JORDAN, LYNCH & CANCIENNE PLLC

Michael Cancienne (SBN 24055256) 

Joseph W. Golinkin II (SBN 24087596) 

1980 Post Oak Blvd., Ste. 2300

Houston, Texas 77056

Telephone: 713.955.4025 

Counsel for 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.

The Individual Defendants N 11th,

LLC; JAMES GOODMAN; JAMES 

FRINZI; STEVEN ZAKHARYAYEV; 

EVELINA PINKASOVA; PEOPLE 

NQ INC.; JJC & PEOPLE LLC; 

GDMN FAMILY INVESTMENTS 2, 

LLC,

Defendants.

Case No. 22-31641-mvl-7

Adversary Proceeding No. 

23-03072-mvl

DEFENDANTS STEVEN ZAKHARYAEV AND EVELINA 

PINKHASOVA’S ANSWER TO PLAINTIFFS’ AMENDED COMPLAINT

Defendants Steven Zakharyayev and Evelina Pinkhasova (“The 

Individual Defendants”) submit their Answer to Plaintiffs’ Amended 

Complaint. Except as otherwise expressly admitted, The Individual 

Defendants deny each and every allegation contained in Plaintiffs’ Amended 

Complaint. 

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INTRODUCTION

1. The Individual Defendants deny the allegations contained in

Paragraph 1.

2. The Individual Defendants deny the allegations contained in

Paragraph 2.

3. The Individual Defendants deny the allegations contained in

Paragraph 3.

4. Paragraph 4 does not contain factual allegations, and therefore

no response to this paragraph is required. To the extent a response is deemed 

required, The Individual Defendants deny any allegations contained in 

Paragraph 4. 

PROCEDURAL BACKGROUND

5. Upon information and belief, The Individual Defendants admit

the allegations contained in Paragraph 5.

6. Upon information and belief, The Individual Defendants admit

the allegations contained in Paragraph 6.

7. Upon information and belief, The Individual Defendants admit

the allegations contained in Paragraph 7.

8. The first two sentences of Paragraph 8 do not contain factual

allegations, and therefore no response to these sentences is required. The third 

sentence of Paragraph 8 contains the Trustee’s consent to entry of a final 

judgment, and therefore is likewise not an allegation that The Individual 

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Defendants can admit or deny. To the extent a response is deemed to be 

required for Paragraph 8, The Individual Defendants deny the allegations 

contained in Paragraph 8.

9. Paragraph 9 consists of a legal conclusion to which The Individual

Defendants is not required to admit or deny. To the extent a response is 

deemed to be required, The Individual Defendants respond that upon 

information and belief, they believe that venue is proper.

PARTIES

10. Upon information and belief, The Individual Defendants admit

that the Trustee is the Chapter 7 trustee of the Debtor. The capacity in which 

the Trustee is filing this lawsuit is not an allegation that The Individual 

Defendants can admit or deny, and The Individual Defendants lack sufficient 

information to admit or deny this statement in any event. 

11. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 11 and, therefore, deny those allegations.

12. The Individual Defendants admit the allegations contained in

Paragraph 12.

13. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 13 and, therefore, deny those allegations.

14. The Individual Defendants lack knowledge or information

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sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 14 and, therefore, deny those allegations.

15. The Individual Defendants admit the allegations contained in

Paragraph 15.

16. The Individual Defendants admit the allegations contained in

Paragraph 16.

17. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 17 and, therefore, deny those allegations.

18. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 18 and, therefore, deny those allegations.

19. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 19 and, therefore, deny those allegations.

“Facts”

20. Upon information and belief, The Individual Defendants admit

that Frinzi was the Chief Executive Officer of the Debtor at the relevant times 

described in the amended complaint. Frinzi’s fiduciary obligations to the 

Debtor is a legal question, and therefore is not an allegation to which The 

Individual Defendants can respond. To the extent a response is deemed 

required, The Individual Defendants deny the assertion. 

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21. Upon information and belief, The Individual Defendants admit

that Frinzi was the Chief Executive Officer of GNET at the relevant times 

described in the amended complaint. Frinzi’s fiduciary obligations to GNET is 

a legal question, and therefore is not an allegation to which The Individual 

Defendants can respond. To the extent a response is deemed required, The 

Individual Defendants deny the assertion.

22. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 22 and, therefore, deny those allegations.

23. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 23 and, therefore, deny those allegations.

24. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 24 and, therefore, deny those allegations.

25. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 25 and, therefore, deny those allegations.

26. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 26 and, therefore, deny those allegations.

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27. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 27 and, therefore, deny those allegations.

28. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 28 and, therefore, deny those allegations.

29. The Individual Defendants admit the allegations contained in

Paragraph 29.

30. The Individual Defendants admit the allegations contained in

Paragraph 30.

31. The Individual Defendants deny the allegations contained in

Paragraph 31.

32. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 32 and, therefore, deny those allegations.

33. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 33 and, therefore, deny those allegations.

34. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 34 and, therefore, deny those allegations.

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35. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 35 and, therefore, deny those allegations.

36. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 36 and therefore deny the allegations. The Third Amended and 

Restated Certificate of Formation is a written document whose terms speak for 

itself. 

37. The Individual Defendants lack knowledge or information

sufficient to form a belief as to whether the “Debtor’s audited financial 

statements for the year ending December 31, 2020, the year in which the 

mandatory redemption obligation was removed, do not reflect a liability for 

accrued and unpaid mandatory redemption of preferred stock” and therefore 

deny this allegation. Otherwise, The Individual Defendants deny the 

allegations contained in Paragraph 37.

38. The Individual Defendants admit the allegations contained in

Paragraph 38.

39. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 39 and, therefore, deny those allegations.

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40. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 40 and, therefore, deny those allegations. 

41. The Individual Defendants admit that 18920 was presented with

an opportunity to purchase preferred shares of Goodman Networks from three 

entities that were owned and controlled by James Goodman. The Individual 

Defendants deny that “18920 was identified by Zakharyayev as the entity that 

would purchase the Transaction Shares” and also deny that Zakharyayev was 

a third party to purchase the transaction shares. Finally, The Individual 

Defendants lack knowledge or information to form a belief as to the truth about 

who identified 18920 to be the third party to purchase the Transaction Shares 

or who proposed to Goodman that he seek to sell some or all of the Series A-1 

Preferred Stock held by the Goodman Entities; thus, The Individual 

Defendants deny those allegations.

42. Paragraph 42 does not identify which “various of other

Defendants” it is referring to, but to the extent Paragraph 42 purports to allege 

that The Individual Defendants “implemented the plan in a nefarious manner, 

employing concealment and misleading documents in an attempt to ‘paper up’ 

something it knew to be nefarious and tortious,” The Individual Defendants

deny those allegations as well as the remainder of the allegations contained in 

Paragraph 42. 

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43. The Individual Defendants admit the allegations contained in

Paragraph 43. 

44. The Individual Defendants admit the allegations contained in

Paragraph 44. 

45. The Individual Defendants admit the allegations contained in

Paragraph 45. 

46. The Individual Defendants admit the allegations contained in

Paragraph 46. 

47. The Individual Defendants admit the allegations contained in

Paragraph 47. 

48. The Individual Defendants deny the allegations contained in

Paragraph 48. 

49. The Individual Defendants deny the allegations contained in

Paragraph 49. 

50. The Individual Defendants deny the allegations contained in

Paragraph 50. 

51. The Individual Defendants admit that it agreed to settle The

Individual Defendants’ redemption demand in exchange for the $50 Million 

Note. The Individual Defendants deny that Frinzi did not have the corporate 

authority to bind the Debtor to the $50 Million Note. The Individual 

Defendants does not know what Trustee has or has not been provided or is or 

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is not aware of, and therefore deny the remainder of the allegations in 

Paragraph 51. 

52. The Individual Defendants admit that on March 10, 2022, 18920

and Debtor executed the Settlement Agreement. The Individual Defendants

deny the remainder of the allegations contained in Paragraph 52. 

53. The Individual Defendants admit that the Settlement Agreement

states that The Individual Defendants holds the $50 Million Note. The 

Individual Defendants deny that the Settlement Agreement “had not been 

signed.” 

54. The Settlement Agreement is a written document that speaks for

itself. To the extent Paragraph 54 contains factual allegations, The Individual 

Defendants admit that 18920 entered into the Settlement Agreement. 

55. The Individual Defendants deny the allegations contained in

Paragraph 55. 

56. The Individual Defendants deny the allegations contained in

Paragraph 56. 

57. The Individual Defendants deny the allegations contained in

Paragraph 57. 

58. The Individual Defendants deny the allegations contained in

Paragraph 58. 

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59. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 59 and, therefore, deny those allegations. 

60. Paragraph 60 does not contain factual allegations, and therefore

no response to these sentences is required. To the extent a response is deemed 

to be required for Paragraph 60, The Individual Defendants deny the 

allegations contained in Paragraph 60. 

61. The Individual Defendants deny the allegations contained in

Paragraph 61. 

62. The Individual Defendants admit that “[i]n April, 2022,

Zakharyayev and Frinzi exchanged a revised version of the Settlement 

Agreement which included the transfer of a $4.5 million note payable by 

Multiband Global Resources, LLC to Multiband Field Services, Inc.” The 

Individual Defendants lack sufficient knowledge to either admit or deny 

whether Frinzi owned this company. The Individual Defendants deny the 

remainder of the allegations contained in Paragraph 62. 

63. The Individual Defendants admit that 18920 paid the Goodman

Entities $10 million but deny the remainder of the allegations contained in 

Paragraph 63. 

64. The Individual Defendants cannot either admit or deny the

allegations contained in Paragraph 64 because the nature of the allegations 

are not clear, and the allegations are therefore denied. 

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65. The Individual Defendants deny the allegations contained in

Paragraph 65. 

66. The Individual Defendants deny the allegations contained in

Paragraph 66.

67. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 67, and, therefore, deny those allegations. 

68. The Individual Defendants deny that Debtor was insolvent. The

Individual Defendants lack knowledge or information sufficient to form a belief 

as to the truth of the remaining allegations contained in Paragraph 68 and, 

therefore, deny those allegations. 

69. The Individual Defendants deny the allegations contained in

Paragraph 69.

70. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 70, and, therefore, deny those allegations. 

71. The Individual Defendants deny the allegations contained in

Paragraph 71. 

72. The Individual Defendants deny the allegations contained in

Paragraph 72. 

73. The Individual Defendants admit the allegations contained in

Paragraph 73. 

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74. The Individual Defendants deny the allegations contained in

Paragraph 74. 

75. The Individual Defendants deny the allegations contained in

Paragraph 75. 

76. The Individual Defendants deny the allegations contained in

Paragraph 76. 

77. The Individual Defendants admit that the Purchase Agreements

contain the language quoted in Paragraph 77. Otherwise, The Individual 

Defendants deny the allegations contained in Paragraph 77. 

78. The Individual Defendants deny the allegations contained in

Paragraph 78. 

79. The Individual Defendants deny the allegations contained in

Paragraph 79. 

80. The Individual Defendants deny the allegations contained in

Paragraph 80. 

81. The Individual Defendants deny the allegations contained in

Paragraph 81. 

82. The Individual Defendants deny the allegations contained in

Paragraph 82. 

83. The Individual Defendants deny the allegations contained in

Paragraph 83. 

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84. The Individual Defendants deny the allegations contained in

Paragraph 84. 

CAUSES OF ACTION

Count I

85. This cause of action is not directed at The Individual Defendants.

Nevertheless, The Individual Defendants deny the allegations contained in 

Paragraph 85, except as expressly admitted above. 

86. The Individual Defendants deny the allegations contained in

Paragraph 86. 

87. The Individual Defendants deny the allegations contained in

Paragraph 87. 

88. The Individual Defendants deny the allegations contained in

Paragraph 88. 

89. The Individual Defendants deny the allegations contained in

Paragraph 89. 

90. The Individual Defendants deny the allegations contained in

Paragraph 90. 

91. The Individual Defendants deny the allegations contained in

Paragraph 91. 

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Count II

92. This cause of action is not directed at The Individual Defendants.

Nevertheless, The Individual Defendants deny the allegations contained in 

Paragraph 92, except as expressly admitted above. 

93. Paragraph 93 contains a legal conclusion to which no response is

required. To the extent that a response is deemed to be required, The 

Individual Defendants deny any allegations contained in Paragraph 93. 

94. The Individual Defendants lack sufficient knowledge to either

admit or deny the allegations contained in Paragraph 94 and, therefore, deny

those allegations. 

95. The Individual Defendants deny the allegations contained in

Paragraph 95. 

96. The Individual Defendants deny the allegations contained in

Paragraph 96. 

97. The Individual Defendants deny the allegations contained in

Paragraph 97. 

98. The Individual Defendants deny the allegations contained in

Paragraph 98. 

99. The Individual Defendants deny the allegations contained in

Paragraph 99. 

100. The Individual Defendants deny the allegations contained in

Paragraph 100. 

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101. The Individual Defendants deny the allegations contained in

Paragraph 101. 

Count III

102. This cause of action is not directed at The Individual Defendants.

Nevertheless, The Individual Defendants deny the allegations contained in 

Paragraph 102, except as expressly admitted above. 

103. The Individual Defendants lack knowledge or information

sufficient to form a belief as to the truth of the allegations contained in 

Paragraph 103 and, therefore, deny those allegations. 

104. The Individual Defendants deny the allegations contained in

Paragraph 104. 

105. The Individual Defendants deny the allegations contained in

Paragraph 105. 

106. The Individual Defendants deny the allegations contained in

Paragraph 106. 

107. The Individual Defendants deny the allegations contained in

Paragraph 107. 

108. The Individual Defendants deny the allegations contained in

Paragraph 108. 

109. The Individual Defendants deny the allegations contained in

Paragraph 109. 

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Count IV

110. This cause of action is not directed at The Individual Defendants.

Nevertheless, The Individual Defendants deny the allegations contained in 

Paragraph 110, except as expressly admitted above. 

111. The Individual Defendants deny the allegations contained in

Paragraph 111. 

112. The Individual Defendants deny the allegations contained in

Paragraph 112. 

113. The Individual Defendants deny the allegations contained in

Paragraph 113. 

114. The Individual Defendants deny the allegations contained in

Paragraph 114. 

115. The Individual Defendants deny the allegations contained in

Paragraph 115. 

Count V1

116. This cause of action is not directed at The Individual Defendants.

Nevertheless, The Individual Defendants deny the allegations contained in 

Paragraph 116, except as expressly admitted above. 

117. Frinzi’s fiduciary obligations to the Debtor is a legal question, and

therefore is not an allegation to which The Individual Defendants can respond. 

1 Although this claim does not directly impact The Individual Defendants, it denies the 

allegations in abundance of caution.

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To the extent a response is deemed required, The Individual Defendants deny 

the assertion. 

118. The Individual Defendants deny the allegations contained in

Paragraph 118. 

119. The Individual Defendants deny the allegations contained in

Paragraph 119. 

120. The Individual Defendants deny the allegations contained in

Paragraph 120. 

121. The Individual Defendants deny the allegations contained in

Paragraph 121.2

Count VI3

122. This cause of action is not directed at The Individual Defendants.

Nevertheless, The Individual Defendants deny the allegations contained in 

Paragraph 122, except as expressly admitted above. 

123. Frinzi’s fiduciary obligations to the Debtor is a legal question, and

therefore is not an allegation to which The Individual Defendants can respond. 

To the extent a response is deemed required, The Individual Defendants deny 

the assertion. 

2 In an abundance of caution, The Individual Defendants deny the assertion set forth in 

footnote five of the Trustee’s Amended Complaint.

3 Although this claim does not directly impact The Individual Defendants, it denies the 

allegations in abundance of caution.

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124. The Individual Defendants deny the allegations contained in

Paragraph 124. 

125. The Individual Defendants deny the allegations contained in

Paragraph 125. 

126. The Individual Defendants deny the allegations contained in

Paragraph 126. 

Count VII

127. The Individual Defendants deny the allegations contained in

Paragraph 127, except as expressly admitted above. 

128. Paragraph 128 contains a legal conclusion to which no response

is required. To the extent that a response is deemed to be required, The 

Individual Defendants deny any allegations contained in Paragraph 128. 

129. The Individual Defendants deny the allegations contained in

Paragraph 129. 

130. The Individual Defendants deny the allegations contained in

Paragraph 130. 

131. The Individual Defendants deny the allegations contained in

Paragraph 131. 

132. The Individual Defendants deny the allegations contained in

Paragraph 132. 

133. The Individual Defendants deny the allegations contained in

Paragraph 133. 

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134. The Individual Defendants deny the allegations contained in

Paragraph 134.

Count VIII

135. The Individual Defendants deny the allegations contained in

Paragraph 135, except as expressly admitted above. 

136. Paragraph 136 contains a legal conclusion to which no response

is required. To the extent that a response is deemed to be required, The 

Individual Defendants deny any allegations contained in Paragraph 136. 

137. The Individual Defendants deny the allegations contained in

Paragraph 137.

138. The Individual Defendants deny the allegations contained in

Paragraph 138. 

139. The Individual Defendants deny the allegations contained in

Paragraph 139. 

140. The Individual Defendants deny the allegations contained in

Paragraph 140. 

141. The Individual Defendants deny the allegations contained in

Paragraph 141. 

142. The Individual Defendants deny the allegations contained in

Paragraph 142. 

143. The Individual Defendants deny the allegations contained in

Paragraph 143. 

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144. The Individual Defendants deny the allegations contained in

Paragraph 144. 

THE INDIVIDUAL DEFENDANTS’ AFFIRMATIVE AND OTHER 

DEFENSES

1. Plaintiffs have failed to state a claim against The Individual

Defendants upon which relief can be granted.

2. Plaintiffs’ claims are barred, in whole or in part, by the doctrine

of laches, acquiescence, waiver, equitable estoppel, and unclean hands. 

3. Plaintiffs’ claims are barred, in whole or in part, because some or

all of Plaintiffs lack standing to bring these claims.

4. Plaintiffs’ claims are barred, in whole or in part, by the doctrine

of ratification.

5. The Individual Defendants acted reasonably and in good faith at

all times. 

6. The costs, damages, and penalties the Plaintiffs seek to recover

or impose are unreasonable, excessive, arbitrary, and capricious.

7. The Plaintiffs are not entitled to recover attorneys’ fees or costs,

or fees of litigation.

8. The Individual Defendants reserves the right to plead additional

defenses as may be appropriate depending upon facts later revealed during 

discovery. 

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THE INDIVIDUAL DEFENDANTS’ REQUEST FOR RELIEF

WHEREFORE, The Individual Defendants pray that Plaintiffs’ claims 

be dismissed, and that this Court award The Individual Defendants their costs 

and reasonable attorneys’ fees in defending against Plaintiffs’ claims, and 

award such other and further relief to which The Individual Defendants may 

be justly entitled.

DEMAND FOR JURY TRIAL

The Individual Defendants hereby demand a trial by jury on all issues 

so triable.

Respectfully submitted,

JORDAN, LYNCH & CANCIENNE 

PLLC

By: Joseph W. Golinkin II

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 The Individual 

Defendants NW 11th, LLC

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CERTIFICATE OF SERVICE

I hereby certify that on this 9th day of May, 2024, I electronically filed 

the foregoing with the Clerk of Court using the CM/ECF system, which 

will send notification of this filing to all counsel of record in this case. 

/s/ Jeb Golinkin

Joseph W. Golinkin II

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