PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO MULTIBAND GLOBAL RESOURCES, LLC—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 

PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO 

MULTIBAND GLOBAL RESOURCES, LLC 

TO: Multiband Global Resources, Inc., by and through its counsel of record, Debbie E. 

 Green, Esq., McDermott Will & Emery LLP, 2501 North Harwood Street, Suite 1900, 

 Dallas, Texas 75201. 

 Scott M. Seidel, for himself and for GNET ATC, LLC and Multibrad Field Services, Inc., 

the plaintiffs in the above styled and numbered Adversary Proceeding, hereby serves the following 

Interrogatories (each an “Interrogatory” and collectively the “Interrogatories”) on defendant 

Multiband Global Resources, LLC (the “Defendant”) pursuant to Federal Rule of Civil Procedure 

33, as follows. 

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Exhibit B Page 1 of 9
 

PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO MULTIBAND GLOBAL RESOURCES, LLC—Page 2 

I. INSTRUCTIONS 

 The Defendant is hereby requested to serve written responses to the Interrogatories listed 

in Section III, using the instructions listed in Section I and the definitions listed in Section II, no 

later than September 11, 2023, at the following address: 

Munsch Hardt Kopf & Harr, P.C. 

Attn: Davor Rukavina 

500 N. Akard St., Ste. 3800 

Dallas, Texas 75201 

 In answering these Interrogatories, the Defendant required to review all information 

available to it, including, but not limited to, information in the possession of its attorneys or their 

investigators or in the possession of its advisors, agents, or associates, or any other information in 

its possession, custody, or control. 

 The Defendant’s answers to these Interrogatories shall be verified as required by Rule 33. 

II. DEFINITIONS 

 “And” means and/or. 

 “FFT” means Frinzi Family Trust. 

 “Identify” when used in reference to a person, means to give, to the extent known, the 

person’s full name, present or last known address, e-mail address, and telephone number, and when 

referring to a natural person, additionally, the present or last known place of employment. Once a 

person has been identified in accordance with this subparagraph, only the name of that person need 

be listed in response to subsequent discovery requesting the identification of that person. 

 “Identify” when used in reference to a document, means to give, to the extent known, the 

(i) type of document; (ii) general subject matter; (iii) date of the document; and (iv) author(s), 

addressee(s), and recipient(s). 

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PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO MULTIBAND GLOBAL RESOURCES, LLC—Page 3 

 “Relate” or “refer” or “relating” or “referring,” mean in any way to comprise, constitute, 

describe, discuss, evidence, identify, memorialize, reflect, support, refute, make a statement about, 

deal with, consist of, refer to, relate to, pertain to, or being in any way logically or factually 

connected with, in whole or in part, the subject matter of the discovery request. 

 “You” and “Yours” refer to Multiband Global Resources, LLC and includes any of its 

agents acting within the scope of their agency. 

III. INTERROGATORIES 

INTERROGATORY NO. 1 

How much was paid to acquire the stock in American Metals Recovery and Recycling, Inc. 

n/k/a MBG Holdings, Inc. from Repository Services, LLC (or any other entity affiliated with it)? 

ANSWER: 

INTERROGATORY NO. 2 

Who paid the purchase price referenced in Interrogatory No. 1, when, and how? 

ANSWER: 

INTERROGATORY NO. 3 

Where did the funds used to make the purchase price referenced in Interrogatory No. 1 

originate from, or what was their source, including whether any portion thereof originated initially 

or subsequently from any of Goodman, GNET ATC, or Multiband? 

ANSWER: 

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PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO MULTIBAND GLOBAL RESOURCES, LLC—Page 4 

INTERROGATORY NO. 4 

What consideration or benefit did you, or anyone on your behalf, provide to GNET ATC 

or anyone else for the December 31, 2021 wire in the amount of $500,000 from GNET ATC to 

Stauber Law Firm, including in what amount, when, how, and to whom? 

ANSWER: 

INTERROGATORY NO. 5 

What was the purpose or the reason behind, from your perspective, the transfer of $4.4 

million to you from Multiband on or about January 4, 2022? 

ANSWER: 

INTERROGATORY NO. 6 

Why did you accept or receive the transfer of $4.4 million to you from Multiband on or 

about January 4, 2022? 

ANSWER: 

INTERROGATORY NO. 7 

Did you enter into any agreement, including a promissory note, related to the transfer of 

$4.4 million to you from Multiband on or about January 4, 2022? 

ANSWER: 

INTERROGATORY NO. 8 

What consideration or benefit did you, or anyone on your behalf, provide to Multiband or 

anyone else for the transfer of $4.4 million to you from Multiband on or about January 4, 2022, 

including in what amount, when, how, and to whom? 

ANSWER: 

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PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO MULTIBAND GLOBAL RESOURCES, LLC—Page 5 

INTERROGATORY NO. 9 

Why did you purchase the real property located at 521 N. Horseshoe Bay Blvd., Horseshoe 

Bay, Texas, and certain real property consisting of approximately .7 acres, and identified as Lot 

44 at the La Serena Loop, Horseshoe Bay, Texas 78657? 

ANSWER: 

INTERROGATORY NO. 10 

How did you pay the price to purchase the real property located at 521 N. Horseshoe Bay 

Blvd., Horseshoe Bay, Texas, and certain real property consisting of approximately .7 acres, and 

identified as Lot 44 at the La Serena Loop, Horseshoe Bay, Texas 78657, such as from cash or the 

proceeds of a loan, and if cash, where you got the money from and if loan, who you obtained the 

loan from. 

ANSWER: 

INTERROGATORY NO. 11 

Why did you transfer the real property located at 521 N. Horseshoe Bay Blvd., Horseshoe 

Bay, Texas, and certain real property consisting of approximately .7 acres, and identified as Lot 

44 at the La Serena Loop, Horseshoe Bay, Texas 78657, to FFT, and what benefit or consideration 

did you receive as a result of the same (and from whom)? 

ANSWER: 

INTERROGATORY NO. 12 

Who (as in which person(s)), for you and also for FFT, or on your behalf and on FFT’s 

behalf, negotiated and agreed to the transfer of the real property located at 521 N. Horseshoe Bay 

Blvd., Horseshoe Bay, Texas, and certain real property consisting of approximately .7 acres, and 

identified as Lot 44 at the La Serena Loop, Horseshoe Bay, Texas 78657 by you to FFT? 

ANSWER: 

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PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO MULTIBAND GLOBAL RESOURCES, LLC—Page 6 

INTERROGATORY NO. 13 

Why did you enter into that certain asset purchase agreement effective August 21, 2022 

with American Metals Recovery and Recycling, Inc. n/k/a MBG Holdings, Inc. from Repository 

Services, LLC, including what return consideration did you receive for that agreement? 

ANSWER: 

INTERROGATORY NO. 14 

Did Goodman, GNET ATC, LLC, and/or Multibrad Field Services, Inc. owe you any 

money on account of which GNET ATC transferred $962,000 to you on or about December 30, 

2021 and, if so, how much and pursuant to what agreement? 

ANSWER: 

INTERROGATORY NO. 15 

What consideration or benefit did you, or anyone on your behalf, provide to GNET ATC 

or anyone else for the transfer $962,000 to you on or about December 30, 2021, including in what 

amount, when, how, and to whom? 

ANSWER: 

INTERROGATORY NO. 16 

Why did you enter into the Subcontract Services Agreement with GNET ATC dated 

December 31, 2021, and what benefit or consideration did you provide to GNET ATC for and 

under that contract? 

ANSWER: 

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PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO MULTIBAND GLOBAL RESOURCES, LLC—Page 7 

INTERROGATORY NO. 17 

 Identify by name each employee of yours you had as of December 31, 2021 to provide 

services under that certain Subcontract Services Agreement with GNET ATC, and when such 

employee became an employee of yours, and when such employee ceased being an employee of 

yours. 

ANSWER: 

INTERROGATORY NO. 18 

 State what revenue you received or were paid, including any unpaid accounts receivable, 

from, on account of, or related to that certain Subcontract Services Agreement dated December 31, 

2021 between GNET ATC and MGR, and from which source, including from the End Customer 

(as defined therein). 

ANSWER: 

INTERROGATORY NO. 19 

 What is the current status of that certain Subcontract Services Agreement dated December 

31, 2021 between GNET ATC and MGR and the Underlying Contract (as defined therein) and, if 

either have been terminated, cancelled, not renewed, assigned, or transferred, state when, why, and 

to whom. 

ANSWER: 

INTERROGATORY NO. 20 

 Identify in detail and with specificity each action, fact, omission, or allegation you contend 

supports your Affirmative Defense No. 2 of “unclean hands or other inequitable conduct,” 

including who, when, and how engaged in unclean hands or other inequitable conduct and the 

nexus or link between the same and the Plaintiffs’ claims being barred. 

ANSWER: 

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PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO MULTIBAND GLOBAL RESOURCES, LLC—Page 8 

INTERROGATORY NO. 21 

 Identify in detail and with specificity each action, fact, omission, or allegation you contend 

supports your Affirmative Defense No. 3 of “estoppel,” including who, when, and how engaged 

in conduct or omissions leading to estoppel, and the nexus or link between the same and the 

Plaintiffs’ claims being barred. 

ANSWER: 

INTERROGATORY NO. 22 

 Identify in detail and with specificity each action, fact, omission, or allegation you contend 

supports your Affirmative Defense No. 4 of “waiver,” including who waived anything, when, and 

how, and what was waived. 

ANSWER: 

INTERROGATORY NO. 23 

 Identify in detail and with specificity each action, fact, omission, or allegation you contend 

supports your Affirmative Defense No. 5 of “ratification,” including who ratified what, when, and 

how. 

ANSWER: 

INTERROGATORY NO. 24 

 Identify in detail and with specificity each action, fact, omission, or allegation you contend 

supports your Affirmative Defense No. 6 of “the business judgment rule,” including the 

considerations taken and rationale underlying each of the contested actions. 

ANSWER: 

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PLAINTIFFS’ FIRST SET OF INTERROGATORIES TO MULTIBAND GLOBAL RESOURCES, LLC—Page 9 

 Dated at Dallas Texas this 11th day of August, 2023. 

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

jvasek@munsch.com 

ATTORNEYS FOR THE PLAINTIFFS 

CERTIFICATE OF SERVICE 

 The undersigned hereby certifies that, on this the 11th day of August, 2023, he caused a 

true and correct copy of this document to be served on counsel of record for all parties in this 

Adversary Proceeding, by e-mail and by U.S. first class mail, postage prepaid, as follows: 

Jason M. Rudd, Esq. 

Wick Phillips Gould & Martin, LLP 

3131 McKinney Avenue, Suite 500 

Dallas, TX 75204 

jason.rudd@wickphillips.com

Debbie E. Green, Esq. 

McDermott Will & Emery LLP 

2501 North Harwood Street 

Suite 1900 

Dallas, Texas 75201 

dgreen@mwe.com 

/s/ Davor Rukavina 

 Davor Rukavina, Esq. 

4856-9352-1782v.1 013229.00016 

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