IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

GOODMAN NETWORKS, INC., 

 Debtor. 

SCOTT M. SEIDEL, et.al., 

 Plaintiffs, 

v. 

HUDSON CLEAN ENERGY 

ENTERPRISES, LLC, et al., 

 Defendants. 

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Case No. 22-31641-mvl-7 

(Chapter 7) 

ADVERSARY PROCEEDING 

NO: 23-03090-mvl

AGREED SCHEDULING ORDER 

 Pursuant to Rule 16, Federal Rules of Civil Procedure, and the parties’ agreement as 

reflected herein, the Court issues the following scheduling order to supersede any prior scheduling 

order entered in this proceeding: 

IT IS ORDERED THAT:

United States Bankruptcy Judge

______________________________________________________________________

Signed May 1, 2024

The following constitutes the ruling of the court and has the force and effect therein described.

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1. Docket call for this Adversary Proceeding will be held on the Court’s May, 2025

trial docket call day, tentatively estimated at May 6, 2025 at 1:15 p.m., but the parties are directed 

to obtain the precise setting once the Court issues its 2025 calendar. 

2. Trial of this Adversary Proceeding will be held during the Court’s trial week for 

May, 2025, tentatively estimated at May 12, 2025, but the parties are directed to obtain the precise 

setting once the Court issues its 2025 calendar. 

3. Parties shall complete fact discovery on or before December 20, 2024. Expert 

discovery shall be completed by February 28, 2025. Discovery must be served promptly enough 

to permit response by the other party prior to the end of the discovery period. Parties may, by 

agreement, continue discovery beyond this deadline without further order of this Court. 

4. Non-expert initial disclosures are waived. 

5. Parties shall exchange names, addresses and reports of experts for trial on or before 

December 20, 2024. 

6. Rebuttal expert reports shall be exchanged on or before February 14, 2025. 

7. All dispositive motions shall be filed and served on all other parties on or before 

March 7, 2025. Responses shall be filed and served on all other parties not later than 21 days of 

the service of the motion. Any replies shall be filed and served on all other parties not later than 

14 days of the service of the response. 

8. Except for impeachment documents, all exhibits, along with a list of witnesses to 

be called, shall be exchanged with all other parties no later than May 1, 2025. The identification 

of witnesses to be called by deposition shall include page and line designations of deposition 

testimony. Counter designations of deposition testimony shall be exchanged with all other parties 

no later than May 6, 2025. All exhibits and designation of deposition testimony not objected to in 

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AGREED SCHEDULING ORDER—Page 3 

writing by Docket Call shall be admitted into evidence at trial without further proof, except for 

objections to relevance. Written objections to exhibits will be taken up either at the beginning or 

during the course of the actual trial or at any pretrial conference. 

9. On or before May 1, 2025, a Joint Pretrial Order in compliance with Local District 

Court Rule 16.4 shall be filed, served, and uploaded for Court entry. All parties are responsible for 

preparing the Joint Pretrial Order, which shall contain the following: (a) a summary of the claims 

and defenses of each party; (b) a statement of stipulated facts; (c) a list of the contested issues of 

fact; (d) a list of contested issues of law; (e) an estimate of the length of trial; (f) a list of additional 

matters which would aid in the disposition of the case; and (g) the signature of each attorney. 

10. On or before May 1, 2025, the parties shall file proposed findings of fact and 

conclusions of law. 

11. On or before May 1, 2025, the parties shall file trial briefs addressing contested 

issues of law. 

12. This Order, and each party’s agreement to this Order, is wholly without prejudice 

to all issues concerning the Court’s core or non-core jurisdiction, or the lack thereof, or the lack of 

any consent to this Court’s entry of final judgment, or to any motion for withdrawal of the 

reference, and all rights, issues, objections, defenses, and arguments concerning any of the 

foregoing are preserved and may be asserted by each party as is otherwise appropriate 

notwithstanding the entry of this Order; provided, however, that any motion for the withdrawal of 

the reference should be filed no later than October 31, 2024, but, if filed thereafter, or if not 

granted prior to trial, the Court shall proceed to trial without prejudice to any reference withdrawal 

issue and, if the Court or the District Court determines that this Court’s jurisdiction is not core, 

then this Court shall make a report and recommendation to the District Court as is otherwise 

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AGREED SCHEDULING ORDER—Page 4 

appropriate if the District Court has not by then entered an order providing otherwise (or unless a 

party obtains a stay from any court pending the same). 

# # # END OF ORDER # # # 

AGREED: 

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 DEFENDANT JAMES 

FRINZI 

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/ Leslie Sara Hyman (w/ permission)

Randall A. Pulman 

Texas State Bar No. 16393250 

rpulman@pulmanlaw.com 

Leslie Sara Hyman 

Texas State Bar No. 00798274 

lhyman@pulmanlaw.com 

Anna K. MacFarlane 

Texas State Bar No. 24116701 

amacfarlane@pulmanlaw.com 

ATTORNEYS FOR DEFENDANTS 

JAMES GOODMAN; GOODMAN 

INVESTMENT HOLDINGS, LLC; 

GENESIS NETWORKS, INC.; GENESIS 

NETWORKS GLOBAL SERVICES, LLC 

JORDAN, LYNCH & CANCIENNE PLLC 

By: /s/ Michael Cancienne (w/ permission) 

Michael Cancienne 

State Bar No. 24046330 

Joseph (“Jeb”) W. Golinkin II 

State Bar No. 24087596 

1980 Post Oak Blvd., Ste. 2300 

Houston, Texas 77056 

713-955-4020 (Telephone) 

713-955-9644 (Fax) 

mcancienne@jlcfirm.com 

jgolinkin@jlcfirm.com

ATTORNEYS FOR HUDSON CLEAN 

ENERGY ENTERPRISES, LLC; 

ALLIANCE TEXAS HOLDINGS, LLC; 

NEIL Z. AUERBACH; JUDITH 

AUERBACH; AUERBACH PARTNERS, 

L.P.; AUERBACH CHILDREN’S 

DYNASTY TRUST U/A/D OCTOBER 9, 

2012; and AUERBACH FAMILY 

DYNASTY TRUST U/A/D OCTOBER 9, 

2012 

4867-3789-2282v.1 013229.00016 

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