AGREED SCHEDULING ORDER 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,

Plaintiff,

v.

JAMES FRINZI, JAMES GOODMAN,

JASON GOODMAN, and JOSEPH

GOODMAN,

Defendants.

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Case No. 22-31641-mvl-7

(Chapter 7)

ADVERSARY PROCEEDING

NO: 24-03039-mvl

AGREED SCHEDULING ORDER

Pursuant to Federal Rule of Civil Procedure 16 and the Court’s Order Regarding Adversary 

Proceedings Trial Setting and Alternative Scheduling Order (Doc. 3), Plaintiff Scott M. Seidel 

United States Bankruptcy Judge

______________________________________________________________________

Signed August 15, 2024

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

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AGREED SCHEDULING ORDER Page 2

(“Trustee”), as the trustee of Goodman Networks, Inc. (“Debtor” or “Goodman Networks”), the 

debtor in the above-styled Chapter 7 bankruptcy case, and Defendants Jason Goodman and Joseph 

Goodman (collectively, “Defendants”) file this Agreed Scheduling Order and ask that it be entered 

in this adversary proceeding. 

IT IS ORDERED THAT:

1. Docket call for this adversary proceeding shall be held on the Court’s June 2025

trial docket call day, tentatively estimated at June 3, 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 shall be held during the Court’s trial week for 

June 2025, tentatively estimated for June 9, 2025, but the parties are directed to obtain the precise 

setting once the Court issues its 2025 calendar.

3. The parties shall serve the initial disclosures required by Federal Rule of 

Bankruptcy Procedure 7026 on or before August 23, 2024. 

4. The parties shall identify experts witnesses for trial and produce expert reports on 

or before February 13, 2025.

5. The parties shall identify rebuttal expert witnesses and produce rebuttal reports on 

or before March 13, 2025. 

6. The parties shall complete fact discovery on or before January 30, 2025. Expert 

discovery shall be completed by May 7, 2025. Discovery must be served promptly enough to 

permit timely response by the other party. Parties may, by agreement, continue discovery beyond 

this deadline without further order of this Court.

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7. All dispositive motions shall be filed on or before March 13, 2025. Responses 

shall be filed not later than twenty-one (21) days of the service of the motion. Any replies shall 

be filed not later than seven (7) days of the service of the response.

8. The parties shall attend mediation on or before January 30, 2025 and participate 

in such mediation in good faith toward resolution. 

9. Except for impeachment evidence, all exhibits, along with a list of witnesses to be 

called, shall be exchanged with all other parties no later than May 22, 2025. All exhibits not 

objected to in writing by Docket Call shall be admitted into evidence at trial without further proof, 

except for objections to relevance. Written objections to exhibits shall be taken up either at the 

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

10. On or before May 22, 2025, a Joint Pretrial Order in compliance with L.B.R. 7016-

1 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.

11. On or before May 22, 2025, the parties shall file proposed findings of fact and 

conclusions of law.

12. On or before May 22, 2025, the parties shall file trial briefs addressing contested 

issues of law.

13. 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, 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, 

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issues, objections, defenses, and arguments concerning any of the foregoing are preserved and may 

be asserted by any party as is otherwise appropriate notwithstanding the entry of this order; 

provided, however, that any motion for withdrawal of the reference should be filed no later than 

October 21, 2024. If a motion to withdrawal of the reference 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 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 # # #

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AGREED SCHEDULING ORDER Page 5 

AGREED:

MUNSCH HARDT KOPF & HARR, P.C.

By: /s/ Jamil N. Alibhai______________

Davor Rukavina 

State Bar No. 24030781 

Jamil N. Alibhai

State Bar No. 00793248 

Thomas D. Berghman 

State Bar No. 24082683 

Anne-Alise “Ali” Hinckley

State Bar No. 24090786 

J. Blake Glatstein

State Bar No. 24123295

Maddison Craig

State Bar No. 24137348

500 North Akard Street, Suite 4000

Dallas, Texas 75201

Telephone: (214) 855-7500

Facsimile: (214) 855-7584

Email: drukavina@munsch.com

jalibhai@munsch.com

tberghman@munsch.com

ahinckley@munsch.com

bglatstein@munsch.com

mcraig@munsch.com

ATTORNEYS FOR TRUSTEE

WHITAKER CHALK SWINDLE & 

SCHWARTZ PLLC

By: Robert A. Simon_________________ 

Robert A. Simon 

State Bar No. 18390000 

301 Commerce Street, Suite 3500 

Fort Worth, Texas 76102 

Telephone: (817) 878-0543 

Facsimile: (817) 878-0501 

Email: rsimon@whitakerchalk.com

ATTORNEY FOR DEFENDANTS 

JOSEPH AND JASON GOODMAN

WICK PHILLIPS GOULD & MARTIN,

LLP 

By: /s/ Paul T. Elkins_____________ 

Jason M. Rudd 

State Bar No. 24028786 

Paul T. Elkins 

State Bar No. 24092383 

3131 McKinney Avenue, Suite 500 

Dallas, Texas 75204 

Telephone: (214) 692-6200 

Facsimile: (214) 692-6255 

Email: jason.rudd@wickphillips.com 

paul.elkins@wickphillips.com 

ATTORNEYS FOR DEFENDANT JAMES 

FRINZI 

PULMAN, CAPPUCCIO & PULLEN, LLP

By: /s/ Randall A. Pulman____________ 

Randall A. Pulman

State Bar No. 16393250 

Anna K. MacFarlane

State Bar No. 24116701 

2161 NW Military Highway, Suite 400 

San Antonio, Texas 78213 

Telephone: (210) 222-9494 

Facsimile: (210) 892-1610 

Email: rpulman@pulmanlaw.com 

amacfarlane@pulmanlaw.com

ATTORNEYS FOR JAMES GOODMAN

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