STIPULATION AND AGREED ORDER OF DISMISSAL OF FRINZI FAMILY TRUST—Page 1 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

GOODMAN NETWORKS, INC., 

 Debtor. 

SCOTT M. SEIDEL, TRUSTEE; 

GNET ATC, LLC; MULTIBAND 

FIELD SERVICES, INC., 

 Plaintiffs, 

v. 

JAMES FRINZI; FRINZI FAMILY TRUST; 

MULTIBAND GLOBAL RESOURCES, 

LLC, 

 Defendants. 

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Case No. 22-31641-mvl-7 

(Chapter 7) 

ADVERSARY PROCEEDING 

NO: 23-03036 

STIPULATION AND AGREED ORDER OF DISMISSAL 

OF FRINZI FAMILY TRUST 

I. STIPULATION 

 Scott M. Seidel (the “Trustee”), for himself and for GNET ATC, LLC and Multiband Field 

Services, Inc., the plaintiffs in the above styled and numbered Adversary Proceeding, and Frinzi 

Family Trust (the “FFT,”, with the Trustee, each a “Party” and together the “Parties”), hereby 

stipulate and agree as follows: 

1. The Parties are parties to that certain Limited Settlement and Release Agreement 

(the “Agreement”). 

2. On June 25, 2024, in the above-referenced Bankruptcy Case at docket no. 580, the 

Court entered its order approving the Agreement, which order has since become final and nonappealable. 

Case 23-03036-mvl Doc 78 Filed 07/16/24 Entered 07/16/24 14:11:53 Desc Main

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STIPULATION AND AGREED ORDER OF DISMISSAL OF FRINZI FAMILY TRUST—Page 2 

3. All conditions precedent to the effectiveness of the Agreement have occurred. 

4. Pursuant to the Agreement, the Parties have agreed to dismiss the FFT from this 

Adversary Proceeding with prejudice, but subject to all rights and obligations in the Agreement. 

5. Accordingly, the Parties hereby stipulate to the dismissal with prejudice of the FFT 

from this Adversary Proceeding, each reserving such rights and obligations as otherwise provided 

for in the Agreement, and with each Party bearing its respective fees and expenses incurred herein. 

II. ORDER 

The Court, having reviewed the above Stipulation, and incorporating its definitions into 

this Order, and finding that the Agreement has been approved pursuant to Bankruptcy Rule 9019 

and that no further notice regarding the Stipulation is required or is appropriate, and otherwise 

finding the Stipulation to be lawful and appropriate, it is hereby: 

ORDERED that all claims and causes of action asserted against the FFT in this Adversary 

Proceeding are hereby DISMISSED WITH PREJUDICE and that this Adversary Proceeding is 

otherwise dismissed with prejudice as against the FFT, with each Party bearing its respective fees 

and costs incurred herein; it is further 

ORDERED that, for the avoidance of doubt, this Order is wholly without prejudice to all 

rights, obligations, and remedies under the Agreement, and to all issues between the Trustee and 

any other defendant in this Adversary Proceeding, all of the Trustee’s claims and causes of action 

against such other defendants being preserved and not affected by the Agreement or by this Order. 

# # # END OF ORDER # # # 

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STIPULATION AND AGREED ORDER OF DISMISSAL OF FRINZI FAMILY TRUST—Page 3 

AGREED AS TO SUBSTANCE AND FORM: 

MUNSCH HARDT KOPF & HARR P.C. 

/s/ Davor Rukavina 

Davor Rukavina, Esq. 

Texas Bar No. 24030781 

500 North Akard St., Ste. 3800 

Dallas, Texas 75201 

Telephone: (214) 855-7500 

drukavina@munsch.com

ATTORNEYS FOR THE PLAINTIFFS 

/s/ Jason M. Rudd (w/ permission) 

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 

COUNSEL FOR DEFENDANTS

4887-8432-2255v.1 013229.00016 

Case 23-03036-mvl Doc 78 Filed 07/16/24 Entered 07/16/24 14:11:53 Desc Main

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