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4882-0882-5538, v. 1 / 6514.011

Randall A. Pulman 

State Bar No. 16393250 

Anna K. MacFarlane 

State Bar No. 24116701 

PULMAN CAPPUCCIO & PULLEN, LLP

2161 NW Military Hwy., Suite 400 

San Antonio, Texas 78213 

Telephone: (210) 222-9494 

Facsimile: (210) 892-1610 

rpulman@pulmanlaw.com 

amacfarlane@pulmanlaw.com 

COUNSEL FOR JAMES GOODMAN AND 

GENESIS NETWORKS GLOBAL SERVICES, LLC 

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

IN RE: 

GOODMAN NETWORKS, INC., 

DEBTOR. 

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CASE NO. 22-31641-MVL-7 

 

CHAPTER 7 

SCOTT M. SEIDEL, TRUSTEE, AND 

GNET ATC, LLC, 

 

PLAINTIFFS

V. 

GENESIS NETWORKS GLOBAL

SERVICES, LLC; AND JAMES GOODMAN

DEFENDANTS

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ADVERSARY NO. 24-03022 

DEFENDANTS JAMES GOODMAN’S AND GENESIS NETWORKS GLOBAL SERVICES, LLC’S 

ANSWER TO TRUSTEE’S ORIGINAL COMPLAINT

COME NOW Defendants James Goodman (“Goodman”) and Genesis Networks Global 

Services, LLC (“Genesis Global,” and, collectively with Goodman, the “Goodman Defendants”) 

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and file this, their Answer to Trustee’s Original Complaint [Adv. Dkt. No. 1] (the “Complaint”) 

responding to the paragraphs of the Complaint as numbered therein. 

I. PROCEDURAL BACKGROUND

1. Goodman Defendants admit the allegations in Paragraph 1. 

2. Goodman Defendants admit the allegations in Paragraph 2. 

3. Goodman Defendants admit the allegations in Paragraph 3. 

4. Goodman Defendants admit that the Court has jurisdiction over this adversary 

proceeding. Goodman Defendants lack sufficient knowledge to admit or deny the remaining 

allegations in Paragraph 4. Goodman Defendants do not consent to the entry of final orders in this 

adversary proceeding. 

5. Goodman Defendants admit that venue is proper in this Court. 

II. PARTIES

6. Goodman Defendants admit the allegations in Paragraph 6. 

7. Goodman Defendants admit the allegations in Paragraph 7. 

8. Goodman Defendants admit the allegations in Paragraph 8. 

III. FACTS

9. Goodman Defendants admit the allegations in Paragraph 9. 

10. Goodman Defendants admit the allegations in Paragraph 10. 

11. Goodman Defendants admit the allegations in Paragraph 11. 

12. Goodman Defendants admit the allegations in Paragraph 12. 

13. Goodman Defendants admit the allegations in Paragraph 13. 

14. Goodman Defendants admit the allegations in Paragraph 14. 

15. Goodman Defendants admit the allegations in Paragraph 15. 

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16. Goodman Defendants admit the allegations in Paragraph 16. 

17. Goodman Defendants admit the allegations in Paragraph 17. 

18. Goodman Defendants admit the allegations in Paragraph 18. 

19. Goodman Defendants admit the allegations in Paragraph 19. 

20. Goodman Defendants lack sufficient knowledge to admit or deny the allegations 

in Paragraph 20 regarding John Goodman. Goodman Defendants admit the remaining allegations 

in Paragraph 20 regarding James Goodman. 

21. Goodman Defendants admit the allegations in Paragraph 21. 

22. Goodman Defendants admit the allegations in Paragraph 22. 

23. Goodman Defendants admit the allegations in Paragraph 23. 

24. Goodman Defendants admit the allegations in Paragraph 24. 

25. Goodman Defendants lack sufficient knowledge to admit or deny the allegations 

in Paragraph 25. 

26. Goodman Defendants lack sufficient knowledge to admit or deny the allegations 

in Paragraph 26. 

27. Goodman Defendants lack sufficient knowledge to admit or deny the allegations 

in Paragraph 27. 

28. The allegations in Paragraph 28 constitute a legal conclusion to which no 

response is necessary. 

29. The allegations in Paragraph 29 constitute a legal conclusion to which no 

response is necessary. 

30. Goodman Defendants admit the allegations in Paragraph 30. 

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31. Goodman Defendants deny the allegations in the first sentence of Paragraph 31. 

Goodman Defendants lack sufficient knowledge to admit or deny the remaining allegations in 

Paragraph 31. 

32. Goodman Defendants deny the allegations in Paragraph 32. 

33. Goodman Defendants lack sufficient knowledge to admit or deny the allegations 

in Paragraph 33. 

34. Goodman Defendants lack sufficient knowledge to admit or deny the allegations 

in Paragraph 34. 

35. Goodman Defendants lack sufficient knowledge to admit or deny the allegations in 

Paragraph 35. 

36. Goodman Defendants deny the allegations in Paragraph 36. 

37. Goodman Defendants deny the allegations in Paragraph 37. 

38. Goodman Defendants deny the allegations in Paragraph 38. 

39. Goodman Defendants deny the allegations in Paragraph 39. 

IV. CAUSES OF ACTION

COUNT 1: CONSTRUCTIVELY FRAUDULENT TRANSFERS/PAYMENTS AS AGAINST GENESIS 

GLOBAL

40. Goodman Defendants incorporate their responses to paragraphs 1 through 39 as if 

fully set forth herein. 

41. Goodman Defendants deny the allegations in Paragraph 41. 

42. Goodman Defendants lack sufficient knowledge to admit or deny the allegations in 

Paragraph 42. 

43. Goodman Defendants lack sufficient knowledge to admit or deny the allegations in 

Paragraph 43. 

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44. Goodman Defendants lack sufficient knowledge to admit or deny the allegations in 

Paragraph 44. 

45. Goodman Defendants admit the allegations in Paragraph 45. 

46. Goodman Defendants admit that the Trustee seeks the relief described in 

Paragraph 46 but denies that the Trustee is entitled to obtain any relief or judgment against the 

Goodman Defendants as pled or otherwise. 

47. Goodman Defendants admit that the Trustee seeks the relief described in 

Paragraph 47 but denies that the Trustee is entitled to obtain any relief or judgment against the 

Goodman Defendants as pled or otherwise. 

COUNT 2: CONSTRUCTIVELY FRAUDULENT TRANSFERS/PAYMENTS AS AGAINST GENESIS 

GLOBAL (TUFTA) 

48. Goodman Defendants incorporate their responses to paragraphs 1 through 47 as if 

fully set forth herein. 

49. Goodman Defendants lack sufficient knowledge to admit or deny the allegations in 

Paragraph 49. 

50. Goodman Defendants lack sufficient knowledge to admit or deny the allegations in 

Paragraph 50. 

51. Goodman Defendants deny the allegations in Paragraph 51. 

52. Goodman Defendants deny the allegations in the first sentence of Paragraph 52. 

Goodman Defendants lack sufficient knowledge to admit or deny the remaining allegations in 

Paragraph 52. 

53. Goodman Defendants admit that Prosperity is the transferee of the Payments. 

Goodman Defendants deny the remaining allegations in the remaining sentences of Paragraph 53. 

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54. Goodman Defendants admit that the Trustee seeks the relief described in 

Paragraph 54 but denies that the Trustee is entitled to obtain any relief or judgment against the 

Goodman Defendants as pled or otherwise. 

55. Goodman Defendants deny that the Trustee is entitled to recover his costs and 

attorneys’ fees. 

COUNT 3: RECOVERY OF FRAUDULENT TRANSFERS AS AGAINST GENESIS GLOBAL

56. Goodman Defendants incorporate their responses to paragraphs 1 through 55 as if 

fully set forth herein. 

57. Goodman Defendants admit that the Trustee seeks the relief described in 

Paragraph 57 but denies that the Trustee is entitled to obtain any relief or judgment against the 

Goodman Defendants as pled or otherwise. 

COUNT 4: BREACH OF FIDUCIARY DUTY AS AGAINST JAMES GOODMAN

58. Goodman Defendants incorporate their responses to paragraphs 1 through 57 as if 

fully set forth herein. 

59. Goodman Defendants admit the allegations in Paragraph 59. 

60. Goodman Defendants deny the allegations in Paragraph 60. 

61. Goodman Defendants deny the allegations in Paragraph 61. 

62. Goodman Defendants deny the allegations in Paragraph 62. 

63. Goodman Defendants deny the allegations in Paragraph 63. 

64. Goodman Defendants admit that the Trustee seeks the relief described in 

Paragraph 64 but denies that the Trustee is entitled to obtain any relief or judgment against the 

Goodman Defendants as pled or otherwise. 

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V. DEFENSES

1. Goodman Defendants are entitled to credit and setoff. 

2. Goodman Defendants received the complained-of transfers for value and in good 

faith and without relevant knowledge of the avoidability of the transfers. 

3. Goodman Defendants were mediate or subsequent transferees who took in good 

faith from an initial transferee. 

4. Goodman Defendants plead proportionate responsibility under Chapter 33 of the 

Texas Civil Practice and Remedies Code. 

5. Goodman Defendants plead the affirmative defense of payment. 

6. Goodman Defendants plead the single recovery rule-the Trustee has already 

recovered some or all of the subject transfers from other parties. 

7. The transfers were made in the ordinary course of business. 

VI. JURY DEMAND

Goodman Defendants demand a trial by jury on all claims to which they are entitled to a 

Jury. 

VII. PRAYER

Goodman Defendants deny any allegations in Trustee’s Original Complaint that are not 

specifically admitted above and deny that Trustee is entitled to obtain any relief or judgment 

against Goodman Defendants as pled or otherwise. 

Dated May 31, 2024 

 

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Respectfully submitted, 

PULMAN, CAPPUCCIO & PULLEN, LLP 

2161 NW Military Highway, Suite 400 

San Antonio, Texas 78213 

www.pulmanlaw.com

(210) 222-9494 Telephone 

(210) 892-1610 Facsimile 

By: /s/ Randall A. Pulman 

Randall A. Pulman 

Texas State Bar No. 16393250 

rpulman@pulmanlaw.com

Anna K. MacFarlane 

Texas State Bar No. 24116701 

amacfarlane@pulmanlaw.com 

ATTORNEYS FOR DEFENDANTS JAMES GOODMAN 

AND GENESIS NETWORKS GLOBAL SERVICES, LLC 

 

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CERTIFICATE OF SERVICE

The undersigned certifies that on May 31, 2024, the foregoing will be electronically mailed 

to the parties that are registered or otherwise entitled to receive electronic notices in this case 

pursuant to the Electronic Filing Procedures in this District, including the following: 

Via CM/ECF drukavina@munsch.com, 

tberghman@munsch.com, cwhite@munsch.com 

Davor Rukavina 

Thomas D. Berghman 

Conor P. White 

Munsch, Hardt, Kopf & Harr 

500 N. Akard Street, Ste 3800 

Dallas, TX 75201-6659 

Counsel for Scott Seidel, Trustee 

/s/ Randall A. Pulman 

Randall A. Pulman 

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