Daniel W. Van Horn, Admitted Pro Hac 

Adam M. Langley, Admitted Pro Hac

R. Campbell Hillyer, Admitted Pro Hac

Butler Snow LLP 

6075 Poplar Ave., Ste. 500 

Memphis, TN 38119 

(901) 680-7200 

Martin A. Sosland, TX Bar No. 18855645 

Candice Carson, TX Bar No. 24074006 

Butler Snow LLP 

2911 Turtle Creek Blvd., Ste. 1400 

Dallas, TX 75219 

(469) 680-5502 

Attorneys for FedEx Supply Chain Logistics & Electronics, Inc. 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: ) 

 ) 

GOODMAN NETWORKS, INC., ) Case No. 23-31641-mvl-7 

 ) 

 Debtor. ) (Chapter 7) 

 ) 

 

SCOTT M. SEIDEL, TRUSTEE, ) 

 ) 

 Plaintiff, ) Adversary Proceeding 

 ) No. 23-03091 

v. ) 

 ) 

FEDEX SUPPLY CHAIN LOGISTICS ) 

& ELECTRONICS, INC., ) 

 ) 

 Defendant. ) 

FEDEX SUPPLY CHAIN LOGISTICS & ELECTRONICS, INC.’S 

CONSENT MOTION FOR LEAVE TO FILE BRIEFS 

IN EXCESS OF PAGE LIMITS SET L.B.R 7007-2(C) 

Case 23-03091-mvl Doc 14 Filed 01/09/24 Entered 01/09/24 16:57:53 Desc Main

Document Page 1 of 4
1. Comes now FedEx Supply Chain Logistics & Electronics, Inc.’s (“FSCLE”) and 

pursuant to L.B.R. 7007-2(c) moves for the Court for an order granting FSCLE and the Trustee 

leave to file briefs in excess of the twenty-five (25) page limit set forth in L.B.R. 7007-2(c). 

2. As grounds for this motion, FSCLE would show the Court that the Trustee has 

filed a motion for preliminary injunction with a forty (40) page brief in support thereof and 

FSCLE intends to file a motion to dismiss the Trustee’s adversary complaint. FSCLE seeks 

leave to file a brief of the same length already filed by the Trustee on the issue of the preliminary 

injunction, to file a brief of the same length in support of its motion to dismiss and for leave for 

the Trustee to file a principal reply brief in opposition to FSCLE’s motion to dismiss that is also 

forty (40) total pages in length. 

3. The legal issues raised by the Trustee and FSCLE are complex. These motions 

are more akin to a summary judgment than an ordinary bankruptcy motion. The page limits for a 

summary judgment under the local rules is fifty (50) pages. L.B.R. 7056-1(e)(2). Because these 

motions are closer to summary judgment motions than ordinary motions, FSCLE and the Trustee 

both seek leave to file briefs of an intermediate length – forty (40) total pages. 

4. In support of this motion, FSCLE relies upon its memorandum of law filed 

herewith, the fact and length of the Trustee’s brief in support of his motion for preliminary 

injunction, its lawsuit filed in the Northern District of Texas and all the pleadings in this 

adversary proceeding. 

5. FSCLE further states that after consultation with counsel for the Trustee that this 

motion is unopposed and is in fact by consent. 

Case 23-03091-mvl Doc 14 Filed 01/09/24 Entered 01/09/24 16:57:53 Desc Main

Document Page 2 of 4
6. WHEREFORE, for good cause shown, FSCLE moves for leave for both the 

Trustee and FSCLE to be granted leave to file principal briefs on the Trustee’s motion for 

preliminary injunction and FSCLE’s motion to dismiss that are forty (40) total pages. 

Dated: January 10, 2024 

Respectfully submitted, 

BUTLER SNOW LLP 

s/ Danny Van Horn 

Adam M. Langley (admitted pro hac vice) 

R. Campbell Hillyer (admitted pro hac vice) 

Danny Van Horn (admitted pro hac vice) 

6075 Poplar Avenue, Suite 500 

Memphis, TN 38119 

Telephone: (901) 680-7316 

adam.langley@butlersnow.com

cam.hillyer@butlersnow.com 

danny.vanhorn@butlersnow.com

and 

Candice Carson (TX Bar No. 24074006) 

Martin A. Sosland (TX Bar No. 18855645) 

2911 Turtle Creek Blvd., Suite 1400 

Dallas, Texas 75219 

Telephone: (469) 680-5502 

candice.carson@butlersnow.com 

martin.sosland@butlersnow.com 

Counsel for FedEx Supply Chain 

Logistics & Electronics, Inc. 

Certificate of Consultation of Counsel

 Prior to filing this motion, counsel for FSCLE (Danny Van Horn) consulted with counsel 

for the Trustee (Joshua Shepherd) on January 5, 8 and 9. As a result of those discussions, 

FSCLE can report that this motion is not opposed and is consented to by the Trustee. 

 

s/ Danny Van Horn 

Case 23-03091-mvl Doc 14 Filed 01/09/24 Entered 01/09/24 16:57:53 Desc Main

Document Page 3 of 4
Certificate of Service 

 I hereby certify that a true and correct copy of the foregoing document was served 

concurrently with the filing of the same via the Court’s CM/ECF electronic filing system upon 

all persons who have filed ECF appearances in this case and via email to Trustee’s Counsel: 

Michael J. Quilling, Esq. 

(Texas Bar No. 16432300) 

Joshua L. Shepherd, Esq. 

(Texas Bar No. 24058104) 

QUILLING, SELANDER, LOWNDS, 

 WINSLETT & MOSER, P.C. 

2001 Bryan Street, Ste. 1800 

Dallas, TX 75201 

(214) 871-2100 

mquilling@qslwm.com 

jshepherd@qslwm.com 

 s/ Danny Van Horn 

85269400.v1 

Case 23-03091-mvl Doc 14 Filed 01/09/24 Entered 01/09/24 16:57:53 Desc Main

Document Page 4 of 4