1 

IN THE UNITED STATES BANKRUPCTY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

GOODMAN NETWORKS, INC. 

 Debtor. 

§ 

§ 

§ 

§ 

§ 

§ 

Case No. 22-31641-mv-7 

(Chapter 7) 

SCOTT M. SIEDEL, TRUSTEE; GNET 

ATC, LLC; MULTIBAND FIELD 

SERVICES, INC. 

 Plaintiff(s), 

v. 

JAMES FRINZI; FRINZI FAMILY TRUST, 

MULTIBAND GLOBAL RESOURCES, 

LLC, 

 Defendant(s). 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

ADVERSARY PROCEEDING 

NO: 23-03036-mvl 

WICK PHILLIPS’ WITNESS AND EXHIBIT LIST 

Wick Phillips Gould & Martin, LLP (“WPGM”) hereby files this Witness and Exhibit List 

in connection with the hearing scheduled for Wednesday May 1, 2024 at 9:30 a.m. before the 

Honorable Michelle V. Larson, United States Bankruptcy Court for the Northern District of Texas, 

1100 Commerce Street, 14th Floor, Courtroom No. 2, Dallas, Texas 75242. 

WITNESSES 

WPGM may call the following witnesses at the hearing, live or by declaration: 

1. Jason M. Rudd; 

2. All witnesses called by any other party; and 

3. Any witnesses necessary for rebuttal depending upon the witnesses and evidence 

presented by other parties. 

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 1 of 15
2 

EXHIBITS 

WPGM designates the following exhibits: 

No. Description Offered Objection Admitted 

1. Unopposed Motion to Withdraw as Counsel of 

Record [ECF No. 67] 

 

2. Notice of Hearing [ECF No. 69] 

WPGM reserves the right to use any exhibits presented by any other party. WPGM also 

reserves the right to use and present demonstratives for any purpose. WPGM also reserves the right 

to use exhibits, demonstratives, and testimony not listed here for impeachment or rebuttal purposes at 

the hearing. 

WPGM reserves the right to further supplement or amend this Witness and Exhibit List at 

any time prior to the hearing. 

Dated: April 26, 2024 Respectfully submitted, 

/s/ Jason M. Rudd 

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 

Email: jason.rudd@wickphillips.com 

 paul.elkins@wickphillips.com 

COUNSEL FOR DEFENDANTS JAMES 

FRINZI, FRINZI FAMILY TRUST, AND 

MULTIBAND GLOBAL RESOURCES, LLC 

 

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 2 of 15
3 

CERTIFICATE OF SERVICE 

 I hereby certify that on April 26, 2024, I electronically filed the foregoing with the clerk of 

the court using the CM/ECF system and have served a copy of the same to the following parties 

or their counsel via the method(s) indicated below: 

Davor Rukavina 

Thomas D. Berghman 

MUNSCH HARDT KOPF & HARR, P.C. 

3800 Ross Tower 

500 N. Akard Street 

Dallas, TX 75201 

Counsel for the Scott Seidel, Chapter 7 Trustee 

 Hand Delivery 

 Regular Mail 

 Facsimile 

 E-mail 

 X CM/ECF 

James Frinzi, Individually, 

Trustee of the Frinzi Family Trust, and as 

Manager of Multiband Global Resources, LLC 

3736 Bee Cave Road, Suite 1164 

Austin, Texas 78746 

James@frinzi.net 

 Hand Delivery 

 X Regular Mail 

 Facsimile 

 X E-mail 

 CM/ECF 

/s/ Jason M. Rudd 

Jason M. Rudd 

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 3 of 15
EXHIBIT 1

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 4 of 15
1 

IN THE UNITED STATES BANKRUPCTY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

GOODMAN NETWORKS, INC. 

 Debtor. 

§ 

§ 

§ 

§ 

§ 

§ 

Case No. 22-31641-mv-7 

(Chapter 7) 

SCOTT M. SIEDEL, TRUSTEE; GNET 

ATC, LLC; MULTIBAND FIELD 

SERVICES, INC. 

 Plaintiff(s), 

v. 

JAMES FRINZI; FRINZI FAMILY TRUST, 

MULTIBAND GLOBAL RESOURCES, 

LLC, 

 Defendant(s). 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

ADVERSARY PROCEEDING 

NO: 23-03036-mvl 

UNOPPOSED MOTION TO WITHDRAW AS COUNSEL OF RECORD 

Wick Phillips Gould & Martin, LLP (“WPGM”) files this Unopposed Motion to Withdraw 

as Counsel (the “Motion”) for Defendants James Frinzi, Frinzi Family Trust, and Multiband Global 

Resources, LLC (“Defendants”). 

1. WPGM seeks to withdraw from representing Defendants in this case. WPGM is

owed substantial fees under its engagement letter. 

2. Pursuant to Local Bankruptcy Rule 2091-1, Defendants agree to WPGM’s

withdrawal and executed this Motion below. Defendants have not retained successor counsel and 

the contact information is as follows: 

a. Name: Mr. James Frinzi

b. Address: 3736 Bee Cave Road, Suite 1164 Austin, Texas 78746

Case 23-03036-mvl Doc 67 Filed 04/23/24 Entered 04/23/24 16:03:18 Desc Main

Document Page 1 of 6

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 5 of 15
2 

c. Telephone Number: (202) 430-4500

3. This request to withdraw is not made for purposes of delay.

WHEREFORE, WPGM respectfully requests this Court to (i) grant the Motion (ii) enter 

the proposed order attached as Exhibit A to permit WPGM to withdraw as counsel to Defendants 

(iii) and grant WPGM such other and further relief to which it may be justly entitled, both at law

and equity. 

Dated: April 23, 2024 Respectfully submitted, 

/s/ Jason M. Rudd 

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 

Email: jason.rudd@wickphillips.com 

 paul.elkins@wickphillips.com 

COUNSEL FOR DEFENDANTS JAMES 

FRINZI, FRINZI FAMILY TRUST, AND 

MULTIBAND GLOBAL RESOURCES, LLC 

CERTIFICATE OF CONFERENCE 

Local Bankruptcy Rule 7007-1, I hereby certify that on April 18, 2024, I conferred by 

phone with Davor Rukavina, Counsel for Scott Seidel, Chapter 7 Trustee and Plaintiff. The 

Trustee does not oppose this Motion. 

/s/ Jason M. Rudd 

Jason M. Rudd 

Case 23-03036-mvl Doc 67 Filed 04/23/24 Entered 04/23/24 16:03:18 Desc Main

Document Page 2 of 6

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 6 of 15
3 

CERTIFICATE OF SERVICE 

 I hereby certify that on April 23, 2024, I electronically filed the foregoing with the clerk of 

the court using the CM/ECF system and have served a copy of the same to the following parties 

or their counsel via the method(s) indicated below: 

Davor Rukavina 

Thomas D. Berghman 

MUNSCH HARDT KOPF & HARR, P.C. 

3800 Ross Tower 

500 N. Akard Street 

Dallas, TX 75201 

Counsel for the Scott Seidel, Chapter 7 Trustee 

 Hand Delivery 

 Regular Mail 

 Facsimile 

 E-mail 

 X CM/ECF 

James Frinzi, Individually, 

Trustee of the Frinzi Family Trust, and as 

Manager of Multiband Global Resources, LLC 

3736 Bee Cave Road, Suite 1164 

Austin, Texas 78746 

James@frinzi.net 

 Hand Delivery 

 X Regular Mail 

 Facsimile 

 X E-mail 

 CM/ECF 

/s/ Jason M. Rudd 

Jason M. Rudd 

Case 23-03036-mvl Doc 67 Filed 04/23/24 Entered 04/23/24 16:03:18 Desc Main

Document Page 3 of 6

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 7 of 15
EXHIBIT A 

Proposed Order 

Case 23-03036-mvl Doc 67 Filed 04/23/24 Entered 04/23/24 16:03:18 Desc Main

Document Page 4 of 6

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 8 of 15
1 

IN THE UNITED STATES BANKRUPCTY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

GOODMAN NETWORKS, INC. 

 Debtor. 

§ 

§ 

§ 

§ 

§ 

§ 

Case No. 22-31641-mv-7 

(Chapter 7) 

SCOTT M. SIEDEL, TRUSTEE; GNET 

ATC, LLC; MULTIBAND FIELD 

SERVICES, INC. 

 Plaintiff(s), 

v. 

JAMES FRINZI; FRINZI FAMILY TRUST, 

MULTIBAND GLOBAL RESOURCES, 

LLC, 

 Defendant(s). 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

ADVERSARY PROCEEDING 

NO: 23-03036-mvl 

ORDER GRANTING UNOPPOSED MOTION TO WITHDRAW AS COUNSEL OF RECORD 

Came on consideration the Unopposed Motion to Withdraw as Counsel, filed by Wick 

Phillips Gould & Martin, LLP (“WPGM”), in the above-captioned case. The Court, having 

jurisdiction to consider the Motion and relief requested therein, finds that proper notice of the 

Motion has been provided and good cause exists to permit WPGM to withdraw as counsel for 

Case 23-03036-mvl Doc 67 Filed 04/23/24 Entered 04/23/24 16:03:18 Desc Main

Document Page 5 of 6

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 9 of 15
2 

Defendants James Frinzi, Frinzi Family Trust, and Multiband Global Resources, LLC 

(“Defendants”). Therefore, it is hereby: 

ORDERED that the Motion is GRANTED; it is further 

ORDERED that the Clerk of this Court and all parties are directed to remove WPGM as 

counsel for Defendants on the docket and any applicable service list, including the Court’s 

CM/ECF electronic notification list, maintained in the Bankruptcy Case. 

ORDERED Mr. Frinzi may be contacted as follows: 3736 Bee Cave Road, Suite 1164 

Austin, Texas 78746, James@frinzi.net. 

# # # END OF ORDER # # # 

PREPARED AND SUBMITTED BY: 

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, Texas 75204 

Telephone: (214) 692-6200 

Facsimile: (214) 692-6255 

jason.rudd@wickphillips.com 

paul.elkins@wickphillips.com 

Case 23-03036-mvl Doc 67 Filed 04/23/24 Entered 04/23/24 16:03:18 Desc Main

Document Page 6 of 6

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 10 of 15
EXHIBIT 2

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 11 of 15
1 

IN THE UNITED STATES BANKRUPCTY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

GOODMAN NETWORKS, INC. 

 Debtor. 

§ 

§ 

§ 

§ 

§ 

§ 

Case No. 22-31641-mv-7 

(Chapter 7) 

SCOTT M. SIEDEL, TRUSTEE; GNET 

ATC, LLC; MULTIBAND FIELD 

SERVICES, INC. 

 Plaintiff(s), 

v. 

JAMES FRINZI; FRINZI FAMILY TRUST, 

MULTIBAND GLOBAL RESOURCES, 

LLC, 

 Defendant(s). 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

§ 

ADVERSARY PROCEEDING 

NO: 23-03036-mvl 

NOTICE OF HEARING 

PLEASE TAKE NOTICE that the Court has scheduled a hearing on May 1, 2024 at 9:30 

a.m. to consider Unopposed Motion to Withdraw as Counsel of Record [Docket No. 67]. The 

hearing will be hybrid before the Honorable Michelle V. Larson, United States Bankruptcy Court for 

the Northern District of Texas, 1100 Commerce Street, 14th Floor, Courtroom No. 2, Dallas, Texas 

75242. 

For WebEx Video Participation/Attendance: 

Link: https://us-courts.webex.com/meet/larson

For WebEx Telephonic Only Participation/Attendance: 

Dial-In: 1.650.479.3207 

Access code: 160 135 6015

Case 23-03036-mvl Doc 69 Filed 04/24/24 Entered 04/24/24 16:53:40 Desc Main

Document Page 1 of 4

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 12 of 15
2 

Dated: April 24, 2024 Respectfully submitted, 

/s/ Jason M. Rudd 

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 

Email: jason.rudd@wickphillips.com 

 paul.elkins@wickphillips.com 

COUNSEL FOR DEFENDANTS JAMES 

FRINZI, FRINZI FAMILY TRUST, AND 

MULTIBAND GLOBAL RESOURCES, LLC 

CERTIFICATE OF SERVICE 

 I hereby certify that on April 24, 2024, I electronically filed the foregoing with the clerk of 

the court using the CM/ECF system and have served a copy of the same to the following parties 

or their counsel via the method(s) indicated below: 

Davor Rukavina 

Thomas D. Berghman 

MUNSCH HARDT KOPF & HARR, P.C. 

3800 Ross Tower 

500 N. Akard Street 

Dallas, TX 75201 

Counsel for the Scott Seidel, Chapter 7 Trustee 

 Hand Delivery 

 Regular Mail 

 Facsimile 

 E-mail 

 X CM/ECF 

James Frinzi, Individually, 

Trustee of the Frinzi Family Trust, and as 

Manager of Multiband Global Resources, LLC 

3736 Bee Cave Road, Suite 1164 

Austin, Texas 78746 

James@frinzi.net 

 Hand Delivery 

 X Regular Mail 

 Facsimile 

 X E-mail 

 CM/ECF 

/s/ Jason M. Rudd 

Jason M. Rudd 

Case 23-03036-mvl Doc 69 Filed 04/24/24 Entered 04/24/24 16:53:40 Desc Main

Document Page 2 of 4

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 13 of 15
WebEx Hearing Instructions

Judge Michelle V. Larson

Pursuant to General Order 2023-05 issued by the Court on September 19, 2023, certain hearings before Judge

Michelle V. Larson will be conducted by WebEx videoconference.

For WebEx Video Participation/Attendance:

Link: https://us-courts.webex.com/meet/larson

For WebEx Telephonic Only Participation/Attendance:

Dial-In: 1.650.479.3207

Access code: 160 135 6015

Participation/Attendance Requirements:

• Counsel and other parties in interest who plan to actively participate in the hearing are encouraged

to attend the hearing in the WebEx video mode using the WebEx video link above. Counsel and

other parties in interest who will not be seeking to introduce any evidence at the hearing and who

wish to attend the hearing in a telephonic only mode may attend the hearing in the WebEx

telephonic only mode using the WebEx dial-in and meeting ID above.

• Attendees should join the WebEx hearing at least 10 minutes prior to the hearing start time. Please

be advised that a hearing may already be in progress. During hearings, participants are required to

keep their lines on mute at all times that they are not addressing the Court or otherwise actively

participating in the hearing. The Court reserves the right to disconnect or place on permanent

mute any attendee that causes any disruption to the proceedings. For general information and

tips with respect to WebEx participation and attendance, please see Clerk’s Notice 20-04:

https://www.txnb.uscourts.gov/sites/txnb/files/hearings/Webex%20Information%20and%20Tips_

0.pdf

• Unless the Court orders otherwise, witnesses are required to attend the hearing in the WebEx 

video mode and live testimony will only be accepted from witnesses who have the WebEx

video function activated. Telephonic testimony without accompanying video will not be accepted

by the Court.

• All WebEx hearing attendees are required to comply with Judge Larson’s Telephonic and

Videoconference Hearing Policy (included within Judge Larson’s Judge-Specific Guidelines):

https://www.txnb.uscourts.gov/content/judge-michelle-v-larson-0

Exhibit Requirements:

• Any party intending to introduce documentary evidence at the hearing must file an exhibit list in

the case prior to the hearing, with a true and correct copy of each designated exhibit filed as a 

separate, individual attachment thereto so that the Court and all participants have ready access to all

designated exhibits.

• If the number of pages of such exhibits exceeds 100, then such party must also deliver two (2) sets

of such exhibits in exhibit binders to the Court by no later than twenty-four (24) hours in advance

of the hearing.

Notice of Hearing Content and Filing Requirements:

IMPORTANT: For all hearings that will be conducted by WebEx only:

• The Notice of Hearing filed in the case and served on parties in interest must: (1) provide notice

that the hearing will be conducted by WebEx videoconference only, (2) provide notice of the above

WebEx video participation/attendance link, and (3) attach a copy of these WebEx Hearing

Instructions or provide notice that they may be obtained from Judge Larson’s hearing/calendar site:

https://www.txnb.uscourts.gov/judges-info/hearing-dates/judge-larson-hearing-dates

• When electronically filing the Notice of Hearing via CM/ECF select “at https://usCase 23-03036-mvl Doc 69 Filed 04/24/24 Entered 04/24/24 16:53:40 Desc Main

Document Page 3 of 4

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 14 of 15
courts.webex.com/meet/larson” as the location of the hearing (note: this option appears

immediately after the first set of Wichita Falls locations). Do not select Judge Larson’s Dallas 

courtroom as the location for the hearing.

• Notice to Members of the Public. While the Judicial Conference of the United States relaxed 

its broadcasting policies during the COVID-19 Pandemic due to restrictions placed on inperson attendance at hearings and trials, these policies will expire and no longer be in effect 

after September 21, 2023. As a result, after September 21, 2023, remote video access to Court 

hearings shall only be available for case participants (parties-in-interest and their 

professionals) and non-case participants are not permitted to attend any hearing by remote 

video means. In certain circumstances, non-case participants may be permitted to attend 

proceedings by remote audio means, but only if no witness testimony is to be provided. The 

presiding judge may take any action deemed necessary or appropriate to address any 

unauthorized remote attendance at a hearing or trial. For the avoidance of doubt, members of 

the public will continue to generally be permitted to attend proceedings in person, in the 

courtroom.

Case 23-03036-mvl Doc 69 Filed 04/24/24 Entered 04/24/24 16:53:40 Desc Main

Document Page 4 of 4

Case 23-03036-mvl Doc 70 Filed 04/26/24 Entered 04/26/24 16:43:24 Desc Main

Document Page 15 of 15