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; 

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 

AGREED SCHEDULING ORDER 

 Pursuant to Rule 16, Federal Rules of Civil Procedure, 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 August 18, 2023

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 

1. Docket call for this Adversary Proceeding will be held on March 5, 2024 at 1:15 

p.m.

2. Trial of this Adversary Proceeding will be held the week of March 11, 2024. 

3. Parties shall complete fact discovery on or before December 31, 2023. Expert 

discovery shall be completed by January 31, 2024. 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. 

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

December 15, 2023. 

5. Rebuttal expert reports shall be exchanged on or before January 5, 2024. 

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

December 31, 2023. 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 

7 days of the service of the response. 

7. 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 March 1, 2024. 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 will be taken up either at the 

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

8. On or before March 4, 2024, 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 

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AGREED SCHEDULING ORDER—Page 3 

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. 

9. On or before March 4, 2024, the parties shall file proposed findings of fact and 

conclusions of law. 

10. On or before March 4, 2024, the parties shall file trial briefs addressing contested 

issues of law. 

11. 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 December 1, 2023 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 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 4 

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 DEFENDANTS JAMES 

FRINZI & FRINZI FAMILY TRUST 

/s/ Debbie E. Green (w/ permission)

Debbie E. Green (Texas Bar No. 24059852) 

Marcus A. Helt (Texas Bar No. 24052187) 

MCDERMOTT WILL & EMERY LLP 

2501 North Harwood Street, Suite 1900 

Dallas, Texas 75201 

Tel: 469.715.4979 

Fax: 972.692.7700 

ATTORNEYS FOR MULTIBAND 

GLOBAL RESOURCES, LLC 

 

4896-0699-0708v.1 013229.00016 

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