JORDAN, LYNCH & CANCIENNE PLLC

Michael Cancienne (SBN 24055256)

Joseph W. Golinkin II (SBN 24087596)

Brittainie J. Zinsmeyer (SBN 24115981)

1980 Post Oak Blvd., Ste. 2300

Houston, Texas 77056

Telephone: 713.955.4025

Counsel for 18920 NW 11th LLC,

Steven Zakharyayev,

and Evelina Pinkhasova

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 NW 11th, LLC; JAMES 

GOODMAN; JAMES FRINZI; STEVEN 

ZAKHARYAYEV; EVELINA 

PINKHASOVA; PEOPLE NQ INC.; JJC 

& PEOPLE LLC; GDMN FAMILY 

INVESTMENTS 2, LLC,

Defendants.

Case No. 22-31641-mvl-7

Adversary Proceeding No. 

23-03072-mvl

DEFENDANT STEVEN ZAKHARYAYEV’S FIRST AMENDED OBJECTIONS AND 

RESPONSES TO TRUSTEE’S FIRST SET OF INTERROGATORIES

To: Trustee, Scott M. Seidel, by and through his attorneys of record, Davor Rukavina, Esq., 

Thomas D. Berghman, Esq., Julian P. Vasek, Esq., and Conor P. White, Esp., Munsch 

Hardt Kopf & Harr, P.C., 500 N. Akard Street, Suite 4000, Dallas, Texas 75201.

Steven Zakharyayev (“Zakharyayev”), Defendant in this Adversary Proceeding, 

hereby serves upon Scott M. Seidel (“Trustee”), Plaintiff in this Adversary Proceeding, this the 

Defendant Steven Zakharyayev’s First Amended Objections and Responses to Trustee’s First Set 

Trustee's

Exhibit 7

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of Interrogatories (the “Interrogatory Responses”) pursuant to Rule 33 of the Federal Rules of 

Civil Procedure as follows.

OBJECTIONS TO INSTRUCTIONS AND DEFINITIONS

1. Zakharyayev objects to the instructions and requests to the extent references to 

Zakharyayev or any other party or entity include that entity’s employees, officers, directors, agents, 

representatives, members, attorneys, departments, sections, affiliates, subsidiaries, parents, and all 

other persons acting on its behalf. To the extent a request references a particular entity, 

Zakharyayev intends to respond based solely on the entity itself, and not the laundry list of other 

agents, representatives, or other related entities listed.

2. Zakharyayev objects to the definition of the term “Document(s)” to the extent it 

exceeds the ordinary use of the term and that which is contemplated by Federal Rule of Civil 

Procedure 34 and in that it is overbroad as defined. Zakharyayev will therefore respond to these 

requests which reference or seek “Document(s)” in accordance with the ordinary use of the term 

and the Federal Rules of Civil Procedure.

3. Zakharyayev objects to the definition of “18920” to the extent it includes its present 

and former parents, subsidiaries, affiliates, agents, employees, representatives, assigns, attorneys, 

predecessors-in-interest, or all others acting on its behalf. Zakharyayev will respond to requests 

referencing “18920” as only the entity 18920 NW 11th, LLC.

4. Zakharyayev objects to the definition of “GDMN” to the extent it includes its 

present and former parents, subsidiaries, affiliates, agents, employees, representatives, assigns, 

attorneys, predecessors-in-interest, or all others acting on its behalf. Zakharyayev will respond to 

requests referencing “GDMN” as only the entity GDMN Family Investments 2, LLC.

5. Zakharyayev objects to the definition of “GDMN” to the extent it includes its 

present and former parents, subsidiaries, affiliates, agents, employees, representatives, assigns, 

attorneys, predecessors-in-interest, or all others acting on its behalf. Zakharyayev will respond to 

requests referencing “GDMN” as only the entity GDMN ATC, LLC.

6. Zakharyayev objects to the definition for “You” and “Your” as it includes responses 

on behalf of Zakharyayev’ s agents, assigns, attorneys, or others acting on his behalf. Zakharyayev 

will respond to requests referencing “You” or “Your” as referencing only himself.

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OBJECTIONS AND RESPONSES TO INTERROGATORIES

INTERROGATORY NO. 1. Identify each State and court (excluding admissions pro hac 

vice) in which You have ever been admitted to practice law. and the date of such admission, 

and, for each such jurisdiction, if You are no longer admitted to practice law therein, the date 

on which You ceased being admitted to practice law and the reason(s) why.

RESPONSE: Zakharyayev objects to this request as overbroad in that it fails to provide an 

applicable timeline and vague as to the information it seeks, and harassing. Zakharyayev also 

objects to this interrogatory as it seeks information that is not relevant nor reasonably 

calculated to lead to the discovery of admissible evidence. Subject to the foregoing, 

Zakharyayev is licensed to practice law in Florida (admitted October 30, 2010), New Jersey 

(admitted February 16, 2011) and in New York (admitted May 29, 2013). 

INTERROGATORY NO. 2. Has a formal disciplinary proceeding ever been commended 

against You in any jurisdiction You were ever admitted to practice law, including admissions 

pro hac vice, and, if so, identify the proceeding and the jurisdiction and state the results thereof.

RESPONSE: Zakharyayev objects to this request as overbroad in that it fails to state an 

applicable timeline or subject matter and is harassing. Zakharyayev also objects to this 

interrogatory as it seeks information that is not relevant nor reasonably calculated to lead to 

the discovery of admissible evidence. Subject to the foregoing objections, Zakharyayev has 

not been subject to formal disciplinary proceedings.

INTERROGATORY NO. 3. Explain what Your law practice has primarily consisted of 

since You were first licensed to practice law, including whether You believe You hold any 

expertise in any area of the law and, if so, what area, and whether Your practice has been 

primarily transaction or litigation, or a mix thereof.

RESPONSE: Zakharyayev objects to this request as overbroad in that it fails to state an 

applicable timeline. Zakharyayev also objects to this interrogatory as it seeks information that 

is not relevant nor reasonably calculated to lead to the discovery of admissible evidence. 

Subject to the foregoing, Zakharyayev’s experience includes Real Estate Transactions, 

Creditors’ Rights, and Litigation. 

INTERROGATORY NO. 4. Have You ever been sued? If so, identify the court and 

proceeding number for each such proceeding.

RESPONSE: Zakharyayev objects to this request as overbroad in that it does not specify a 

relevant timeframe nor subject matter for the lawsuits it seeks to discover. Zakharyayev also 

objects to this interrogatory as it seeks information that is not relevant nor reasonably 

calculated to lead to the discovery of admissible evidence.

INTERROGATORY NO. 5. Have You ever been charged with or indicted for a crime, 

except non-alcohol related driving offenses, or have you ever entered into any agreement with 

any prosecutor to avoid such charges or indictment? If so, provide the court and proceeding 

number for each such proceeding.

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RESPONSE: Zakharyayev objects to this request as overbroad as it fails to specify an 

applicable timeline or subject matter for the type of crime. Zakharyayev also objects to this 

interrogatory as it seeks information that is not relevant nor reasonably calculated to lead to 

the discovery of admissible evidence. Zakharyayev also objects to this request to the extent it 

exceeds the confines of Federal Rule of Evidence 609. Subject to the foregoing, none.

INTERROGATORY NO. 6. Explain the general nature of your relationships with Shalom 

Auerbach, including how long you have known him, how you met him, whether you are friends 

with him or his family, whether you are related as family members, whether you or he serve in 

any religious capacities to members of your families, and whether you have ever transacted 

any business with him, including as investors in the same business, being on the same board 

or management team of any business, or as a client of his or he as a client of Yours or any 

business affiliated with You.

RESPONSE: Zakharyayev objects to this request as overbroad as it fails to specify an 

applicable timeframe. Zakharyayev also objects to this interrogatory as it seeks information 

that is not relevant nor reasonably calculated to lead to the discovery of admissible evidence. 

Subject to the foregoing, Zakharyayev and Shalom Auerbach are friends that met in 2018. 

They are not related. They currently operate a collections business together and have made 

some small pre-IPO investments together. 

INTERROGATORY NO. 7. Explain the general nature of Your relationships with Frinzi, 

including how long you have known him, how you met him, whether you are friends with him 

or his family, whether you are related as family members, whether you or he serve in any 

religious capacities to members of your families, and whether you have ever transacted any 

business with him, including as investors in the same business, being on the same board or 

management team of any business, or as a client of his or he as a client of Yours or any business 

affiliated with You.

RESPONSE: Zakharyayev objects to this request as overbroad as it fails to specify an 

applicable timeframe. Zakharyayev also objects to this interrogatory as it seeks information 

that is not relevant nor reasonably calculated to lead to the discovery of admissible evidence. 

Subject to the foregoing, Zakharyayev met Frinzi sometime in 2021 or 2022 through Shalom 

Auerbach. Zakharyayev later helped Frinzi with some contract matters, but did not charge any 

fee or have a formal representative relationship.

INTERROGATORY NO. 8. Explain the general nature of Your relationships with Neil 

Auerbach, including how long you have known him, how you met him, whether you are friends 

with him or his family, whether you are related as family members, whether you or he serve in 

any religious capacities to members of your families, and whether you have ever transacted 

any business with him, including as investors in the same business, being on the same board 

or management team of any business, or as a client of his or he as a client of Yours or any 

business affiliated with You.

RESPONSE: Zakharyayev objects to this request as overbroad as it fails to specify an 

applicable timeframe. Zakharyayev also objects to this interrogatory as it seeks information 

that is not relevant nor reasonably calculated to lead to the discovery of admissible evidence. 

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Subject to the foregoing, Zakharyayev met Neil Auerbach through Shalom Auerbach sometime 

in 2019 or 2020, and has helped Neil Auerbach with some contract matters relating to Hudson 

Energy.

INTERROGATORY NO. 9. At the time of the Redemption Notice, who did You 

understand Frinzi to be with respect to the Debtor and GNET, including whether You 

understood him to be a director, officer, or manager of the Debtor and GNET?

RESPONSE: At the time of the Redemption Notice, it was presented to Zakharyayev that 

Frinzi was an officer and potentially a member of Debtor and GNET. 

INTERROGATORY NO. 10. At the time of the Redemption Notice, what was the factual 

basis for the statement in the Redemption Notice that "18920 NW 11th LLC, (the 

"Shareholder") is owner of 4,032,918 Series A-1 Preferred Shares" as of the date of the 

Redemption Notice? Your answer should address whether, by that date, 18920 had paid for the 

Transaction Shares, whether You believed that it needed to pay for the same in order to then 

own the same, why You may have believed that it need not have paid for the same in order to 

then own the same, and whether any steps had then been taken for 18920 to take any action to 

evidence its ownership of the Transaction Shares and what any such action would have been 

and whether and when it was taken.

RESPONSE: Zakharyayev objects to this request to the extent it seeks information protected 

from disclosure by the attorney client or work product doctrine. Zakharyayev also objects that 

this information is better obtained through 18920. See 18920 Obj. & Resp. to Trustee’s 1st 

Interrog. at Interrog. No. 8. The Share Purchase Agreements with the various Goodman 

entities entitled 18920 to the preferred shares which carried mandatory redemption rights. 

18290 initiated payments of $10 million to Goodman Networks around March 9 or 10, 2022. 

18920 recognized it needed to pay to purchase the shares consistent with the terms of the Share 

Purchase Agreement. As of the date of the Redemption Notice, the shares had not yet been 

paid for, but 18920 had an obligation to make such a payment. 

INTERROGATORY NO. 11. At the time of the execution of the Purchase Agreements, 

how did You believe or understand that 18920 paid, or would pay, for the Transaction Shares, 

and when it would do so or when it had done so?

RESPONSE: Zakharyayev objects to this request to the extent it seeks information protected 

from disclosure by the attorney client or work product doctrine. Zakharyayev also objects to 

this request as vague. Subject to the foregoing, 18920 had relationships with various investors 

and lenders.

INTERROGATORY NO. 12. At the time of the Redemption Notice, what was the factual 

basis for the statement in the Redemption Notice that the "Preferred Shares are subject to 

mandatory redemptions at their liquidation value on a quarterly basis?"

RESPONSE: Zakharyayev objects to this request to the extent it seeks information protected 

from disclosure by the attorney client or work product doctrine. Zakharyayev also objects that 

this information is better obtained through 18920. See 18920 Obj. & Resp. to Trustee’s 1st 

Interrog. at Interrog. No. 9. As a representative of 18920, Zakharyayev believed the governing 

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documents provided for the mandatory redemption at their liquidation value on a quarterly 

basis, as was indicated to him by other parties and as agreed by company. 

INTERROGATORY NO. 13. Explain what steps You took, including any due diligence 

You undertook, to review whether the "Preferred Shares are subject to mandatory redemptions 

at their liquidation value on a quarterly basis," as stated in the Redemption Notice, including 

by identifying any documents You reviewed or relied on to state the same. and including any 

communications You reviewed, made, had, were given, or You relied on, to state the same. 

Identify any such documents or communications in Your production to the Trustee's Requests 

for Production served concurrently herewith. 

RESPONSE: Zakharyayev objects to this request to the extent it seeks information protected 

from disclosure based on attorney client or work product privileges. Zakharyayev objects to 

this request as overbroad. Zakharyayev further objects that this information is more properly 

sought from 18920. See 18920 Obj. & Resp. to Trustee’s 1st Interrog. at Interrog. Nos. 9, 10.

As a representative for 18920, Zakharyayev had written and oral communications with Frinzi 

and Goodman, as well as their counsel from Winstead, and Anthony Rao, and reviewed 

documents provided relating to the operational structure of those entities and the rights of the 

holders of preferred shares. 

INTERROGATORY NO. 14. At the time of the Redemption Notice, did You believe or 

understand that the "Preferred Shares are subject to mandatory redemptions at their liquidation 

value on a quarterly basis," as stated therein, and, if You so believed, why did You so believe?

RESPONSE: Zakharyayev objects to this request to the extent it seeks information protected 

from disclosure based on attorney client or work product privileges. Zakharyayev further 

objects that this information is more properly sought from 18920. See 18920 Obj. & Resp. to 

Trustee’s 1st Interrog. at Interrog. Nos. 9, 10. Zakharyayev, as a representative of 18920, 

believed the preferred shares carried mandatory redemption rights based on written and oral 

communications with Frinzi and Goodman, as well as their counsel from Winstead, and 

Anthony Rao, and reviewed documents provided relating to the operational structure of those 

entities and the rights of the holders of preferred shares.

INTERROGATORY NO. 15. At the time of the Redemption Notice, what did You believe 

or understand was the “liquidation value [of Preferred Shares] on a quarterly basis” as stated 

in the Redemption Notice, and why?

RESPONSE: Zakharyayev objects to this request to the extent it seeks information protected 

from disclosure based on attorney client or work product privileges. Zakharyayev objects to 

this request as overbroad. Zakharyayev further objects that this information is more properly 

sought from 18920. See Steven Zakharyayev’s February 10, 2023 deposition testimony, given 

as 18920’s corporate representative, at 34:4–16, 37:16–38:5. As a representative for 18920, 

Zakharyayev believed the liquidation value was the amount referenced in the Redemption 

Agreement. 

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INTERROGATORY NO. 16. At the time of the Redemption Notice, did You believe or 

understand that the Debtor had the funds necessary to pay the "mandatory redemptions" as 

stated in the Redemption Notice and if so, why?

RESPONSE: Zakharyayev objects to this request to the extent it seeks information protected 

from disclosure based on attorney client or work product privileges. Zakharyayev further 

objects that this information is more properly sought from 18920. Subject to the foregoing, 

Frinzi represented the Debtor had necessary funds, particularly cash, assets in the amount of 

$75 million, and a $44 million note payable to the Debtor secured by the AMRR business, 

which would have been more than sufficient to allow 18920 to redeem on its preferred shares.

INTERROGATORY NO. 17. At the time of the execution of the Purchase Agreements, 

where and how did you believe that the funds that would be used by 18920 to pay for the 

Transaction Shares would ultimate [sic] come or originate from.

RESPONSE: Zakharyayev objects to this request to the extent it seeks information protected 

from disclosure by the attorney client or work product doctrine. Zakharyayev also objects to 

this request as vague and to the extent it is duplicative of Interrogatory No. 11. Subject to the 

foregoing, see Response to Interrogatory No. 11.

INTERROGATORY NO. 18. At the time of the Redemption Notice, did You have a belief 

or understanding as to the Debtor's solvency and, if so, state the factual basis for any such 

belief or understanding. As used herein, "solvency" means both that the assets of the Debtor 

exceeded its liabilities, including any debt payable on the Redemption Notice, and that the 

Debtor was paying its debts as they became due, including any debt payable on the Redemption 

Notice.

RESPONSE: Zakharyayev objects to this request to the extent it seeks information protected 

from disclosure based on attorney client or work product privileges. Zakharyayev objects to 

this request as overbroad. Zakharyayev further objects that this information is more properly 

sought from 18920. See Steven Zakharyayev’s February 10, 2023 deposition testimony, given 

as 18920’s corporate representative, at 71:4–16. As a representative for 18920, Zakharyayev

spoke with Frinzi, who was CEO of Goodman Networks, and through those conversations, it 

was represented that the company was not insolvent and there was sufficient cash to conduct 

the transaction. 

INTERROGATORY NO. 19. As of the date of the Settlement Agreement, what value did 

You believe or understand that 18920 gave to the Debtor for the Settlement Agreement or what 

the "value received" stated in the Promissory Note was?

RESPONSE: Zakharyayev objects to this request to the extent it seeks information protected 

from disclosure based on attorney client or work product privileges. Zakharyayev further 

objects that this information is more properly sought from 18920. See 18920 Obj. & Resp. to 

Trustee’s 1st Interrog. at Interrog. No. 15. As a representative for 18920, Zakharyayev is aware 

that 18920 paid $10 million for the preferred shares pursuant to the Share Purchase Agreements 

with the three Goodman entities

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INTERROGATORY NO. 20. As of the date of the Settlement Agreement, state the factual 

basis for Your belief or understanding in answer to Interrogatory No. 17.

RESPONSE: Zakharyayev objects that this request is vague in that it fails to state with 

specificity the information it seeks. Subject to the foregoing, see Response to Interrogatory 

No. 11.

INTERROGATORY NO. 21. Who negotiated the Settlement Agreement on behalf of 

18920, and who was it negotiated with on behalf of the Debtor?

RESPONSE: Zakharyayev objects that this information is more properly sought from 18920. 

Subject to the foregoing, Zakharyayev, as a representative and counsel for 18920, negotiated 

the Settlement Agreement with Goodman Networks, Inc. representatives Goodman and Frinzi, 

as well as counsel for Debtor.

INTERROGATORY NO. 22. Do You agree that. at the time of the execution of the 

Purchase Agreements, You already had an understanding or agreement, whether oral or 

written, with the Debtor, GNET. Frinzi, Goodman, or anyone else, that, in lieu of the Debtor 

paying the redemption demand the subject of the Redemption Notice, the Debtor would instead 

execute the Promissory Note and the Settlement Agreement and deliver to 18920 the 

consideration provided for in the Settlement Agreement? If so, who did You or 18920 have 

that understanding or agreement with, when did such understanding or agreement or agreement 

arise, and what to You was the purpose of any such understanding or agreement.

RESPONSE: Zakharyayev objects to this request to the extent it seeks information protected 

from disclosure based on attorney client or work product privileges. Zakharyayev further 

objects that this information is more properly sought from 18920. Subject to the foregoing, 

Zakharyayev does not agree. 

INTERROGATORY NO. 23. Explain the negotiations and the sequence of events that led 

to the negotiation, any execution of, and any performance under, the Promissory Note and the 

Settlement Agreement, including whose idea such documents originally was, why they were 

negotiated, why they were negotiated within one or two days of each other, and what the 

consideration for each of these documents was. and the persons involved in such negotiation, 

execution, and performance, including who any professional (whether attorney, accountant, or 

financial advisor) for any of the parties thereto was. 

RESPONSE: Zakharyayev objects to this request as it seeks information that is protected 

from disclosure by attorney client or work product privileges. Zakharyayev also objects that 

this request is unduly burdensome and better suited for other forms of discovery. Zakharyayev 

further objects that this information is more properly sought from 18920. Subject to the 

foregoing, see Steven Zakharyayev’s February 10, 2023 deposition testimony, given as 

18920’s corporate representative, at 34:4–52:17, 54:7–55:7, 58:12–60:4, 62:8–64:9. After 

executing the purchase of the Preferred Shares, 18920 became the owner of those shares and 

made a demand as to the mandatory redemption rights. Goodman Networks was essentially 

obligated to repurchase the shares at the liquidation value. This obligation led to the 

negotiation and execution of the Promissory Note and, thereafter, the Settlement Agreement. 

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Dated this 19th day of July, 2024.

JORDAN, LYNCH & CANCIENNE PLLC

By: s/ Michael Cancienne

Michael Cancienne

State Bar No. 24046330

Joseph (“Jeb”) W. Golinkin II

State Bar No. 24087596

Brittainie Zinsmeyer

State Bar No. 24115981

1980 Post Oak Blvd., Ste. 2300

Houston, Texas 77056

713-955-4020 (Telephone)

713-955-9644 (Fax)

mcancienne@jlcfirm.com

jgolinkin@jlcfirm.com

bzinsmeyer@jlcfirm.com

ATTORNEYS FOR 18920 NW 11th LLC, 

STEVEN ZAKHARYAYEV, AND EVELINA 

PINKASHOVA

CERTIFICATE OF SERVICE

I hereby certify that on this 19th day of July, 2024, I electronically served the 

foregoing to counsel of record.

/s/ Brittainie Zinsmeyer

Brittainie Zinsmeyer

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