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IN THE UNITED STATES BANKRUPCTY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

GOODMAN NETWORKS, INC. 

 Debtor. 

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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). 

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ADVERSARY PROCEEDING 

NO: 23-03090-mvl 

UNOPPOSED MOTION TO EXPEDITE HEARING MOTION TO

WITHDRAW AS COUNSEL OF RECORD 

Wick Phillips Gould & Martin, LLP (“WPGM”) respectfully states as follows in support 

of this request (the “Motion to Expedite”) for an expedited hearing: 

1. Concurrently herewith, WPGM filed its Unopposed Motion to Withdraw as 

Counsel of Record for Defendant James Frinzi (“Mr. Frinzi”) [ECF No. 23] (the “Motion to 

Withdraw”). 

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2. WPGM respectfully requests that the Court consider the Motion to Withdraw as 

soon as the Court’s schedule permits. 

3. WPGM estimates that a hearing on the Motion to Withdraw will last approximately 

15 minutes or less, absent objection. 

4. Undersigned counsel certifies that there is a true necessity for an expedited hearing 

and that WPGM did not create the need for an emergency hearing by a lack of diligence. 

5. If the Motion to Expedite is granted, WPGM will promptly file a notice of hearing, 

which will be served via-email where possible. 

WHEREFORE, WPGM respectfully requests that the Court enter an order substantially in 

the form attached hereto as Exhibit A, granting the relief herein and such other relief as the Court 

deems appropriate under the circumstances. 

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 

 

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CERTIFICATE OF CONFERENCE 

The undersigned hereby certifies that on April 19, 2024, he 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 

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EXHIBIT A 

Proposed Order 

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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). 

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ADVERSARY PROCEEDING 

NO: 23-03090-mvl 

ORDER GRANTING UNOPPOSED MOTION TO EXPEDITE HEARING 

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CAME ON FOR CONSIDERATION the request (the “Motion to Expedite”) for an 

expedited hearing on the Unopposed Motion to Withdraw as Counsel (the “Motion to Withdraw”), 

filed by Wick Phillips Gould & Martin, LLP. The Court finds that the Motion to Expedite should 

be granted as set forth below. 

It is therefore ORDERED that the Motion to Withdraw is scheduled for expedited hearing 

on the date and time listed above. 

# # # 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 24 Filed 04/23/24 Entered 04/23/24 16:00:12 Desc Main

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