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 

MEMORANDUM IN SUPPORT OF 

CONSENT MOTION FOR LEAVE TO FILE BRIEFS 

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

Case 23-03091-mvl Doc 15 Filed 01/09/24 Entered 01/09/24 16:59:32 Desc Main

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

for its memorandum in support of its Consent Motion for Leave to File Briefs In Excess of the 

Page Limits Set forth in L.B.R. 7007-2(c) states as follows: 

2. On November 21, 2023, the Trustee filed his motion for a preliminary injunction 

[Dkt. #4] and his memorandum in support thereof. [Dkt. #5]. Trustee’s memo was forty total 

pages in length with approximately 33-34 pages of legal argument. The page limit for summary 

judgment motions under the local rules is fifty (50) pages. L.B.R. 7056-1(e)(2). Whereas, the 

page limit for all other motions is twenty-five (25) pages. Trustee’s motion is neither a motion 

for summary judgment nor an ordinary motion. The Trustee’s motion and memo would 

effectively act as a dispositive motion against FSCLE if granted. 

3. The arguments contained therein cover a variety of subjects including extensive 

briefing on jurisdiction, the question of whether the claims asserted by FSCLE in its lawsuit 

pending in the Northern District of Texas belong to FSCLE or the bankruptcy estate and the 

question of any possible stay violation. 

4. FSCLE does not take any issue with the length of the Trustee’s brief. However, 

in fairness, FSCLE asks for the same length brief to address the issues raised by the Trustee and 

to advance FSCLE positions. The gravity of what is at stake cannot be overstated for either the 

Trustee or FSCLE. These are serious issues, involving complex legal arguments with tens of 

millions at stake. 

5. In addition to filing a motion for a preliminary injunction [Dkt. #4], the Trustee 

also filed an adversary complaint against FSCLE [Dkt. #1]. FSCLE is now responding to that 

complaint with both an answer and a motion to dismiss the Trustee’s adversary complaint. 

FSCLE is filing both an answer and a motion to dismiss because in the interests of judicial 

Case 23-03091-mvl Doc 15 Filed 01/09/24 Entered 01/09/24 16:59:32 Desc Main

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efficiency and to reach a resolution of these disputes, the parties have agreed to an expeditated 

trial date. It is unlikely that FSCLE’s motion to dismiss or the Trustee’s motion for a 

preliminary injunction will be heard prior to the trial date. FSCLE believes that there are 

significant jurisdictional issues which preclude the relief sought by the Trustee and that the 

Trustee’s adversary complaint is not ripe. The Trustee undoubtedly disputes those positions just 

as FSCLE disputes that a preliminary injunction may be granted. These are foundational 

questions that must be addressed at the outset of the trial. FSCLE has prepared a brief in support 

of its motion to dismiss that is similarly 40 total pages in length with 33-34 pages of legal 

argument. 

6. Subject to the Court’s approval, FSCLE and the Trustee have met and conferred 

and agree that it would be fair and provide a full opportunity for briefing before the Court for: 

(1) the Trustee’s memo in support of his motion for a preliminary injunction to be retroactively 

approved to be the length that it is; (2) for FSCLE to be granted leave to file a similar sized brief 

in opposition and (3) for both FSCLE and the Trustee to be granted leave to file briefs on 

FSCLE’s motion to dismiss that are 40 total pages in length with 33-34 pages of legal argument. 

7. 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 40 total pages with 33-34 pages 

of legal argument. 

Dated: January 10, 2024 

Respectfully submitted, 

BUTLER SNOW LLP 

s/ Danny Van Horn 

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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 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 

85266800.v1 

Case 23-03091-mvl Doc 15 Filed 01/09/24 Entered 01/09/24 16:59:32 Desc Main

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