JORDAN, LYNCH & CANCIENNE PLLC

Michael Cancienne (SBN 24055256) 

Joseph W. Golinkin II (SBN 24087596) 

1980 Post Oak Blvd., Ste. 2300

Houston, Texas 77056

Telephone: 713.955.4028

Counsel for 18920 NW 11th, LLC

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

SCOTT M. SEIDEL, TRUSTEE; and 

GNET ATC, LLC

Plaintiffs, 

v.

18920 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. 

23-3072-mvl

18920 NW 11TH, LLC’S ANSWER TO 

PLAINTIFFS’ ORIGINAL COMPLAINT

18920 NW 11th, LLC (“18920”) submit its Answer Plaintiffs’ Original 

Complaint. Except as otherwise expressly admitted, 18920 denies each and every 

allegation contained in Plaintiffs’ Original Complaint.

INTRODUCTION

1. 18920 denies the allegations contained in Paragraph 1.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 1 of 15
2 

2. 18920 denies the allegations contained in Paragraph 2.

3. 18920 denies 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, 

18920 denies any allegations contained in Paragraph 4. 

PROCEDURAL BACKGROUND

5. Upon information and belief, 18920 admits the allegations contained in 

Paragraph 5.

6. Upon information and belief, 18920 admits the allegations contained in 

Paragraph 6.

7. Upon information and belief, 18920 admits 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 18920 contains the Trustee’s consent to entry of a final 

judgment, and therefore is likewise not an allegation that 18920 can admit or deny.

To the extent a response is deemed to be required for Paragraph 8, 18920 denies the 

allegations contained in Paragraph 8.

9. Paragraph 9 consists of a legal conclusion, to which 18920 is not 

required to admit or deny. To the extent a response is deemed to be required, 18920

responds that upon information and belief, it believes that venue is proper.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 2 of 15
3 

PARTIES

10. Upon information and belief, 18920 admits 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 18920 can admit or deny, and 18920 lacks sufficient 

information to admit or deny this statement in any event. 

11. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 11 and, therefore, denies those 

allegations.

12. 18920 admits the allegations contained in Paragraph 12.

13. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 13 and, therefore, denies those 

allegations.

14. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 14 and, therefore, denies those 

allegations.

15. 18920 admits the allegations contained in Paragraph 15.

16. 18920 admits the allegations contained in Paragraph 16.

17. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 17 and, therefore, denies those 

allegations.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 3 of 15
4 

18. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 18 and, therefore, denies those 

allegations.

19. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 19 and, therefore, denies those 

allegations.

“Facts”

20. Upon information and belief, 18920 admits that Frinzi was the Chief 

Executive Officer of the Debtor at the relevant times described in the complaint.

Frinzi’s fiduciary obligations to the Debtor is a legal question, and therefore is not an 

allegation to which 18920 can respond. To the extent a response is deemed required, 

18920 denies the assertion. 

21. Upon information and belief, 18920 admits that Frinzi was the Chief 

Executive Officer of GNET at the relevant times described in the complaint. Frinzi’s 

fiduciary obligations to the Debtor and GNET is a legal question, and therefore is not 

an allegation to which 18920 can respond. To the extent a response is deemed 

required, 18920 denies the assertion.

22. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 22 and, therefore, denies those 

allegations.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 4 of 15
5

23. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 23 and, therefore, denies those 

allegations.

24. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 24 and, therefore, denies those 

allegations.

25. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 25 and, therefore, denies those 

allegations.

26. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 26 and, therefore, denies those 

allegations.

27. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 27 and, therefore, denies those 

allegations.

28. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 28 and, therefore, denies those 

allegations.

29. 18920 admits the allegations contained in Paragraph 29.

30. 18920 admits the allegations contained in Paragraph 30.

31. 18290 denies the allegations contained in Paragraph 31.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 5 of 15
6

32. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 32 and, therefore, denies those 

allegations.

33. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 33 and, therefore, denies those 

allegations.

34. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 34 and, therefore, denies those 

allegations.

35. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 35 and, therefore, denies those 

allegations.

36. 18920 lacks knowledge or information sufficient to form a belief as to 

the truth of the allegations contained in Paragraph 36 and therefore denies the 

allegations. The Third Amended and Restated Certificate of Formation is a written 

document whose terms speak for itself.

37. 18920 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 denies this allegation. Otherwise, 18920 denies the allegations 

contained in Paragraph 37.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 6 of 15
7

38. 18920 admits the allegations contained in Paragraph 38.

39. 18920 lack knowledge or information sufficient to form a belief as to the 

truth of the allegations contained in Paragraph 39 and, therefore, denies those 

allegations.

40. 18920 admits 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. 18920 denies that “18920 was identified by 

Zakharyayev as the entity that would purchase the Transaction Shares” because the 

allegation is incoherent. Finally, 18920 lacks knowledge or information to form a 

belief as to the truth about who identified Zakharyayev 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 

18920 denies those allegations.

41. Paragraph 41 does not identify which “various of other Defendants” it is 

referring to, but to the extent Paragraph 41 purports to allege that 18920 

“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,” 18920 denies those allegations as well as the remainder of the 

allegations contained in Paragraph 41.

42. 18920 admits the allegations contained in Paragraph 42.

43. 18920 admits the allegations contained in Paragraph 43.

44. 18920 admits the allegations contained in Paragraph 44.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 7 of 15
8

45. 18920 admits the allegations contained in Paragraph 45.

46. 18290 admits the allegations contained in Paragraph 46.

47. 18290 denies the allegations contained in Paragraph 47.

48. 18290 admits the allegations contained in Paragraph 48.

49. 18920 admits the allegations contained in Paragraph 49.

50. 18290 admits that it agreed to settle 18920’s redemption demand in 

exchange for the $50 Million Note. 18290 denies that Frinzi had the corporate 

authority to bind the Debtor to the $50 Million Note. 18920 does not know what 

Trustee has or has not been provided or is or is not aware of, and therefore denies the 

remainder of the allegations in Paragraph 50.

51. 18920 admits that on March 10, 2022, 18920 and Debtor executed the 

Settlement Agreement. 18920 denies the remainder of the allegations contained in 

Paragraph 51.

52. 18920 admits that the Settlement Agreement states that 18920 holds 

the $50 Million Note. 18290 denies that the Settlement Agreement “had not been 

signed.”

53. The Settlement Agreement is a written document whose terms speaks 

for itself. To the extent Paragraph 53 contains factual allegations, 18920 admits it 

entered into the Settlement Agreement.

54. 18920 admits the allegations contained in Paragraph 54.

55. 18920 admits the allegations contained in Paragraph 55.

56. 18920 admits the allegations contained in Paragraph 56.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 8 of 15
9

57. 18290 admits the allegations contained in Paragraph 57.

58. 18290 denies the allegations contained in Paragraph 58.

59. 18920 denies the allegations contained in Paragraph 59.

60. 18920 denies the allegations contained in Paragraph 60.

61. 18920 admits 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,” but lacks sufficient 

knowledge to either admit or deny whether Frinzi controlled this company. 18920 

denies the remainder of the allegations contained in Paragraph 61.

62. 18290 admits it paid the Goodman Entities $10 million but denies the 

remainder of the allegations contained in Paragraph 62.

63. 18920 cannot either admit or deny the allegations contained in 

Paragraph 63 because the nature of the allegations are not clear, therefore, denied.

64. 18920 denies the allegations contained in Paragraph 64.

65. 18920 lack knowledge or information sufficient to form a belief as to the 

truth of the allegations contained in Paragraph 65.

66. 18290 denies that Debtor was insolvent.18920 lack knowledge or 

information sufficient to form a belief as to the truth of the remaining allegations 

contained in Paragraph 66.

67. 18920 lack knowledge or information sufficient to form a belief as to the 

truth of the allegations contained in Paragraph 67.

68. 18920 denies the allegations contained in Paragraph 68.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 9 of 15
10

69. 18290 denies the allegations contained in Paragraph 69.

70. 18920 admits the allegations contained in Paragraph 70.

71. 18290 denies the allegations contained in Paragraph 71.

72. 18920 denies the allegations contained in Paragraph 72.

73. 18920 denies the allegations contained in Paragraph 73.

74. 18920 denies the allegations contained in Paragraph 74.

75. 18920 denies the allegations contained in Paragraph 75.

76. 18290 denies the allegations contained Paragraph 76.

77. 18920 denies the allegations contained in Paragraph 77.

78. 18290 denies the allegations contained in Paragraph 78.

79. 18290 denies the allegations contained in Paragraph 79.

80. 18290 denies the allegations contained in Paragraph 80.

81. 18290 denies the allegations contained in Paragraph 81.\ 

CAUSES OF ACTION

Count I

82. 18290 denies the allegations contained in Paragraph 82.

83. 18290 denies the allegations contained in Paragraph 83.

84. 18290 denies the allegations contained in Paragraph 84.

85. 18290 denies the allegations contained in Paragraph 85.

86. 18290 denies the allegations contained in Paragraph 86.

87. 18290 denies the allegations contained in Paragraph 87.

88. 18290 denies the allegations contained in Paragraph 88.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 10 of 15
11

Count II

89. 18290 denies the allegations contained in Paragraph 89.

90. 18290 denies the allegations contained in Paragraph 90.

91. 18290 denies the allegations contained in Paragraph 91.

92. 18290 denies the allegations contained in Paragraph 92.

93. 18290 denies the allegations contained in Paragraph 93.

94. 18290 denies the allegations contained in Paragraph 94.

95. 18290 denies the allegations contained in Paragraph 95.

96. 18290 denies the allegations contained in Paragraph 96.

97. 18290 denies the allegations contained in Paragraph 97.

98. 18290 denies the allegations contained in Paragraph 98.

Count III

99. 18290 denies the allegations contained in Paragraph 99.

100. 18290 denies the allegations contained in Paragraph 100.

101. 18290 denies the allegations contained in Paragraph 101.

102. 18290 denies the allegations contained in Paragraph 102.

103. 18290 denies the allegations contained in Paragraph 103.

104. 18290 denies the allegations contained in Paragraph 104.

105. 18290 denies the allegations contained in Paragraph 105.

106. 18290 denies the allegations contained in Paragraph 106.

Count IV

107. 18290 denies the allegations contained in Paragraph 107.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 11 of 15
12

108. 18290 denies the allegations contained in Paragraph 108.

109. 18290 denies the allegations contained in Paragraph 109.

110. 18290 denies the allegations contained in Paragraph 110.

111. 18290 denies the allegations contained in Paragraph 111.

112. 18290 denies the allegations contained in Paragraph 112.

Count V1

113. 18290 denies the allegations contained in Paragraph 113.

114. 18290 denies the allegations contained in Paragraph 114.

115. 18290 denies the allegations contained in Paragraph 115.

116. 18290 denies the allegations contained in Paragraph 116.

117. 18290 denies the allegations contained in Paragraph 117.

118. 18290 denies the allegations contained in Paragraph 118.

Count VI2

119. 18290 denies the allegations contained in Paragraph 119.

120. 18290 denies the allegations contained in Paragraph 120.

121. 18290 denies the allegations contained in Paragraph 121.

122. 18290 denies the allegations contained in Paragraph 122.

123. 18290 denies the allegations contained in Paragraph 123.

Count VII

124. 18290 denies the allegations contained in Paragraph 124.

125. 18290 denies the allegations contained in Paragraph 125.

1 Although this claim does not directly impact 18920, it denies the allegations in abundance of caution.

2 Although this claim does not directly impact 18920, it denies the allegations in abundance of caution.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 12 of 15
13

126. 18290 denies the allegations contained in Paragraph 126.

127. 18290 denies the allegations contained in Paragraph 127.

128. 18290 denies the allegations contained in Paragraph 128.

129. 18290 denies the allegations contained in Paragraph 129.

130. 18290 denies the allegations contained in Paragraph 130.

Count VIII

131. 18290 denies the allegations contained in Paragraph 131.

132. 18290 denies the allegations contained in Paragraph 132.

133. 18290 denies the allegations contained in Paragraph 133

134. 18290 denies the allegations contained in Paragraph 134.

135. 18290 denies the allegations contained in Paragraph 135.

136. 18290 denies the allegations contained in Paragraph 136.

137. 18290 denies the allegations contained in Paragraph 137.

138. 18290 denies the allegations contained in Paragraph 138.

139. 18290 denies the allegations contained in Paragraph 139.

140. 18290 denies the allegations contained in Paragraph 140.

Count IX

141. 18290 denies the allegations contained in Paragraph 141.

142. 18290 denies the allegations contained in Paragraph 142.

143. 18290 denies the allegations contained in Paragraph 143.

144. 18290 denies the allegations contained in Paragraph 144.

145. 18290 denies the allegations contained in Paragraph 145.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 13 of 15
14

18920’s AFFIRMATIVE AND OTHER DEFENSES

1. Plaintiffs have failed to state a claim against 18920 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. 18920 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 18920 Defendants reserve the right to plead additional defenses as 

may be appropriate depending upon facts later revealed during discovery.

18920’S REQUESTS FOR RELIEF

WHEREFORE, 18920 prays that Plaintiffs’ claims be dismissed, and that this 

Court award 18920 their costs and reasonable attorneys’ fees in defending against 

Plaintiffs’ claims, and award such other and further relief to which 18920 may be 

justly entitled.

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 14 of 15
15

DEMAND FOR JURY TRIAL

18920 hereby demands 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 18920 NW 11th, LLC

CERTIFICATE OF SERVICE

I hereby certify that on this 21st day of September, 2023, 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

Case 23-03072-mvl Doc 6 Filed 09/21/23 Entered 09/21/23 17:18:02 Desc Main

Document Page 15 of 15