TRUSTEE’S FIRST SET OF POST-JUDGMENT REQUESTS FOR PRODUCTION

TO UNIFIED FIELD SERVICES, INC.—Page 1

Davor Rukavina, Esq.

Texas Bar No. 24030781

Thomas D. Berghman, Esq.

Texas Bar No. 24082683

Conor P. White

Texas Bar No. 24125722

MUNSCH HARDT KOPF & HARR, P.C.

500 N. Akard Street, Suite 4000

Dallas, Texas 75201-6659

Telephone: (214) 855-7500

Facsimile: (214) 855-7584

SPECIAL COUNSEL FOR SCOTT M. SEIDEL, TRUSTEE

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., §

§ (Chapter 7)

Debtor. §

§

§

SCOTT M. SEIDEL, TRUSTEE, §

§

Plaintiff, § ADVERSARY PROCEEDING

§ NO. 23-03088-mvl

v. §

§

UNIFIED FIELD SERVICES, INC., §

§

Defendant. §

TRUSTEE’S FIRST SET OF POST-JUDGMENT REQUESTS FOR PRODUCTION

TO UNIFIED FIELD SERVICES, INC.

To: Unified Field Services, Inc., by and through its attorneys of record, Randall A. Pulman, 

Leslie Sara Hyman, Anna K. MacFarlane, Pulman, Cappuccio & Pulllen, LLP, 2161 NW 

Military Highway, Suite 400, San Antonio, Texas 78213.

Scott M. Seidel, Trustee (the “Trustee”), the plaintiff in this Adversary Proceeding, hereby 

serves upon Unified Field Services, Inc. (“UFS”), the defendant in this Adversary Proceeding, this 

his Trustee’s First Set of Post-Judgment Requests for Production to Unified Field Services, Inc. 

Trustee's

Ex. A

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Exhibit A Page 1 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT REQUESTS FOR PRODUCTION

TO UNIFIED FIELD SERVICES, INC.—Page 2

(the “Requests”) as follows.

I. INSTRUCTIONS

1. These requests are intended to cover all information, documents, and things in Your 

possession, custody, or control. A document or thing is deemed to be in Your possession, custody, 

or control, if:

a. It is in Your physical control; or

b. It is in the physical control of any other person or entity, and You, individually or 

otherwise

i. Own the document or thing in whole or in part;

ii. Have a right by contract, statute, or otherwise, to use, inspect, examine, or 

copy that document or thing on any terms; or

iii. Have, as a practical matter, been able to use, inspect, examine, or copy that 

document or thing when You have sought to do so.

2. Unless otherwise indicated, references in these requests to You or any party, 

business organization, or other legal entity specifically includes all of that entity’s present or 

former employees, officers, directors, agents, representatives, members, attorneys, departments, 

sections, affiliates, subsidiaries, parents, and all other persons acting on its behalf.

3. If any portion of any document, electronically stored information, or tangible thing 

is responsive to any Request, then the entire document, electronically stored information, or 

tangible thing must be produced. Documents and electronically stored information shall be 

produced in the order in which they are found in your files. Documents that are found stapled, 

clipped, or otherwise fastened shall be produced in such form.

4. In the event that no document, electronically stored information, or tangible thing 

exists that is responsive to a particular Request, a written response indicating the same shall be 

provided.

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Exhibit A Page 2 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT REQUESTS FOR PRODUCTION

TO UNIFIED FIELD SERVICES, INC.—Page 3

5. If any document, electronically stored information, or tangible thing is withheld on 

the basis of privilege, or any Request is objected to on the basis of privilege, you must nevertheless 

produce other responsive documents, electronically stored information, or tangible things pursuant 

to such Request that are not subject to any privilege, and you must produce a privilege log 

concerning documents, electronically stored information, and tangible things withheld on the basis 

of privilege providing sufficient information to allow the Trustee to evaluate and determine the 

propriety of each such claim of privilege.

6. UFS must serve its responses to the Requests, no later than thirty (30) days 

following service of these Requests, at the following address or email:

Munsch Hardt Kopf & Harr, P.C.

Attn: Davor Rukavina

4000 Ross Tower

500 N. Akard Street

Dallas, Texas 75201

drukavina@munsch.com

II. DEFINITIONS

7. “Adversary Proceeding” shall mean Seidel v. Unified Field Services, Inc., Case No. 

23-03088-mvl in the United States Bankruptcy Court for the Northern District of Texas, Dallas 

Division.

8. “Affiliate” shall have the same meaning as defined in 11 U.S.C. § 101(2), and 

further include any directors, officers, managers, owners, any entity that has shared ownership 

with, or any subsidiary of the target of the Request.

9. “And” and “or” shall each be individually interpreted in every instance as meaning 

“and/or” and shall not be interpreted disjunctively to exclude any information otherwise within the 

scope of any specification.

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Exhibit A Page 3 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT REQUESTS FOR PRODUCTION

TO UNIFIED FIELD SERVICES, INC.—Page 4

10. “APA” shall mean that certain Asset Purchase Agreement dated June 4, 2021 by 

and between UFS, as buyer, and the Debtor, as seller, for certain assets related to the Debtor’s 

business.

11. “Bankruptcy Case” shall mean In re Goodman Networks, Inc., Case No. 22-31641-

mlv-7 in the United States Bankruptcy Court for the Northern District of Texas, Dallas Division.

12. “Communication” shall mean any contact or act by which any information is 

transmitted or conveyed between two or more persons, and shall include, without limitation, 

written contact by such means as letters, memoranda, telegrams, telexes, electronically transmitted 

messages, e-mails, or by any document, and any oral contact by such means as face-to-face 

meetings or conversations and telephone conversations that are transcribed, notated, or in any other 

manner memorialized in written, typed, or recorded form.

13. “Computer data” means any documents, information, or data ever placed into or 

stored on any of your computers, including but not limited to the hard drive, laptops, disks, storage 

systems, retrieval systems and similar systems, e-mails, Internet transmissions, electronic bulletin 

boards, websites, diary systems, calendar systems, tickler systems, and any other programs.

14. “Debtor” means Goodman Networks, Inc., the debtor in the Bankruptcy Case.

15. “Document(s)” means all written, recorded or graphic matter, whether in hard copy 

or generated or stored electronically or magnetically or by any other means, including without 

limitation, all papers, books, records, letters, photographs, tangible things, correspondence, 

communications, telegrams, cables, telex messages, memoranda, notes, notations, work papers, 

transcripts, minutes, reports, recordings of telephone or other conversations, interviews, 

conferences or other meetings, affidavits, statements, summaries, opinions, reports, studies, 

analyses, evaluations, contracts, agreements, jottings, agendas, bulletins, notices, announcements, 

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Exhibit A Page 4 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT REQUESTS FOR PRODUCTION

TO UNIFIED FIELD SERVICES, INC.—Page 5

advertisements, instructions, charges, brochures, publications, schedules, lists, journals, statistical 

records or calculations, desk calendars, appointment books, diaries, tabulations, programs, data 

process input and output, microfilm, ledgers, journals or books of account, records and invoices 

reflecting business operations, records kept by electronic, photographic or mechanical means, any 

notes or drafts relating to the foregoing, and all things similar to any of the foregoing, however 

denominated. “Document” shall also mean and include the original, drafts of the original and each 

non-identical copy (whether different from the original because of marginal notes or in whatever 

respect), including translations, of any written or graphic matter, whether typed, printed, recorded, 

filmed, produced by hand, or reproduced by any other mechanical process or means. Document 

includes ESI, Computer Data, and information on any Electronic information system and 

Electronic storage device.

16. “Electronic information system” refers to a computer system or network, cell 

phone, smart phone, tablet computer, PDA, cloud storage, online storage or other similar system 

or device that contains electronic storage.

17. “Electronic storage device” refers to magnetic, optical, flash, or other storage 

media, such as hard drives, flash or thumb drives, DVDs, CDs, tapes, cartridges, floppy diskettes, 

cloud storage, internet storage, smart cards, integrated circuit cards (e.g., SIM cards), cell phone, 

smart phone, tablet, or PDA drives.

18. “ESI” shall mean all electronically stored information or electronic files in an 

electronic information system or on electronic storage device, as defined herein. ESI includes, 

without limitation, voicemail messages; email messages and their attachments; text messages and 

their attachments; instant -messaging messages and their attachments; voicemail, email text and 

instant-messaging messages, and other electronic messages including all versions of these 

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Exhibit A Page 5 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT REQUESTS FOR PRODUCTION

TO UNIFIED FIELD SERVICES, INC.—Page 6

messages such as draft, sent, received, deleted, archived, and saved messages; electronic files such 

as word processing, spreadsheet, presentation, and other electronic files; draft, archived, and 

deleted versions of any kind of electronic file; temporary files; system history files; internet or 

web-browser-generated information stored in textual, graphical, or audio format, including history 

files, caches, and cookies; computer activity logs; metadata; all digital communications; 

accounting applications data; calendar and diary application data; presentations; network-access 

and server activity logs; and back-up and archival files. ESI also specifically includes any metadata 

associated with the ESI.

19. “File” means any collection or group of documents maintained, held, stored, or 

used together, including, without limitation, all collections of documents maintained, held, or 

stored in folders, notebooks, or other devices for separating or organizing documents.

20. “Financial Document” means any document related to or evidencing the financial 

condition of a company, including a financial statement, cash flow statement, balance sheet, or 

income statement, whether internal or created for or provided to a third person.

21. “Including” means ‘including but not limited to’, and is not restrictive or limiting.

22. “Insider” shall have the same meaning as defined by 11 U.S.C. § 101(31). This 

definition means any: director of the Debtor, officer of the Debtor, person in control of the Debtor, 

partnership in which the Debtor is a general partner, general partner of the Debtor, relative of a 

general partner, director, officer, or person in control of the Debtor, affiliate or insider of an 

affiliate if such affiliate were the Debtor, and managing agent of the Debtor.

23. “Goodman” shall mean Goodman Networks, Inc. and its present and former 

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

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Exhibit A Page 6 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT REQUESTS FOR PRODUCTION

TO UNIFIED FIELD SERVICES, INC.—Page 7

predecessors -in-interest, and all other natural persons or businesses or legal entities, presently or 

previously, acting on behalf of Goodman Networks, Inc.

24. “Person” or "persons" means any natural persons, firms, partnerships, associations, 

joint ventures, corporations and any other form of business organization or arrangement, as well 

as government or quasi-governmental agencies. If other than a natural person, include all natural 

persons associated with such entity.

25. “Transfer” shall have the same meaning as defined by 11 U.S.C. § 101(54). In 

particular, Transfer shall mean any creation of a lien, retention of title as a security interest, 

foreclosure of a debtor’s equity of redemption, or each mode, direct or indirect, absolute or 

conditional, voluntary or involuntary, of disposing or parting with property or an interest in 

property.

26. “TSA” shall mean that certain Transition Services Agreement dated June 4, 2021, 

by and between UFS and the Debtor in conjunction with the APA.

27. “UFS” shall mean Unified Field Services, Inc. and its present and former parents, 

subsidiaries, affiliates, agents, employees, representatives, assigns, attorneys, predecessors -ininterest, and all other natural persons or businesses or legal entities, presently or previously, acting 

on behalf of Unified Field Services, Inc.

28. “You” and “your” shall mean UFS and its present and former parents, subsidiaries, 

affiliates, agents, employees, representatives, assigns, attorneys, predecessors-in-interest, and all 

other natural persons or businesses or legal entities, presently or previously, acting on behalf of it.

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Exhibit A Page 7 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT REQUESTS FOR PRODUCTION

TO UNIFIED FIELD SERVICES, INC.—Page 8

III. 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:

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:

REQUEST NO. 3:

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

format, since January 1, 2020.

RESPONSE:

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:

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:

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Exhibit A Page 8 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT REQUESTS FOR PRODUCTION

TO UNIFIED FIELD SERVICES, INC.—Page 9

REQUEST NO. 6:

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

You under any contract or agreement.

RESPONSE:

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:

REQUEST NO. 8:

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

RESPONSE:

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:

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 

loan or capital, including any document giving rise to such payment or evidencing any obligation 

to make such payment.

RESPONSE:

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Exhibit A Page 9 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT REQUESTS FOR PRODUCTION

TO UNIFIED FIELD SERVICES, INC.—Page 10

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:

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:

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:

REQUEST NO. 14:

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

RESPONSE:

REQUEST NO. 15:

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

2022.

RESPONSE:

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:

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Exhibit A Page 10 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT REQUESTS FOR PRODUCTION

TO UNIFIED FIELD SERVICES, INC.—Page 11

REQUEST NO. 17:

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

any amounts owed by You thereunder.

RESPONSE:

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:

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:

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:

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:

Case 23-03088-mvl Doc 10-1 Filed 04/02/24 Entered 04/02/24 16:37:41 Desc

Exhibit A Page 11 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT REQUESTS FOR PRODUCTION

TO UNIFIED FIELD SERVICES, INC.—Page 12

DATED this 29th day of January, 2024.

MUNSCH HARDT KOPF & HARR, P.C.

By: /s/ Davor Rukavina

Davor Rukavina, Esq.

Texas Bar No. 24030781

Thomas D. Berghman, Esq.

Texas Bar No. 24082683

Conor P. White, Esq.

Texas Bar No. 24125722

500 N. Akard Street, Suite 4000

Dallas, Texas 75201-6659

Telephone: (214) 855-7500

Facsimile: (214) 855-7584

COUNSEL FOR SCOTT M. SEIDEL, 

TRUSTEE

CERTIFICATE OF SERVICE

The undersigned hereby certifies that, on the 29th day of January, 2024, he caused a true 

and correct copy of this document to be served via email on Randall A. Pulman, counsel of record 

for UFS, at RPulman@pulmanlaw.com, and by U.S. mail first-class, postage prepaid, on the 

following:

Randall A. Pulman

Leslie Sara Hyman

Anna K. MacFarlane

Pulman, Cappuccio & Pulllen, LLP

2161 NW Military Highway, Suite 400

San Antonio, Texas 78213

By: /s/ Conor White

Conor P. White

Case 23-03088-mvl Doc 10-1 Filed 04/02/24 Entered 04/02/24 16:37:41 Desc

Exhibit A Page 12 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT INTERROGATORIES TO UNIFIED FIELD SERVICES, 

INC.—Page 1

Davor Rukavina, Esq.

Texas Bar No. 24030781

Thomas D. Berghman, Esq.

Texas Bar No. 24082683

Conor P. White

Texas Bar No. 24125722

MUNSCH HARDT KOPF & HARR, P.C.

500 N. Akard Street, Suite 4000

Dallas, Texas 75201-6659

Telephone: (214) 855-7500

Facsimile: (214) 855-7584

SPECIAL COUNSEL FOR SCOTT M. SEIDEL, TRUSTEE

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., §

§ (Chapter 7)

Debtor. §

§

§

SCOTT M. SEIDEL, TRUSTEE, §

§

Plaintiff, § ADVERSARY PROCEEDING

§ NO. 23-03088-mvl

v. §

§

UNIFIED FIELD SERVICES, INC., §

§

Defendant. §

TRUSTEE’S FIRST SET OF POST-JUDGMENT INTERROGATORIES

TO UNIFIED FIELD SERVICES, INC.

To: Unified Field Services, Inc., by and through its attorneys of record, Randall A. Pulman, 

Leslie Sara Hyman, Anna K. MacFarlane, Pulman, Cappuccio & Pulllen, LLP, 2161 NW 

Military Highway, Suite 400, San Antonio, Texas 78213.

Scott M. Seidel, Trustee (the “Trustee”), the plaintiff in this Adversary Proceeding, hereby 

serves upon Unified Field Services, Inc. (“UFS”), the defendant in this Adversary Proceeding, this 

his Trustee’s First Set of Post-Judgment Interrogatories to Unified Field Services, Inc. 

Case 23-03088-mvl Doc 10-1 Filed 04/02/24 Entered 04/02/24 16:37:41 Desc

Exhibit A Page 13 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT INTERROGATORIES TO UNIFIED FIELD SERVICES, 

INC.—Page 2

(the “Interrogatories”) as follows.

I. INSTRUCTIONS

1. UFS must serve its responses to the Interrogatories, no later than thirty (30) days 

following service of these Requests, at the following address or email:

Munsch Hardt Kopf & Harr, P.C.

Attn: Davor Rukavina

4000 Ross Tower

500 N. Akard Street

Dallas, Texas 75201

drukavina@munsch.com

II. DEFINITIONS

2. “Adversary Proceeding” shall mean Seidel v. Unified Field Services, Inc., Case No. 

23-03088-mvl in the United States Bankruptcy Court for the Northern District of Texas, Dallas 

Division.

3. “Affiliate” shall have the same meaning as defined in 11 U.S.C. § 101(2), and 

further include any directors, officers, managers, or owners, any entity that has shared ownership, 

or any subsidiary of the target of the Request.

4. “And” and “or” shall each be individually interpreted in every instance as meaning 

“and/or” and shall not be interpreted disjunctively to exclude any information otherwise within the 

scope of any specification.

5. “APA” shall mean that certain Asset Purchase Agreement dated June 4, 2021 by 

and between UFS, as buyer, and the Debtor, as seller, for certain assets related to the Debtor’s

business.

6. “UFS” shall mean Unified Field Services, Inc. and its present and former parents, 

subsidiaries, affiliates, agents, employees, representatives, assigns, attorneys, predecessors -inCase 23-03088-mvl Doc 10-1 Filed 04/02/24 Entered 04/02/24 16:37:41 Desc

Exhibit A Page 14 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT INTERROGATORIES TO UNIFIED FIELD SERVICES, 

INC.—Page 3

interest, and all other natural persons or businesses or legal entities, presently or previously, acting 

on behalf of Unified Field Services, Inc.

7. “Bankruptcy Case” shall mean In re Goodman Networks, Inc., Case No. 22-31641-

mlv-7 in the United States Bankruptcy Court for the Northern District of Texas, Dallas Division.

8. “Debtor” means Goodman Networks, Inc., the debtor in the Bankruptcy Case.

9. “Including” means ‘including but not limited to’, and is not restrictive or limiting.

10. “Insider” shall have the same meaning as defined by 11 U.S.C. § 101(31). This 

definition means any: director of the Debtor, officer of the Debtor, person in control of the Debtor, 

partnership in which the Debtor is a general partner, general partner of the Debtor, relative of a 

general partner, director, officer, or person in control of the Debtor, affiliate or insider of an 

affiliate if such affiliate were the Debtor, and managing agent of the Debtor.

11. “Notes” shall mean the Seller’s Senior Secured notes due 2022, CUSIP No. 

38239HAF2, CUSIP No. 38239HAG0, and/or CUSIP No. 38239HAH8 identified in the APA.

12. “Person” or "persons" means any natural persons, firms, partnerships, associations, 

joint ventures, corporations and any other form of business organization or arrangement, as well 

as government or quasi-governmental agencies. If other than a natural person, include all natural 

persons associated with such entity.

13. “Transfer” shall have the same meaning as defined by 11 U.S.C. § 101(54). In 

particular, Transfer shall mean any creation of a lien, retention of title as a security interest, 

foreclosure of a debtor’s equity of redemption, or each mode, direct or indirect, absolute or 

conditional, voluntary or involuntary, of disposing or parting with property or an interest in 

property.

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Exhibit A Page 15 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT INTERROGATORIES TO UNIFIED FIELD SERVICES, 

INC.—Page 4

14. “TSA” shall mean that certain Transition Services Agreement dated June 4, 2021, 

by and between UFS and the Debtor in conjunction with the APA.

15. “Trustee” shall mean Scott M. Seidel, in his capacity as Trustee of the Bankruptcy 

Estate of Goodman Networks, Inc., in the above styled and numbered Bankruptcy Case.

16. “You” and “your” shall mean the party responding to these requests and its present 

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

predecessors-in-interest, and all other natural persons or businesses or legal entities, presently or 

previously, acting on behalf of it.

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Exhibit A Page 16 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT INTERROGATORIES TO UNIFIED FIELD SERVICES, 

INC.—Page 5

III. 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:

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:

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:

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:

INTERROGATORY NO. 5:

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

for Production, and Interrogatories.

RESPONSE:

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Exhibit A Page 17 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT INTERROGATORIES TO UNIFIED FIELD SERVICES, 

INC.—Page 6

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:

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:

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:

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:

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:

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Exhibit A Page 18 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT INTERROGATORIES TO UNIFIED FIELD SERVICES, 

INC.—Page 7

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:

INTERROGATORY NO. 12:

Explain the relationship between Goodman Investment Holdings and You, including with 

respect to the Notes as enumerated by the APA.

RESPONSE:

INTERROGATORY NO. 13:

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

or were purchased by You.

RESPONSE:

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:

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:

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Exhibit A Page 19 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT INTERROGATORIES TO UNIFIED FIELD SERVICES, 

INC.—Page 8

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:

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:

INTERROGATORY NO. 18:

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

the APA?

RESPONSE:

INTERROGATORY NO. 19:

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

you and their capital contributions.

RESPONSE:

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:

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Exhibit A Page 20 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT INTERROGATORIES TO UNIFIED FIELD SERVICES, 

INC.—Page 9

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:

INTERROGATORY NO. 22:

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

No. 7.

RESPONSE:

DATED this 29th day of January, 2024.

MUNSCH HARDT KOPF & HARR, P.C.

By: /s/ Davor Rukavina

Davor Rukavina, Esq.

Texas Bar No. 24030781

Thomas D. Berghman, Esq.

Texas Bar No. 24082683

Conor P. White, Esq.

Texas Bar No. 24125722

500 N. Akard Street, Suite 4000

Dallas, Texas 75201-6659

Telephone: (214) 855-7500

Facsimile: (214) 855-7584

COUNSEL FOR SCOTT M. SEIDEL, 

TRUSTEE

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Exhibit A Page 21 of 22
TRUSTEE’S FIRST SET OF POST-JUDGMENT INTERROGATORIES TO UNIFIED FIELD SERVICES, 

INC.—Page 10

CERTIFICATE OF SERVICE

The undersigned hereby certifies that, on the 29th day of January, 2024, he caused a true 

and correct copy of this document to be served via email on Randall A. Pulman, counsel of record 

for UFS, at RPulman@pulmanlaw.com, and by U.S. mail first-class, postage prepaid, on the 

following:

Randall A. Pulman

Leslie Sara Hyman

Anna K. MacFarlane

Pulman, Cappuccio & Pulllen, LLP

2161 NW Military Highway, Suite 400

San Antonio, Texas 78213

By: /s/ Conor White

Conor P. White

Case 23-03088-mvl Doc 10-1 Filed 04/02/24 Entered 04/02/24 16:37:41 Desc

Exhibit A Page 22 of 22