IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

In re: 

GOODMAN NETWORKS, INC., 

Debtor. 

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 Case No. 22-31641 (MVL) 

(Bankr. N.D. Tex. – Dallas Division) 

 Chapter 7 

ARRIS SOLUTIONS, INC., 

Plaintiff, 

v. 

GOODMAN NETWORKS, INC. d/b/a 

GOODMAN SOLUTIONS; GNET ATC, LLC 

GENESIS NETWORKS TELECOM 

SERVICES, LLC d/b/a GENESIS ATC; and 

JAMES GOODMAN, 

Defendants. 

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Adversary Proceeding No. 23-03035-mvl 

AGREED MOTION TO ABATE ADVERSARY PROCEEDING 

Plaintiff ARRIS Solutions, Inc. (“ARRIS”), Defendants James Goodman (“Goodman”), 

and Scott M. Seidel, Chapter 7 Trustee of the bankruptcy estate of Goodman Networks, Inc. d/b/a 

Goodman Solutions (the “Trustee’) file their Agreed Motion to Abate Adversary Proceeding and 

show: 

I. MOTION 

1. The above-captioned lawsuit was originally filed in state court in Bexar County, 

Texas in November 2021. 

2. In September 2022, the above-captioned involuntary bankruptcy proceeding was 

filed against Goodman Networks, Inc. d/b/a Goodman Solutions (the “Debtor”) in this Court. 

3. In December 2022, this Court entered an order for relief in the involuntary 

bankruptcy proceeding. 

4. On March 13, 2023, Goodman timely removed this lawsuit to the U.S. Bankruptcy 

Court for the Western District of Texas, San Antonio Division. 

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5. Subsequently, Goodman moved to transfer this lawsuit to the U.S. Bankruptcy 

Court for the Northern District of Texas, Dallas Division. Neither ARRIS nor Scott Seidel, the 

Chapter 7 Trustee, opposed the transfer of this lawsuit to this Court, though both reserved all rights, 

including the right to request remand to state court if they subsequently believe remand to be 

appropriate. 

6. Transfer of this lawsuit to this Court was granted and it was docketed as the abovecaptioned adversary proceeding. 

7. On June 7, 2023, the Court conducted a status conference in this adversary 

proceeding, at which counsel for ARRIS, Goodman, and the Trustee were present. During the 

status conference, counsel for all parties announced their intention to file an agreed order 

temporarily abating this adversary proceeding for 180 days to minimize unnecessary costs and 

expenditures while the main bankruptcy proceeding moves forward. 

8. As evidenced by the signatures of counsel on the agreed order attached as Exhibit 

A, the parties believe this adversary proceeding should be abated for 180 days, subject to the other 

conditions set forth in the agreed order. 

II. RELIEF REQUESTED 

For these reasons, the parties request that the Court enter the agreed order attached as 

Exhibit A abating this adversary proceeding and grant such other relief as the Court deems just 

and appropriate. 

 

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Respectfully Submitted, 

DLA PIPER LLP (US) 

/s/ Noah Schottenstein 

James Muenker 

State Bar No. 24002659 

Noah Schottenstein 

State Bar No. 24100661 

1900 N. Pearl St., Suite 2200 

Dallas, Texas 75201-2482 

james.muenker@dlapiper.com

noah.schottenstein@dlapiper.com 

Counsel for ARRIS SOLUTIONS, INC. 

- AND - 

MUNSCH HARDT KOPF & HARR, P.C. 

/s/ Thomas Berghman 

Davor Rukavina 

State Bar No. 24030781 

Thomas D. Berghman 

State Bar No. 24082683 

drukavina@munsch.com 

tberghman@munsch.com 

500 N. Akard Street, Suite 3800 

Dallas, Texas 75201-6659 

Counsel for Scott M. Seidel, Trustee of GOODMAN 

NETWORKS, INC., parent entity of GNET ATC, LLC 

- AND -

WINSTEAD PC 

By:/s/ Matthias Kleinsasser 

Matthias Kleinsasser 

State Bar No. 24071357 

mkleinsasser@winstead.com 

Sahrish K. Soleja 

State Bar No. 24102522 

ssoleja@winstead.com 

300 Throckmorton Street, Suite 1700 

Fort Worth, Texas 76102 

Counsel for Defendant James Goodman 

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CERTIFICATE OF CONFERENCE 

As evidenced by the signatures of counsel for ARRIS, Goodman, and the Trustee on the 

attached agreed order, this motion is unopposed. 

/s/ Matthias Kleinsasser 

Matthias Kleinsasser 

CERTIFICATE OF SERVICE 

I certify that a true and correct copy of the foregoing was forwarded to all counsel of record 

in this case by ECF on September 18, 2023 as follows: 

James Muenker 

Noah Schottenstein 

DLA PIPER LLP (US) 

1900 N. Pearl St., Suite 2200 

Dallas, Texas 75201-2482 

Counsel for ARRIS SOLUTIONS, INC. 

Davor Rukavina 

Thomas D. Berghman 

MUNSCH HARDT KOPF & HARR, P.C. 

500 N. Akard Street, Suite 3800 

Dallas, Texas 75201-6659 

Counsel for Scott M. Seidel, Trustee of 

GOODMAN NETWORKS, INC., parent entity of GNET ATC, LLC 

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EXHIBIT A 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

In re: 

GOODMAN NETWORKS, INC., 

Debtor. 

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 Case No. 22-31641 (MVL) 

(Bankr. N.D. Tex. – Dallas Division) 

 Chapter 7 

ARRIS SOLUTIONS, INC., 

Plaintiff, 

v. 

GOODMAN NETWORKS, INC. d/b/a 

GOODMAN SOLUTIONS; GNET ATC, LLC 

GENESIS NETWORKS TELECOM 

SERVICES, LLC d/b/a GENESIS ATC; and 

JAMES GOODMAN, 

Defendants. 

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Adversary Proceeding No. 23-03035-mvl 

AGREED ORDER GRANTING AGREED 

MOTION TO ABATE ADVERSARY PROCEEDING 

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Before the Court is the Agreed Motion to Abate Adversary Proceeding (the “Motion”) filed 

by Plaintiff ARRIS Solutions, Inc. (“ARRIS”), Defendant James Goodman (“Goodman”), and 

Scott M. Seidel, Trustee of the bankruptcy estate of Goodman Networks, Inc. d/b/a Goodman 

Solutions (the “Trustee”). By the Motion, the parties request that the above-captioned adversary 

proceeding (the “Adversary”) be abated for 180 days, subject to the conditions set forth below. 

After reviewing the Motion and considering the agreement of counsel and applicable authority, 

the Court finds and concludes that the Motion should be GRANTED. It is therefore 

ORDERED that the Motion is GRANTED; and it is further 

ORDERED that the Adversary, and any deadlines therein or related thereto, are abated for 

180 days from the date of entry of this Order, after which the Court will consider whether the 

Adversary should remain abated; provided that abatement is without prejudice to any party to the 

Adversary requesting that abatement be lifted prior to the 180-day deadline and the right of any 

other party to oppose such request; and it is further 

ORDERED that this Order shall not affect any rights, claims, and defenses of each party 

with respect to the Adversary, all of which are expressly reserved. 

#### END OF ORDER #### 

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AGREED IN SUBSTANCE AND FORM: 

DLA PIPER LLP (US) 

/s/ Noah Schottenstein 

James Muenker 

State Bar No. 24002659 

Noah Schottenstein 

State Bar No. 24100661 

1900 N. Pearl St., Suite 2200 

Dallas, Texas 75201-2482 

james.muenker@dlapiper.com

noah.schottenstein@dlapiper.com 

Counsel for ARRIS SOLUTIONS, INC. 

- AND - 

MUNSCH HARDT KOPF & HARR, P.C. 

/s/ Thomas Berghman 

Davor Rukavina 

State Bar No. 24030781 

Thomas D. Berghman 

State Bar No. 24082683 

drukavina@munsch.com 

tberghman@munsch.com 

500 N. Akard Street, Suite 3800 

Dallas, Texas 75201-6659 

Counsel for Scott M. Seidel, Trustee of 

GOODMAN NETWORKS, INC., parent entity of GNET ATC, LLC 

- AND -

WINSTEAD PC 

By:/s/ Matthias Kleinsasser 

Matthias Kleinsasser 

State Bar No. 24071357 

mkleinsasser@winstead.com 

Sahrish K. Soleja 

State Bar No. 24102522 

ssoleja@winstead.com 

300 Throckmorton Street, Suite 1700 

Fort Worth, Texas 76102 

 

Counsel for Defendant James Goodman 

Case 23-03035-mvl Doc 19 Filed 09/18/23 Entered 09/18/23 16:58:01 Desc Main

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