TRUSTEE’S MOTION TO COMPEL UNIFIED FIELD SERVICES, INC. 

TO RESPOND TO REQUESTS FOR PRODUCTION AND INTERROGATORIES —Page 1

Davor Rukavina, Esq.

Texas Bar No. 24030781

Thomas D. Berghman, Esq.

Texas Bar No. 24082683

Conor P. White, Esq.

Texas Bar No. 24125722

MUNSCH HARDT KOPF & HARR, P.C.

500 N. Akard Street, Suite 3800

Dallas, Texas 75201-6659

Telephone: (214) 855-7500

Facsimile: (214) 855-7584

ATTORNEYS FOR 

SCOTT M. SEIDEL, TRUSTEE

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION

In re: §

§ Case No. 22-31641-mvl-7

GOODMAN NETWORKS, INC., §

§ (Chapter 7)

Debtor. §

§

§

SCOTT M. SEIDEL, TRUSTEE, §

§

Plaintiff, § ADVERSARY PROCEEDING

§ NO. 23-03088-mvl

v. §

§

UNIFIED FIELD SERVICES, INC., §

§

Defendant. §

TRUSTEE’S MOTION TO COMPEL UNIFIED FIELD SERVICES, INC. TO RESPOND 

TO REQUESTS FOR PRODUCTION AND INTERROGATORIES 

TO THE HONORABLE MICHELLE V. LARSON, U.S. BANKRUPTCY JUDGE:

COMES NOW Scott M. Seidel (the “Trustee”), the duly-appointed chapter 7 trustee for 

Goodman Networks, Inc. (the “Debtor”), debtor in the above-styled and numbered chapter 7 

bankruptcy case (the “Bankruptcy Case”), and the Debtor’s estate (the “Estate”), and files this 

Motion to Compel Unified Field Services, Inc. to Respond to Requests for Production and 

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TRUSTEE’S MOTION TO COMPEL UNIFIED FIELD SERVICES, INC. 

TO RESPOND TO REQUESTS FOR PRODUCTION AND INTERROGATORIES —Page 2

Interrogatories (the “Motion”) against Unified Field Services, Inc. (“UFS”), the judgment debtor 

in the above styled and numbered adversary proceeding (the “Adversary Proceeding”), 

respectfully showing as follows:

I. RELIEF REQUESTED

1. The Trustee properly served post-judgment discovery on UFS seeking information 

relevant to assist the Trustee in collecting and liquidating his Judgment against UFS. UFS initially 

defaulted on the RFPs and, after multiple conferences and a limited production, UFS remains in 

default of the RFPs. UFS has not answered the Interrogatories at all. All this is of critical 

importance to the Trustee, not only for the obvious reason that he seeks to collect on the Judgment, 

but also because he has no idea what happened to UFS who, until very recently, seemed to be a 

business with a going concern. Given the history of fraudulent transfers that predominate the 

Debtor’s Bankruptcy Case, it is critical for the Trustee to discover what happened to UFS and to 

its business as soon as reasonably possible. Accordingly, by this Motion, the Trustee seeks an 

order from this court compelling UFS to produce all documents responsive to the RFPs without 

objection, and to fully answer the Interrogatories, within seven (7) days of the entry of such order.

II. BACKGROUND

2. On or about June 4, 2021, the Debtor sold certain of its e-commerce servicing assets 

to UFS. To assist in the transition of the sale and based on the service-related nature of the assets, 

UFS and the Debtor entered into a transition services agreement (the “TSA”) whereby the Debtor 

would continue to provide services on behalf of UFS, and which obligated UFS to repay the Debtor 

for the services provided. UFS shares an insider with the Debtor, namely James Goodman 

(“Goodman”). Ultimately, the UFS failed to repay the Debtor for its services under the TSA, 

leaving UFS obligated to the Debtor in an amount of $5,986,897.60 (the “Receivable”).

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TRUSTEE’S MOTION TO COMPEL UNIFIED FIELD SERVICES, INC. 

TO RESPOND TO REQUESTS FOR PRODUCTION AND INTERROGATORIES —Page 3

3. The Trustee filed his Original Complaint [Adv. Docket 1] against UFS seeking 

recovery of the Receivable on November 1, 2023, thereby initiating this Adversary Proceeding. 

On December 1, 2023, UFS entered its Defendant Unified Field Services, Inc.’s Answer and 

Consent to Entry of Judgment (the “Answer”) [Adv. Docket 5] whereby UFS consented to entry 

of judgment for the full value of the Receivable. 

4. The Court entered final judgment in the Adversary Proceeding on January 10, 2024, 

granting judgment for the Trustee for the full amount of the Receivable in addition to reasonable 

and necessary attorney’s fees and costs and post-judgment interest. [Adv. Docket 8] (the 

“Judgment”). 

5. On January 29, 2024, the Trustee served his First Set of Post-Judgment Requests 

for Production to Unified Field Services, Inc. (the “RFPs”) and his First Set of Post-Judgment 

Interrogatories to Unified Field Services, Inc. (the “Interrogatories”) upon counsel of record for 

UFS via both email and U.S. first-class mail, postage prepaid. A true and correct copy of the RFPs 

and Interrogatories are attached hereto as Exhibit “A”. The foregoing included a disclosure that 

any and all responses were to be received by counsel for the Trustee no later than 30 days after 

service of the same, which would place the response deadline on February 28, 2024.

6. UFS failed to provide any response to the RFPs, to produce any documents in 

response to the RFPs, or to answer any of the Interrogatories, by said deadline.

7. Thereafter, the Trustee transmitted that certain Demand for Cure of Discovery 

Deficiency (the “Deficiency Letter”) upon UFS via email and U.S. first-class mail, postage prepaid, 

on March 4, 2024. A true and correct copy of the Deficiency Letter is attached hereto as Exhibit 

“B”. The Deficiency Letter informed UFS of its defaults and further notified UFS of potential 

relief from this Court if no response was received by March 8, 2024. UFS responded to the 

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TRUSTEE’S MOTION TO COMPEL UNIFIED FIELD SERVICES, INC. 

TO RESPOND TO REQUESTS FOR PRODUCTION AND INTERROGATORIES —Page 4

Deficiency Letter on March 5, 2024. On March 6, 2024, UFS provided a production to the Trustee 

including the Debtor’s insurance policies, corporate documents, certain known litigation, 

unaudited income statements and balance sheets for 2021-2023, and certain of the Debtor’s bank 

statements (the “Initial Production”). 

8. The total document count received by counsel for the Trustee in the Initial 

Production was 71 documents. Counsel for UFS, on a phone call with counsel for the Trustee, 

requested additional time to assess whether production of all responsive emails would be 

necessary. Counsel for the Trustee obliged, but reserved all rights to pursue production. No other 

documents responsive to the RFPs were produced, and no written answers to the Interrogatories 

were served. 

9. Counsel for the Trustee advised counsel for UFS on March 7, 2024, that certain 

documents were missing from the Initial Production. On March 8, 2024, counsel for UFS 

responded with certain information helpful to contextualize the deficiency, but indicated that 

further information was necessary and that information would be confirmed. Counsel for the 

Trustee requested an update on this information on March 20, 2024 via email, and again by phone 

on March 28, 2024. No response has been received from counsel for UFS since the March 8, 2024 

email response. A true and correct copy of this email exchange is attached hereto as Exhibit “C”.

10. Accordingly, as UFS has failed to either comply with the response deadline 

imposed by the Federal Rules of Civil Procedure or remedy the identified deficiencies informally, 

request is now made for this Court to compel production of the requested documents and 

interrogatory answers. 

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TRUSTEE’S MOTION TO COMPEL UNIFIED FIELD SERVICES, INC. 

TO RESPOND TO REQUESTS FOR PRODUCTION AND INTERROGATORIES —Page 5

III. DISCUSSION

11. Rule 69 of the Federal Rules of Civil Procedure, as made applicable to the 

Adversary Proceeding by Rule 7069 of the Federal Rules of Bankruptcy Procedure, provides in 

relevant part that, in “aid of the judgment or execution, the judgment creditor... may obtain 

discovery from any person—including the judgment debtor—as provided in these rules or by the 

procedure of the state where the court is located.” FED. R. CIV. P. 69(a)(2). Rule 26 of the Federal 

Rules of Civil Procedure further provides that a party may obtain discovery regarding “any 

nonprivileged matter” related to the claims or defenses. See FED. R. CIV. P. 26(b)(1). Rule 34 of 

the Federal Rules of Civil Procedure provides that a party must respond, in writing, to a request 

for production within 30 days after being served. See FED. R. CIV. P. 34(b)(2)(A). The same 

deadline applies to interrogatories. See FED. R. CIV. P. 33(b)(2).

12. Absent certain limited exceptions, when a party “fails to object timely to 

interrogatories, production requests, or other discovery efforts, objections thereto are waived.” In 

re United States, 864 F.2d 1153, 1156 (5th Cir. 1989). “The scope of postjudgment discovery is 

very broad to permit a judgment creditor to discover assets upon which execution may be made.” 

JP Morgan Chase Bank, N.A. v. DataTreasury Corp., 936 F.3d 251, 256 (5th Cir. 2019) (quoting 

FDIC v. LeGrand, 43 F.3d 163, 172 (5th Cir. 1995)). 

13. Bankruptcy courts retain jurisdiction to enforce their own judgments. See In re 

Offshore Financial Corp., 319 B.R. 845, 847 (Bankr. N.D. Tex. 2005) (citing Celotex Corp. v. 

Edwards, 514 U.S. 300 (1995); United States v. Revie, 834 F.2d 1198, 1205 (5th Cir. 1987)). 

Compelling a judgment debtor who has failed to respond to post-judgment requests for discovery 

furthers the purpose of Rule 69: enforcement of a judgment. See Butters-Fetting Co., Inc. v. 

O’Connor, 2023 WL 2825700, at *1 (N.D. Tex. January 19, 2023).

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TRUSTEE’S MOTION TO COMPEL UNIFIED FIELD SERVICES, INC. 

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14. Here, UFS failed to timely respond to the RFPs—in fact, it has not responded to 

them in writing at all—and it has not produced nearly the whole of the documents responsive to 

the RFPs. UFS has failed wholly to respond to the Interrogatories. As a result, any objections that 

UFS could have raised in response thereto have been waived by operation of law. 

15. It has been over a month since the deadline to respond to the Trustee’s discovery 

has expired. While multiple efforts were made to resolve the default and deficiencies informally, 

UFS has since gone silent on further attempts to resolve these issues. As a result of UFS’s defaults 

in responding to the Trustee’s discovery and subsequent lack of responsiveness to informal efforts 

to bridge the gap, the Trustee now seeks an order from the Court compelling production of all 

documents responsive to the RFPs and answers to the Interrogatories.

16. Rule 37 of the Federal Rules of Civil Procedure, as incorporated into this Adversary 

Proceeding, provides that “a party may move for an order compelling disclosure or discovery.” 

FED. R. CIV. P. 37(a)(1). There can be no question here that the Trustee has conferred with UFS 

on multiple occasions regarding this matter, and that he has attempted to obtain the information 

that he is entitled to from UFS without the need to involve this Court, as contemplated by the Rule. 

The Rule expressly permits the Court to enter an “order compelling an answer, designation, 

production, or inspection,” including when “a party fails to answer an interrogatory submitted 

under Rule 33” or when “a party fails to produce documents or fails to respond that inspection will 

be permitted—or fails to permit inspection—as requested under Rule 34.” FED. R. CIV. P. 

37(a)(3)(B).

17. UFS is an entity owned and controlled by Goodman, like so many of the parties 

involved in both this Bankruptcy Case and affiliated adversary proceedings. The Debtor now 

holds a money judgment against UFS in an amount of nearly six million dollars. Given the nature 

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TRUSTEE’S MOTION TO COMPEL UNIFIED FIELD SERVICES, INC. 

TO RESPOND TO REQUESTS FOR PRODUCTION AND INTERROGATORIES —Page 7

of UFS’s business and the involvement of Goodman, not only are documents and communications 

evidencing UFS’s financial health relevant to any potential recovery on the Receivable, so too are 

documents and communications evidencing and discussing transfers between UFS and other 

parties. To point out the obvious: the Debtor sold a valuable business line to UFS less than three 

(3) years ago, UFS failed to pay, and, only two (2) years later, UFS was apparently out of business. 

Where did the business the Debtor sold go, and where did UFS’s own business go, not to mention 

its cash? Not only does the history of fraudulent transfers in the Bankruptcy Case give rise to 

heightened suspicion and scrutiny here, but UFS’s blatant discovery defaults do as well, especially 

when no reason or explanation for the defaults is offered. 

18. By way of example, Interrogatory No. 1 requires UFS to identify all of its bank 

accounts. That is obviously critical information, and should be easy to respond to. Interrogatory 

No. 2 seeks an accounting of assets. Interrogatory No. 7 requires information regarding any 

transfers. Interrogatory No. 8 seeks information related to who UFS’ directors and officers were. 

Interrogatory No. 14 requires basic information regarding whether UFS has any business 

operations and, if not, what happened to them. These and all of the Trustee’s requests are proper, 

reasonable, and necessary for the Trustee to seek to collect on the Judgment, including to enable 

him to learn of potential third parties that he may have claims against on account of the Judgment.

19. Accordingly, the Trustee requests that the Court enter an order compelling UFS to 

produce all documents responsive to the RFPs and to otherwise respond to the same, and provide 

answers to the Interrogatories, no later than seven (7) days after the entry of an order on this 

Motion, which is more than sufficient time given that it has been more than two (2) months since 

the Trustee served his RFPs and his Interrogatories. 

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TRUSTEE’S MOTION TO COMPEL UNIFIED FIELD SERVICES, INC. 

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20. Finally, the Trustee reserves all of his rights to seek an award of his reasonable 

attorney’s fees and expenses incurred on this matter and through this Motion, pursuant to separate 

motion if and when appropriate.

IV. PRAYER

WHEREFORE, PREMISES CONSIDERED, the Trustee respectfully requests that the 

Court enter an order: (i) granting this Motion; (ii) compelling UFS to respond to the RFPs and 

produce all documents in its possession, custody, or control responsive thereto no later than seven 

(7) days after the entry of said order; (iii) compelling UFS to fully answer and verify the 

Interrogatories no later than seven (7) days after the entry of said order; (iv) providing that such 

order will be enforced through contempt; and (v) granting the Trustee such other and further relief 

to which he may be justly entitled.

RESPECTFULLY SUBMITTED this 2nd day of April, 2024.

MUNSCH HARDT KOPF & HARR, P.C.

By: /s/ Conor White

Davor Rukavina, Esq.

Texas Bar No. 24030781

Thomas D. Berghman, Esq.

Texas Bar No. 24082683

Conor P. White, Esq.

Texas Bar No. 24125722

500 N. Akard Street, Suite 3800

Dallas, Texas 75201-6659

Telephone: (214) 855-7500

Facsimile: (214) 855-7584

E-mail: drukavina@munsch.com

 tberghman@munsch.com

cwhite@munsch.com

ATTORNEYS FOR 

SCOTT M. SEIDEL, TRUSTEE

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TRUSTEE’S MOTION TO COMPEL UNIFIED FIELD SERVICES, INC. 

TO RESPOND TO REQUESTS FOR PRODUCTION AND INTERROGATORIES —Page 9

CERTIFICATE OF CONFERENCE

The undersigned hereby certifies that on has attempted to confer multiple times, as outlined 

in the Motion, in good faith to resolve the issues underlying the relief requested herein without the 

need for Court intervention. As a result of these efforts, many deficiencies remain, and since 

March 8, 2024, no further response has been received.

By: /s/ Conor White

Conor P. White, Esq.

CERTIFICATE OF SERVICE

The undersigned hereby certifies that, on this the 2nd day of April, 2024, he caused a true 

and correct copy of this document to be served upon Randall A. Pulman, counsel of record for 

UFS, at rpulman@pulmanlaw.com, and served by U.S. first class mail, postage prepaid, on the 

following:

Unified Field Services

Attn: Randall Pulman; Leslie Sara Hyman; Anna K. MacFarlane

Pulman, Cappuccio & Pullen, LLP

2161 NW Militray Highway, Suite 400

San Antonio, Texas 78213

By: /s/ Conor White

Conor P. White, Esq.

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