UNOPPOSED MOTION FOR AGREED PRELIMINARY INJUNCTION Page 1 

Davor Rukavina, Esq.

Texas Bar No. 24030781

Julian P. Vasek, Esq.

Texas Bar No. 24070790

Conor P. White, Esq.

Texas Bar No. 24125722

MUNSCH HARDT KOPF & HARR P.C.

500 N. Akard Street, Suite 4000

Dallas, Texas 75201

Telephone: (214) 855-7500

COUNSEL FOR THE PLAINTIFFS

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) 

Adv. No.: 23-03036 

UNOPPOSED MOTION FOR AGREED PRELIMINARY INJUNCTION

TO THE HONORABLE MICHELLE V. LARSON, U.S. BANKRUPTCY JUDGE:

Scott M. Seidel (the “Trustee”), the duly-appointed chapter 7 trustee for Goodman 

Networks, Inc., the debtor in the above-styled and numbered chapter 7 bankruptcy case, GNET 

ATC, LLC, and Multiband Field Services, Inc. (collectively, the “Plaintiffs”), file this Unopposed 

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UNOPPOSED MOTION FOR AGREED PRELIMINARY INJUNCTION Page 2 

Motion for Agreed Preliminary Injunction (the “Motion”), in support of which they would 

respectfully show as follows: 

1. By this Motion, the Plaintiffs request that the Court enter the proposed agreed order 

attached hereto as Exhibit A (the “Proposed Order”), preliminarily enjoining James Frinzi, Frinzi 

Family Trust, and Multiband Global Resources, LLC (collectively, the “Defendants”) from 

disposing of, permitting liens against, or otherwise materially impairing the value of certain 

Watercraft (defined below) that the Defendants allegedly purchased with certain funds at issue in 

this litigation. 

2. On May 4, 2023, the Plaintiffs filed their Original Complaint (the “Original 

Complaint”) [Docket No. 1] against the Defendants. On November 27, 2023, the Plaintiffs filed 

their Amended Complaint (the “Amended Complaint”) [Docket No. 30]. As further explained in 

the Original Complaint and the Amended Complaint, Goodman Networks, Inc. (the “Debtor”) is 

the sole member and owner of both GNET ATC, LLC (“GNET ATC”), and Multiband Field 

Services, Inc. (“Multiband”). 

3. Among other things, the Amended Complaint seeks to recover and impose a 

constructive trust with respect to a $4.4 million dollar transfer from Multiband to Multiband Global 

Resources, LLC (“MGR”) on January 4, 2022, and a $962,000.00 transfer from GNET ATC to 

MGR on December 31, 2022 (the “Transfers”).

4. The Trustee believes that, shortly after receiving the Transfers, MGR made multiple 

further transfers to watercraft dealers with respect one or more of the following watercraft (the 

“Watercraft”):

a. Yamaha, Registration Number 3665KN; 

b. Yamaha, Registration Number 3725KN; 

c. Sea Doo, Registration Number 9736KN; 

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UNOPPOSED MOTION FOR AGREED PRELIMINARY INJUNCTION Page 3

d. Sea Doo, Registration Number 9738KN; and 

e. Cobalt, Registration Number 5469CH.

5. The Defendants deny the Trustee’s allegations and reserve all rights with respect to 

the same. The Defendants have also informed the Plaintiffs that at least one of the Watercraft was 

destroyed in an accident before this litigation began. Nevertheless, in an effort to facilitate the 

expeditious and cost-effective resolution of this adversary proceeding, the Defendants have agreed, 

prior to final judgment, not to sell or grant any interest, including a lien or security interest, against 

the Watercraft without either a Court order or a written filed agreement of the Plaintiffs.

6. “At the commencement of and throughout an action, every remedy is available 

that, under the law of the state where the court is located, provides for seizing a person or property 

to secure satisfaction of the potential judgment.” Fed. R. Civ. P. 64; Fed. R. Bankr. P. 7064. The 

Amended Complaint alleges claims under the Texas Uniform Fraudulent Transfer Act. Tex. Bus. 

& Comm. Code §§ 24.001 et seq. That Act permits the Court to grant, “subject to applicable 

principles of equity and in accordance with applicable rules of civil procedure: (A) an injunction 

against further disposition by the debtor or a transferee, or both, of the asset transferred or of other 

property ....” Tex. Bus. & Comm. Code § 24.008(a)(3)(A). Texas law also permits pre-judgment 

attachment under certain circumstances. See Tex. Civ. Prac. & Rem. Code §§ 61.001 et seq. 

WHEREFORE, PREMISES CONSIDERED, the Plaintiffs respectfully request that the 

Court enter the Proposed Order and grant them such other and further relief to which they are 

entitled at law or in equity.

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UNOPPOSED MOTION FOR AGREED PRELIMINARY INJUNCTION Page 4 

RESPECTFULLY SUBMITTED this 15th day of February, 2024. 

MUNSCH HARDT KOPF & HARR, P.C.

/s/ Julian P. Vasek 

Davor Rukavina, Esq. 

Texas Bar No. 24030781 

Julian P. Vasek

Texas Bar No. 24070790 

Conor P. White, Esq. 

Texas Bar No. 24125722 

500 N. Akard Street, Suite 4000 

Dallas, Texas 75201 

Telephone: (214) 855-7500 

COUNSEL FOR THE PLAINTIFFS

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on the 15th day of February, 2024, he caused true 

and correct copies of the foregoing document to be served via the Court’s CM/ECF system on all 

parties entitled to notice thereby and upon counsel of record for the Defendants, Jason M. Rudd, 

Jason.rudd@wickphillips.com and Paul T. Elkins, paul.elkins@wickphillips.com. 

/s/ Julian P. Vasek 

 Julian P. Vasek

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