1 

IN THE UNITED STATES BANKRUPCTY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

GOODMAN NETWORKS, INC. 

 Debtor. 

§ 

§ 

§ 

§ 

§ 

§ 

Case No. 22-31641-mv-7 

(Chapter 7) 

SCOTT M. SIEDEL, TRUSTEE 

 Plaintiff, 

v. 

HUDSON CLEAN ENERGY 

ENTERPRISES, LLC, ALLIANCE TEXAS 

HOLDINGS, LLC; NEIL Z. AUERBACH, 

JUDITH AUERBACH, AUERBACH 

PARTNERS, L.P, JAMES GOODMAN, 

JAMES FRINZI, GOODMAN 

INVESTMENT HOLDINGS, LLC, 

GENESIS NETWORKS, INC., GENESIS 

NETWORKS GLOBAL SERVICES, LLC, 

AUERBACH CHILDREN’S DYNASTY 

TRUST U/A/D OCTOBER 9, 2012, and 

AUERBACH FAMILY DYNASTY TRUST 

U/A/D OCTOBER 9, 2012, 

 Defendant(s). 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

ADVERSARY PROCEEDING 

NO: 23-03090-mvl 

UNOPPOSED MOTION TO WITHDRAW AS COUNSEL OF RECORD 

Wick Phillips Gould & Martin, LLP (“WPGM”) files this Unopposed Motion to Withdraw 

as Counsel (the “Motion”) for Defendant James Frinzi (“Mr. Frinzi”). 

1. WPGM seeks to withdraw from representing Mr. Frinzi in this case. WPGM is

owed substantial fees and expenses under its engagement letter. 

Case 23-03090-mvl Doc 23 Filed 04/23/24 Entered 04/23/24 15:58:06 Desc Main

Document Page 1 of 6
2 

2. Pursuant to Local Bankruptcy Rule 2091-1, Mr. Frinzi agrees to WPGM’s

withdrawal and executed this Motion below. Mr. Frinzi has not retained successor counsel and his 

contact information is as follows: 

a. Name: Mr. James Frinzi

b. Address: 3736 Bee Cave Road, Suite 1164 Austin, Texas 78746

c. Telephone Number: (202) 430-4500

3. This request to withdraw is not made for purposes of delay.

WHEREFORE, WPGM respectfully requests this Court to (i) grant the Motion, (ii) enter 

the proposed order attached as Exhibit A to permit WPGM to withdraw as counsel to Mr. Frinzi, 

(iii) and grant WPGM such other and further relief to which it may be justly entitled, both at law

and equity. 

Dated: April 23, 2024 Respectfully submitted, 

/s/ Jason M. Rudd 

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 

Email: jason.rudd@wickphillips.com 

 paul.elkins@wickphillips.com 

COUNSEL FOR DEFENDANT JAMES 

FRINZI 

Case 23-03090-mvl Doc 23 Filed 04/23/24 Entered 04/23/24 15:58:06 Desc Main

Document Page 2 of 6
3 

CERTIFICATE OF CONFERENCE 

Local Bankruptcy Rule 7007-1, I hereby certify that on April 18, 2024, I conferred by 

phone with Davor Rukavina, Counsel for Scott Seidel, Chapter 7 Trustee and Plaintiff. The 

Trustee does not oppose this Motion. 

/s/ Jason M. Rudd 

Jason M. Rudd 

CERTIFICATE OF SERVICE 

 I hereby certify that on April 23, 2024, I electronically filed the foregoing with the clerk of 

the court using the CM/ECF system and have served a copy of the same to the following parties 

or their counsel via the method(s) indicated below: 

Davor Rukavina 

Thomas D. Berghman 

MUNSCH HARDT KOPF & HARR, P.C. 

3800 Ross Tower 

500 N. Akard Street 

Dallas, TX 75201 

Counsel for the Scott Seidel, 

Chapter 7 Trustee 

 Hand Delivery 

 Regular Mail 

 Facsimile 

 E-mail 

 X CM/ECF 

James Frinzi 

3736 Bee Cave Road, Suite 1164 

Austin, Texas 78746 

James@frinzi.net 

 Hand Delivery 

 X Regular Mail 

 Facsimile 

 X E-mail 

 CM/ECF 

/s/ Jason M. Rudd 

Jason M. Rudd 

Case 23-03090-mvl Doc 23 Filed 04/23/24 Entered 04/23/24 15:58:06 Desc Main

Document Page 3 of 6
EXHIBIT A 

Proposed Order 

Case 23-03090-mvl Doc 23 Filed 04/23/24 Entered 04/23/24 15:58:06 Desc Main

Document Page 4 of 6
1 

IN THE UNITED STATES BANKRUPCTY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

GOODMAN NETWORKS, INC. 

 Debtor. 

§ 

§ 

§ 

§ 

§ 

§ 

Case No. 22-31641-mv-7 

(Chapter 7) 

SCOTT M. SIEDEL, TRUSTEE 

 Plaintiff, 

v. 

HUDSON CLEAN ENERGY 

ENTERPRISES, LLC, ALLIANCE TEXAS 

HOLDINGS, LLC; NEIL Z. AUERBACH, 

JUDITH AUERBACH, AUERBACH 

PARTNERS, L.P, JAMES GOODMAN, 

JAMES FRINZI, GOODMAN 

INVESTMENT HOLDINGS, LLC, 

GENESIS NETWORKS, INC., GENESIS 

NETWORKS GLOBAL SERVICES, LLC, 

AUERBACH CHILDREN’S DYNASTY 

TRUST U/A/D OCTOBER 9, 2012, and 

AUERBACH FAMILY DYNASTY TRUST 

U/A/D OCTOBER 9, 2012, 

 Defendant(s). 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

ADVERSARY PROCEEDING 

NO: 23-03090-mvl 

ORDER GRANTING UNOPPOSED MOTION TO WITHDRAW AS COUNSEL OF RECORD

Case 23-03090-mvl Doc 23 Filed 04/23/24 Entered 04/23/24 15:58:06 Desc Main

Document Page 5 of 6
2 

Came on consideration the Unopposed Motion to Withdraw as Counsel, filed by Wick 

Phillips Gould & Martin, LLP (“WPGM”), in the above-captioned case. The Court finds that 

proper notice of the Motion has been provided and good cause exists to permit WPGM to withdraw 

as counsel for Defendant James Frinzi (“Mr. Frinzi”). Therefore, it is hereby: 

ORDERED that the Motion is GRANTED; it is further 

ORDERED that the Clerk of this Court and all parties are directed to remove WPGM as 

counsel for Mr. Frinzi on the docket and any applicable service list, including the Court’s CM/ECF 

electronic notification list, maintained in the Bankruptcy Case. 

ORDERED Mr. Frinzi may be contacted as follows: 3736 Bee Cave Road, Suite 1164 

Austin, Texas 78746, James@frinzi.net. 

# # # END OF ORDER # # # 

PREPARED AND SUBMITTED BY: 

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, Texas 75204 

Telephone: (214) 692-6200 

Facsimile: (214) 692-6255 

jason.rudd@wickphillips.com 

paul.elkins@wickphillips.com 

Case 23-03090-mvl Doc 23 Filed 04/23/24 Entered 04/23/24 15:58:06 Desc Main

Document Page 6 of 6