1 

4868-8560-7917, v. 1

Randall A. Pulman 

State Bar No. 16393250 

Anna K. MacFarlane 

State Bar No. 24116701 

PULMAN, CAPPUCCIO & PULLEN, LLP 

2161 NW Military Hwy., Suite 400 

San Antonio, Texas 78213 

Telephone: (210) 222-9494 

Facsimile: (210) 892-1610 

rpulman@pulmanlaw.com 

amacfarlane@pulmanlaw.com 

COUNSEL FOR THE GOODMAN DEFENDANTS 

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

IN RE: 

GOODMAN NETWORKS, INC., 

DEBTOR. 

§ 

§ 

§ 

§ 

CASE NO. 22-31641-MVL-7 

 

CHAPTER 7 

SCOTT M. SEIDEL, TRUSTEE, AND

GNET ATC, LLC, 

PLAINTIFFS

V. 

18920 NW 11TH, LLC; ET AL.

DEFENDANTS

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

ADVERSARY NO. 23-03072-MVL

JAMES GOODMAN’S, PEOPLE NQ, INC.’S, JJC & PEOPLE, LLC’S, AND 

GDMN FAMILY INVESTMENTS 2, LLC’S WITNESS AND EXHIBIT LIST 

FOR OCTOBER 9, 2024 HEARING ON

TRUSTEE’S MOTION TO COMPEL WRITTEN DISCOVERY RESPONSES AND PRODUCTION OF 

DOCUMENTS FROM JAMES GOODMAN, GDMN FAMILY INVESTMENTS 2, LLC, PEOPLE NQ,

INC., AND JJC & PEOPLE, LLC [ECF NO. 67] 

COME NOW Defendants James Goodman, (“J.E. Goodman”1), People NQ, Inc. (“People 

NQ”), JJC & People, LLC (“JJC”) and GDMN Family Investments 2, LLC (“GDMN” and 

1

 James Goodman’s full name is James E. Goodman, Jr. Because Mr. Goodman has brothers who were 

involved with the Debtor and whose first names also start with the letter “J”, for the sake of clarity the 

Goodman Defendants refer to James Goodman as J.E. Goodman herein. 

Case 23-03072-mvl Doc 83 Filed 10/08/24 Entered 10/08/24 16:18:55 Desc Main

Document Page 1 of 3
 2 

4868-8560-7917, v. 1

together with J.E. Goodman, People NQ, and JJC, “Goodman Defendants”) and file this, their 

Witness and Exhibit List for the hearing on October 9, 2024 on the following matter: 

MATTERS TO BE HEARD: 

Trustee’s Motion to Compel Written Discovery Responses and Production of Documents from 

James Goodman, GDMN Family Investments, LLC, People NQ, Inc., and JJC & People, LLC 

[Dkt. No. 67], and 

Goodman Defendants’ Response to Trustee’s Motion to Compel Written Discovery Responses 

and Production of Documents from James Goodman, GDMN Family Investments, LLC, People 

NQ, Inc., and JJC & People, LLC [Dkt. No. 81] 

GOODMAN DEFENDANTS’ WITNESSES: 

Goodman Defendants designate the following witnesses: 

1. Anna MacFarlane; 

2. Any witness called or designated by any other party; 

3. Any rebuttal or impeachment witnesses, as necessary; and 

4. Any person present at the hearing. 

Goodman Defendants reserve the right to amend or supplement this list at any time prior to the 

hearing. 

GOODMAN DEFENDANTS’ EXHIBITS 

Goodman Defendants’ Exhibits are marked with a “G” 

Ex. # Description Offered Objection Admitted/ 

Not 

Admitted 

Disposition 

G-1 James Goodman’s Amended 

Responses to Trustee’s First 

Interrogatories 

 

G-2 James Goodman’s Amended 

Responses to Trustee’s First 

Requests for Production 

 

G-3 People NQ, Inc.’s Amended 

Responses to Trustee’s First 

Interrogatories 

 

G-4 People NQ Inc.’s Amended 

Responses to Trustee’s First 

Interrogatories 

 

G-5 JJC and People, LLC’s Amended 

Responses to Trustee’s First 

Requests for Production 

 

Case 23-03072-mvl Doc 83 Filed 10/08/24 Entered 10/08/24 16:18:55 Desc Main

Document Page 2 of 3
 3 

4868-8560-7917, v. 1

G-6 GDMN Family Investment 2, 

LLC’s Amended Responses to 

Trustee’s First Interrogatories 

 

G-7 GDMN Family Investment 2’s 

Amended Responses to Trustee’s 

First Interrogatories 

 

 Any exhibits designated by any 

other party

 

 Any rebuttal or impeachment 

exhibits 

 

Goodman Defendants reserve the right to amend or supplement this list at any time prior to the 

hearing. 

 

Dated October 8, 2024 Respectfully submitted, 

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/ Randall A. Pulman

Randall A. Pulman

Texas State Bar No. 16393250

rpulman@pulmanlaw.com

Anna K. MacFarlane

Texas State Bar No. 24116701

amacfarlane@pulmanlaw.com 

ATTORNEYS FOR JAMES E. GOODMAN,

PEOPLE NQ, INC., JJC & PEOPLE, LLC, AND 

GDMN FAMILY INVESTMENTS 2, LLC 

CERTIFICATE OF SERVICE

I hereby certify that on this 8th day of October, 2024, the foregoing was electronically filed 

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/ Randall A. Pulman 

Randall A. Pulman 

Case 23-03072-mvl Doc 83 Filed 10/08/24 Entered 10/08/24 16:18:55 Desc Main

Document Page 3 of 3