AGREED SCHEDULING ORDER—Page 1 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

GOODMAN NETWORKS, INC., 

 Debtor. 

SCOTT M. SEIDEL, TRUSTEE; 

GNET ATC, LLC; MULTIBAND 

FIELD SERVICES, INC., 

 Plaintiffs, 

v. 

18290 NW 11th, LLC, et. al., 

 Defendants. 

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Case No. 22-31641-mvl-7 

(Chapter 7) 

ADVERSARY PROCEEDING 

NO: 23-03072-mvl 

AGREED SCHEDULING ORDER 

 Pursuant to Rule 16, Federal Rules of Civil Procedure, and the parties’ agreement as 

reflected herein, the Court issues the following scheduling order to supersede any prior scheduling 

order entered in this proceeding: 

IT IS ORDERED THAT:

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AGREED SCHEDULING ORDER—Page 2 

1. Docket call for this Adversary Proceeding will be held on the Court’s February, 

2025 trial docket call day, tentatively estimated at February 4, 2025 at 1:15 p.m., but the parties 

are directed to obtain the precise setting once the Court issues its 2025 calendar. 

2. Trial of this Adversary Proceeding will be held during the Court’s trial week for 

February, 2025, tentatively estimated at February 10, 2025, but the parties are directed to obtain 

the precise setting once the Court issues its 2025 calendar. 

3. Parties shall complete fact discovery on or before September 20, 2024. Expert 

discovery shall be completed by November 30, 2024. Discovery must be served promptly enough 

to permit timely response by the other party. Parties may, by agreement, continue discovery 

beyond this deadline without further order of this Court. 

4. Non-expert initial disclosures are waived. 

5. Parties shall exchange names, addresses and reports of experts for trial on or before 

September 30, 2024. 

6. Rebuttal expert reports shall be exchanged on or before October 18, 2024. 

7. All dispositive motions shall be filed and served on all other parties on or before 

November 1, 2024. Responses shall be filed and served on all other parties not later than 21 days 

of the service of the motion. Any replies shall be filed and served on all other parties not later than 

7 days of the service of the response. 

8. Except for impeachment documents, all exhibits, along with a list of witnesses to 

be called, shall be exchanged with all other parties no later than January 31, 2025. 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. 

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AGREED SCHEDULING ORDER—Page 3 

9. On or before January 31, 2025, a Joint Pretrial Order in compliance with Local 

District Court Rule 16.4 shall be filed, served, and uploaded for Court entry. All parties 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. 

10. On or before January 31, 2025, the parties shall file proposed findings of fact and 

conclusions of law. 

11. On or before January 31, 2025, the parties shall file trial briefs addressing 

contested issues of law. 

12. This Order, and each party’s agreement to this Order, is wholly without prejudice 

to all issues concerning the Court’s core or non-core jurisdiction, or the lack thereof, or the lack of 

any consent to this Court’s entry of final judgment, or to any motion for withdrawal of the 

reference, and all rights, issues, objections, defenses, and arguments concerning any of the 

foregoing are preserved and may be asserted by each party as is otherwise appropriate 

notwithstanding the entry of this Order; provided, however, that any motion for the withdrawal of 

the reference should be filed no later than August 23, 2024, but, if filed thereafter, or if not granted 

prior to trial, the Court shall proceed to trial without prejudice to any reference withdrawal issue 

and, if the Court or the District Court determines that this Court’s jurisdiction is not core, then this 

Court shall make a report and recommendation to the District Court as is otherwise appropriate if 

the District Court has not by then entered an order providing otherwise (or unless a party obtains 

a stay from any court pending the same). 

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AGREED SCHEDULING ORDER—Page 4 

# # # END OF ORDER # # # 

AGREED: 

MUNSCH HARDT KOPF & HARR P.C. 

/s/ Davor Rukavina 

Davor Rukavina, Esq. 

Texas Bar No. 24030781 

500 North Akard St., Ste. 3800 

Dallas, Texas 75201 

Telephone: (214) 855-7500 

drukavina@munsch.com

ATTORNEYS FOR THE PLAINTIFFS 

/s/ Jason M. Rudd (w/ permission) 

Jason M. Rudd, Tex. Bar No. 24028786 

Paul T. Elkins, Tex. Bar No. 24092383 

WICK PHILLIPS GOULD & MARTIN, 

LLP 

3131 McKinney Avenue, Suite 500 

Dallas, TX 75204 

Phone: (214) 692-6200 

Fax: (214) 692-6255 

COUNSEL FOR DEFENDANT JAMES 

FRINZI 

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: /s/ Anna MacFarlane (w/ permission)

Randall A. Pulman 

Texas State Bar No. 16393250 

rpulman@pulmanlaw.com 

Leslie Sara Hyman 

Texas State Bar No. 00798274 

lhyman@pulmanlaw.com

ATTORNEYS FOR DEFENDANTS 

JAMES GOODMAN, PEOPLE NQ, INC., 

JJC & PEOPLE, LLC, AND GDMN 

FAMILY INVESTMENTS 2, LLLC 

JORDAN, LYNCH & CANCIENNE PLLC 

By: /s/ Michael Cancienne 

Michael Cancienne 

State Bar No. 24046330 

Joseph (“Jeb”) W. Golinkin II 

State Bar No. 24087596 

1980 Post Oak Blvd., Ste. 2300 

Houston, Texas 77056 

713-955-4020 (Telephone) 

713-955-9644 (Fax) 

mcancienne@jlcfirm.com 

jgolinkin@jlcfirm.com

ATTORNEYS FOR 18920 NW 11th, LLC, 

STEVEN ZAKHARYAYEV AND 

EVELINA PINKASHOVA 

4891-1836-2022v.1 013229.00016 

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