of 18
Dated: April 24, 2024 Respectfully submitted, 

PULMAN, CAPPUCCIO & PULLEN, LLP 

2161 NW Military Highway, Suite 400 

San Antonio, Texas 78213 

www.pulmanlaw.com 

(210) 222-9494 Telephone 

(210) 892-1610 Facsimile 

 

By: 4s/ Randall A. Pulman 

Randall A. Pulman 

Texas State Bar No. 16393250 

rpulman@pulmanlaw.com 

Leslie Sara Hyman 

Texas State Bar No. 00798274 

lhyman@pulmanlaw.com 

Anna Kk. MacFarlane 

Texas State Bar No. 24116701 

amacfarlane@pulmanlaw.com 

 

 

 

 

 

 

ATTORNEYS FOR DEFENDANT UNIFIED FINANCIAL 

SERVICES, INC. 

4860-1730-8342, v. 1

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Exhibit D Page 2 of 18
RESPONSES TO 

 

FIRST SET OF POST-JUDGMENT INTERROGATORIES 

 

INTERROGATORY NO. 1: 

Identify all of the bank accounts currently held in Your name or for Your benefit and any 

such bank accounts held at any time since January 1, 2020. The foregoing includes the name of 

the bank, the account number, and the holder of the account. 

RESPONSE: 

Encore Bank - Acct. No. 700192297 - Unified Field Services, Inc., Operating Account 

Encore Bank - Acct. No. 700192305 — Unified Field Services, Inc., Payroll Account 

 

INTERROGATORY NO. 2: 

Provide an accounting of all assets currently owned by You, including but not limited to, 

any cash equivalents, real property, personal property, contracts, accounts receivable, and potential 

or pending causes of action. 

RESPONSE: To the best of my knowledge and belief, there are no assets currently owned by UFS. 

 

INTERROGATORY NO. 3: 

Identify with specificity all holders of security interests or liens encumbering any of Your 

assets at any time since January 1, 2020, and, for each holder of such encumbrance, the collateral, 

amount, and method of such security interest or lien. 

RESPONSE: I am unaware of any current holders of any such security interests or liens. Per a 

UCC search of Unified Field Services, Inc., conducted April 19, 2024, using the Texas Secretary of 

State’s online database, there are no UCC Financing Statements on file that identify Unified Field 

Services, Inc. as a debtor. 

 

INTERROGATORY NO. 4: 

Identify any individuals or entities with knowledge of Your financial status, whether or not 

they are currently employed by You or a current or former preparer of Your financial information, 

including the most recent contact information for each. 

RESPONSE: 

Former CFO: Zachary Wiebe 

zachary.wiebe(@deviceservicesgroup.com 

210-823-0940 

4860-1730-8342, v. 1

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Exhibit D Page 3 of 18
310 Wilmeth Road, Suite 100 

McKinney, TX 75071 

Current Accountant: Melissa Novak 

accounting (@managelife.co 

210-487-0999 

711 W. Brackenridge St. 

Edna, TX 77957 

 

Tax Preparers: Yessica Perez 

210-760-1640 

Calvetti Ferguson 

700 Louisiana St. # 2500 

Houston, TX 77002 

 

INTERROGATORY NO. 5: 

Identify all individuals who assisted You with Your responses to the Trustee’s Requests 

for Production, and Interrogatories. 

RESPONSE: 

Attorneys with Pulman, Cappuccio & Pullen, LLP 

Cynthia Smith, General Counsel Contractor, Symbiont Ventures, LLC (formerly known as 

Goodman Investment Holdings, LLC). 

 

INTERROGATORY NO. 6: 

Identify all entities or individuals that are Affiliates, subsidiaries, owners, shareholders, or 

Insiders of You at any time since January 1, 2020. 

RESPONSE: 

Goodman Investment Holdings LLC is the sole shareholder of Unified Field Services, Inc. 

Unified Field Services, Inc. has no subsidiaries. 

See, UFS Org Chart produced in response to Trustee’s document request. 

 INTERROGATORY NO. 7: 

Provide an accounting of all assets Transferred by You outside the ordinary course of 

business since January 1, 2020, including but not limited to, any cash equivalents, real property, 

personal property, contracts, accounts receivable, and potential or pending causes of action. 

RESPONSE: See, Asset Purchase Agreement dated June 4, 2021. 

4860-1730-8342, v. 1

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Exhibit D Page 4 of 18
 

INTERROGATORY NO. 8: 

Identify each person (by name, title, address, phone number, and e-mail address) who was 

a director or officer of You at any time since January 1, 2020 and state the amount of compensation, 

expense reimbursements, and dividends or distributions paid to each such person during such time. 

RESPONSE: 

4/07/2021 John (Scot) Brunke appointed as sole Director 

Joseph Hart IV appointed as CEO and President. 

10/29/2021 John (Scot) Brunke removed as Director 

James Goodman appointed as Sole Director. 

Jake Goodman appointed as President 

Joseph Hart IV appointed as CEO 

Brad Kozma appointed as CFO 

6/23/2022 Lewis A. Walker II appointed as additional Director. 

INTERROGATORY NO. 9: 

Identify all of Your current contractual counterparties or trade partners, whether or not such 

relationship was a result of the APA or TSA. 

RESPONSE: None. 

INTERROGATORY NO. 10: 

For the individuals or entities identified in Interrogatory 9, identify the balance of the 

outstanding trade accounts, whether owed by You or the individual or entity identified above. 

RESPONSE: None. 

 

INTERROGATORY NO. 11: 

Identify each person who provided accounting services to you at any time since January 1, 

2020, including any auditor, internal accountant, outside accountant, or tax accountant, by name, 

firm, or current contact information, and the services that such person provided to You, and when. 

RESPONSE: See, Response to Interrogatory No. 4. 

 

INTERROGATORY NO. 12: 

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Exhibit D Page 5 of 18
Explain the relationship between Goodman Investment Holdings and You, including with 

respect to the Notes as enumerated by the APA. 

RESPONSE: Goodman Investment Holdings was the sole shareholder of UFS. 

 

INTERROGATORY NO. 13: 

Identify whether any additional Seller’s Notes, as defined in the APA, are currently held 

or were purchased by You. 

RESPONSE: I have reviewed Section 2.2 of the APA and found no definition of additional Seller 

Notes. 

 

INTERROGATORY NO. 14: 

Do you still have any business operations? If not, identify the circumstances by which You 

ceased any such business operations, including the date(s), the reason(s) why, whether any such 

business operations or underlying assets were Transferred by You, and to whom, why, and for 

what consideration. 

RESPONSE: None. 

 

INTERROGATORY NO. 15: 

Explain why You did not make payment on the amounts owed to the Debtor that formed 

the basis for this Adversary Proceeding. 

RESPONSE: UFI terminated operations and ran out of cash. 

INTERROGATORY NO. 16: 

Does any person owe You any money (whether by way of refund, contract, promissory 

note, lawsuit, unearned retainer, insurance claim, or otherwise) and, if so, by whom, for what and 

for how much. 

RESPONSE: To the best of my knowledge and belief, no. 

 

INTERROGATORY NO. 17: 

Identify any lawsuit that you have been involved in in any capacity at any time since 

January 1, 2020, including by name of court, proceeding number, and party names and capacities. 

RESPONSE: To the best of my knowledge and belief, the only lawsuit in which UFS is or was a 

party is this adversary proceeding. 

4860-1730-8342, v. 1

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Exhibit D Page 6 of 18
 INTERROGATORY NO. 18: 

What happened to the business and/or the assets you acquired from the Debtor pursuant to 

the APA? 

RESPONSE: The funds received from the Debtor went to pay overhead expenses. 

 INTERROGATORY NO. 19: 

How were you capitalized? Your answer should include the identity of persons capitalizing 

you and their capital contributions. 

RESPONSE: To the best of my knowledge and belief, Unified Field Services, Inc. was capitalized 

only by the loan from Goodman Investment Holdings, LLC in the amount $2,250,000, as evidenced 

by the March 1, 2022 Promissory Note in that same amount from Unified Field Services, Inc. to 

Goodman Investment Holdings, LLC. 

 INTERROGATORY NO. 20: 

Identify any payment made by You or on Your behalf to any creditor of You since January 

1, 2023, including the name of such creditor, the amount of such payment, and reason for such 

payment (such as whether the payment was for goods, services, or otherwise). You may exclude 

wages and salaries to anyone who was not a director, officer, or Insider. 

RESPONSE: To the best of my knowledge, none. 

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Exhibit D Page 7 of 18
 

INTERROGATORY NO. 21: 

Identify each payment or Transfer made by You since January 1, 2020 to any Affiliate, 

Insider, equity owner, director, or officer, including the date of such payment or Transfer, the 

amount thereof, and the reason for the same, and also including any return consideration You 

received for such payment or Transfer. 

RESPONSE: To the best of my knowledge, Unified Field Services, Inc. made some loan payments 

in 2022 to Goodman Investment Holdings, LLC pursuant to the March J, 2022 Promissory Note in 

the amount of $2,250,000 from Unified Field Services, Inc. to Goodman Investment Holdings, LLC. 

 

INTERROGATORY NO. 22: 

Identify any return consideration You received for any Transfer the subject of Interrogatory 

No. 7. 

RESPONSE: The “Acquired Assets” as such are defined in Article I of the Asset Purchase 

Agreement. 

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Exhibit D Page 8 of 18
VERIFICATION 

STATE OF TEXAS 

COUNTY OF BEXAR § 

BEFORE ME, the undersigned authority, on this day personally appeared John M. 

Goodman, President of Defendant Unified Field Services, Inc., who, being duly sworn on his oath, 

deposed and said that he is duly authorized to answer Defendants’ interrogatories in his capacity as 

president of Unified Field Services, Inc., that he has read the above and foregoing answers; and that 

based upon the best of his information and belief all factual statements contained therein are true 

and correct. 

Uniriep Fis_p Services, INc. 

 (a tant G rank pl 

 By: James E, Goodman, President 

SUBSCRIBED AND SWORN to before me on the _ day of 2024 to certify which 

witness my hand and official seal. 

 Notary Public 

In and for the State of Texas 

4860-1730-8342, v. 1

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Exhibit D Page 9 of 18
CERTIFICATE OF SERVICE 

The undersigned hereby certifies that, on the 24th day of April, 2024, a true and correct 

copy of the foregoing document was served on counsel of record for Trustee/Plaintiff in the manner 

and method indicated below. 

Via email: drukavina@numsch.com; 

tberghman@J11tt1tscl1.com; cwltite@J11u11sch.com 

Munsch Hardt Kopf & HalT, P.C. 

Attn: Davor Rukavina 

Thomas D. Berghman, 

Conor P. White 

4000 Ross Tower 

500 N. Akard Street 

Dallas, Texas 75201 

4860-1730-8342, V. 1 

Isl Randall A. Pulman 

Randall A. Pulman 

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Exhibit D Page 10 of 18
Randall A. Pulman 

State Bar No. 16393250 ~ 

Leslie Sara Hyman 

State Bar No. 00798274 

Anna K. MacFarlane 

State Bar No. 24116701 

PULMAN CAPPUCCIO & PULLEN, LLP - 

2161 NW Military Hwy., Suite 400 

San Antonio, Texas 78213 

Telephone: (210) 222-9494 

Facsimile: (210) 892-1610 

rpulman@pulmanlaw.com 

lhyman@pulmanlaw.com 

amacfarlane@pulmanlaw.com 

COUNSEL FOR UNIFIED FIELD SERVICES, INC 

 

 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

 

DALLAS DIVISION 

IN RE: § CASE NO. 22-31641-MVL-7 

§ 

GOODMAN NETWORKS, INC., § 

§ 

DEBTOR. § CHAPTER 7 

SCOTT M. SEIDEL, TRUSTEE, § 

PLAINTIFF § 

§ 

Vv. § 

§ ADVERSARY NO. 23-03088-MVL 

UNIFIED FIELD SERVICES, INC. § 

 

DEFENDANT § 

DEFENDANT UNIFIED FIELD SERVICES, INC.’S OBJECTIONS AND RESPONSES TQ TRUSTEE’S 

First SET OF Post-JUDGMENT REQUESTS FOR PRODUCTION. . 

t 

TO: Scott M. SEIDEL, TRUSTEE, Plaintiff herein, by and through his ‘attorneys of record, 

Davor Rukavina, Munsch Hardt Kopf & Harr, PC, 500 N. Akard St., Suite 4000, Dallas, 

Texas 75201 

Comes now Unified Field Services, Inc. Defendant herein (hereinafter “UFS” or 

“Defendant”) and serves upon Scott M. Seidel, Trustee (“Trustee” or “Plaintiff”), its Objections and 

Responses to Trustee’s First Set of Post-Judgment Requests for Production to Defendant. 

4876-7818-7190, v. 1

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Exhibit D Page 11 of 18
Dated: April 24, 2024 

4876-7818-7190, v. 4 

Respectfully submitted, 

PULMAN, CAPPUCCIO & PULLEN, LLP 

2161 NW Military Highway, Suite 400 

San Antonio, Texas 78213 

www.pulmanlaw.com 

(210) 222-9494 Telephone 

(210) 892-1610 Facsimile 

 

By: 4s/ Randall A, Pulman 

Randall A. Pulman 

Texas State Bar No. 16393250 

rpulman@pulmanlaw.com 

Leslie Sara Hyman 

Texas State Bar No. 00798274 

{hyman@pulmanlaw.com 

Anna kK. MacFarlane 

Texas State Bar No. 24116701 

amacfarlane@pulmanlaw.com 

 

 

 

 

 

 

ATTORNEYS FOR DEFENDANT UNIFIED FINANCIAL 

SERVICES, INC.

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Exhibit D Page 12 of 18
RESPONSES TO 

 

FIRST SET OF POST-JUDGMENT 

 

REQUESTS FOR PRODUCTION 

 REQUEST NO. 1: 

Any and all bank statements for any bank accounts held in Your name or for Your benefit 

since January 1, 2020 through the present. 

RESPONSE: 

Documents responsive to this request and included in Defendant’s current production are bates 

labeled Seidel UFS 000001 - 000165 

 

REQUEST NO. 2: 

Documents and records evidencing any and all of Your assets, including but not limited to 

any cash, cash equivalents, real property, personal property, contracts, accounts receivable, and 

potential or pending causes of action, since January 1, 2020. 

RESPONSE: 

Documents responsive to this request are included in the documents previously produced by 

Defendant. 

Documents responsive to this request and included in Defendant’s current production include, but 

may not be limited to, those documents bates labeled Seidel UFS 000717-000722, 001159- 

001165. 

 

REQUEST NO. 3: 

All Financial Documents of Yours, including any QuickBooks or accounting files in native 

format, since January 1, 2020. 

RESPONSE: 

Documents responsive to this request are included in the documents previously produced and are 

also included in the current production of documents. 

 

REQUEST NO. 4: 

All corporate governance documents since January 1, 2020, including any amendments 

thereof, and including Your articles of incorporation and bylaws, and including any records of any 

meeting of Your board (including any minutes, resolutions, presentations made to the board, and 

any other document by which any action or approval of the board was sought or made). 

RESPONSE: 

Documents responsive to this request are bates labeled Seidel UFS 000550-619, 001281-1283. 

4876-7818-7190, v. 1

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Exhibit D Page 13 of 18
 

REQUEST NO. 5: 

Communications discussing or related to, directly or indirectly, payments made by You to 

any Affiliates or Insiders of You since January 1, 2020. 

RESPONSE: 

Documents responsive to this request are included in the documents previously produced and are 

included in the current production of documents. 

 

REQUEST NO. 6: 

Documents or records reflecting any accounts receivable or other sums or amounts due to 

You under any contract or agreement. 

RESPONSE: 

Documents responsive to this request are included in the documents previously produced and are 

included in the current production of documents. 

 

REQUEST NO. 7: 

Any Documents reflecting an organizational chart outlining the structure of Your business, 

including the hierarchy of employees and related entities, since January 1, 2020. 

RESPONSE: A UFS organizational chart is included in the produced documents bates labeled 

Seidel UFS 000841. 

 

REQUEST NO. 8: 

All of Your tax returns filed with any governmental authority since January 1, 2020. 

RESPONSE: 2021 and 2022 Federal Tax Returns are included in the current document production. 

 

REQUEST NO. 9: 

Communications by and between You and the Debtor or any third-party related to the assets 

purchased by You under the APA or the services provided by the Debtor to You pursuant to the 

MSA. 

RESPONSE: 

To the extent such communications exist they are included in the produced documents. 

 

REQUEST NO. 10: 

Documents and Communications evidencing any distribution or transfer of funds to Your 

equity holders since January 1, 2020, whether by way of dividend, distribution, or repayment of 

4 

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Exhibit D Page 14 of 18
loan or capital, including any document giving rise to such payment or evidencing any obligation 

to make such payment. 

RESPONSE: 

Such documents and communications, if any, are included in the produced documents. 

 

REQUEST NO. 11: 

Documents and records evidencing any security interest or lien currently encumbering any 

asset of Yours, including but not limited to any financing agreements, factoring agreements, or 

judgment liens. 

RESPONSE: 

See response to Interrogatory No. 3. 

 

REQUEST NO. 12: 

For all individuals or entities identified in your response to Interrogatory Number 9, 

Documents and records evidencing the relationship between You and the identified party. 

RESPONSE: 

To the best of my knowledge and belief, to the extent such documents and records exist they are 

included in the produced documents. 

 

REQUEST NO. 13: 

All Documents and Communications evidencing or related to any Transfer of any of Your 

property since January 1, 2020 outside the ordinary course of Your business, including any related 

letter of intent, term sheet, or asset purchase agreement. 

RESPONSE: 

To the best of my knowledge and belief, to the extent such documents and communications exist 

they are included in the produced documents. 

 

REQUEST NO. 14: 

Documents and Communications relating to any cessation of Your business operations. 

RESPONSE: 

See document bates labeled Siedel UFS 001352. To the best of my knowledge and belief, the extent 

other documents and communications related to this request exist they are included in the produced 

documents. 

 

REQUEST NO. 15: 

Documents and Communications related to any repayment of Your debt since January 1, 

5 4876-7818-7190, v. 1

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Exhibit D Page 15 of 18
2022. 

RESPONSE: 

To the best of my knowledge and belief, no such documents exist, however, to the extent such 

documents and records may exist they are included in the produced documents. 

 

REQUEST NO. 16: 

Documents evidencing or related to any funds that any person may owe you, including any 

promissory note and security instrument, letter of credit, refund, general intangible, or commercial 

tort. 

RESPONSE: 

To the best of my knowledge and belief, no such documents exist, however, to the extent such 

documents and records may exist they are included in the produced documents. 

 

REQUEST NO. 17: 

All Communications between You and the Debtor regarding the APA or the TSA including 

any amounts owed by You thereunder. 

RESPONSE: 

To the best of my knowledge and belief, to the extent such documents and records exist they are 

included in the produced documents. 

 

REQUEST NO. 18: 

All insurance policies held in Your name or under which You were a payee or loss payee 

since January 1, 2020, including any director’s and officer’s coverage. 

RESPONSE: 

Copies of insurance policies responsive to this request were included in the documents initially 

produced by Defendant. 

 

REQUEST NO. 19: 

All documents and communications between You and any insurance carrier or broker 

evidencing or related to any claim You made on any insurance policy at any time since January 1, 

2020. 

RESPONSE: To the best of my knowledge and belief, no such documents or communications exist. 

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Exhibit D Page 16 of 18
 

REQUEST NO. 20: 

Your current listing of accounts payable or other funds owed by you to any person for any 

reason, including the amount of such funds that is claimed as owing, and the name and contact 

information of such person or creditor. 

RESPONSE: 

To the best of my knowledge and belief, no such listing exists. 

 

REQUEST NO. 21: 

All documents and communications between You and Amazon.com Services, Inc. or other 

contract counterparties pursuant to the contracts and businesses you acquired under the APA, 

related to any transfer, assignment, termination, alleged breach, renewal, non-renewal, 

amendment, or modification of any such contract or business. 

RESPONSE: 

To the best of my knowledge and belief, to the extent such documents and communications exist, 

they are included in the produced documents. 

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Exhibit D Page 17 of 18
CERTIFICATE OF SERVICE 

The undersigned hereby certifies that, on the 24th day of April, 2024, a true and correct 

copy of the foregoing document was served on counsel of record for Trustee/Plaintiff in the manner 

and method indicated below. 

Via email: drukavina@munsch.comi 

tberghman@Jnunsch.comj cwhite@111u11sch.com 

Munsch Hardt Kopf & Harr, P.C. 

Attn: Davor Rukavina 

Thomas D. Berghman, 

Conor P. White 

4000 Ross Tower 500 

N. Akard Street 

Dallas, Texas 75201 

4876-7818-7190, V. 1 

8 

Isl Randall A. Putman 

Randall A. Pulman 

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Exhibit D Page 18 of 18