PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO MULTIBAND GLOBAL RESOURCES, 

INC.—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 

PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO 

MULTIBAND GLOBAL RESOURCES, INC. 

TO: Multiband Global Resources, Inc., by and through its counsel of record, Debbie E. 

 Green, Esq., McDermott Will & Emery LLP, 2501 North Harwood Street, Suite 1900, 

 Dallas, Texas 75201. 

 Scott M. Seidel, for himself and for GNET ATC, LLC and Multibrad Field Services, Inc., 

the plaintiffs in the above styled and numbered Adversary Proceeding, hereby serves the following 

Requests for Production (each a “Request” and collectively the “Requests”) on defendant 

Multiband Global Resources, Inc. (the “Defendant”) pursuant to Federal Rule of Civil Procedure 

34, as follows. 

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PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO MULTIBAND GLOBAL RESOURCES, 

INC.—Page 2 

I. INSTRUCTIONS 

1. These requests are intended to cover all information, documents, and things in Your 

possession, custody, or control. A document or thing is deemed to be in Your possession, custody, 

or control, if: 

a. It is in Your physical control; or 

b. It is in the physical control of any other person or entity, and You, individually or 

otherwise 

i. Own the document or thing in whole or in part; 

ii. Have a right by contract, statute, or otherwise, to use, inspect, examine, or 

copy that document or thing on any terms; or 

iii. Have, as a practical matter, been able to use, inspect, examine, or copy that 

document or thing when You have sought to do so. 

2. Unless otherwise indicated, references in these requests to You or any party, 

business organization, or other legal entity specifically includes all of that entity’s present or 

former employees, officers, directors, agents, representatives, members, attorneys, departments, 

sections, affiliates, subsidiaries, parents, and all other persons acting on its behalf. 

3. If any portion of any document, electronically stored information, or tangible thing 

is responsive to any Request, then the entire document, electronically stored information, or 

tangible thing must be produced. Documents and electronically stored information shall be 

produced in the order in which they are found in your files. Documents that are found stapled, 

clipped, or otherwise fastened shall be produced in such form. 

4. In the event that no document, electronically stored information, or tangible thing 

exists that is responsive to a particular Request, a written response indicating the same shall be 

provided. 

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PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO MULTIBAND GLOBAL RESOURCES, 

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5. If any document, electronically stored information, or tangible thing is withheld on 

the basis of privilege, or any Request is objected to on the basis of privilege, you must nevertheless 

produce other responsive documents, electronically stored information, or tangible things pursuant 

to such Request that are not subject to any privilege, and you must produce a privilege log 

concerning documents, electronically stored information, and tangible things withheld on the basis 

of privilege providing sufficient information to allow the Debtors to evaluate and determine the 

propriety of each such claim of privilege. 

6. These Requests cover and include all electronically stored information and means 

of communication, including Signal, Snapchat, e-mail, test messaging, and all other electronic 

means of communication or records. 

II. DEFINITIONS

7. “Adversary Proceeding” shall mean Case No. 23-03036 pending in the United 

States Bankruptcy Court for the Northern District of Texas, Dallas Division. 

8. “And” and “or” shall each be individually interpreted in every instance as meaning 

“and/or” and shall not be interpreted disjunctively to exclude any information otherwise within the 

scope of any specification. 

9. “Bankruptcy Case” shall mean Case No. 22-31541 pending in the United States 

Bankruptcy Court for the Northern District of Texas, Dallas Division. 

10. “Communication” shall mean any contact or act by which any information is 

transmitted or conveyed between two or more persons, and shall include, without limitation, 

written contact by such means as letters, memoranda, telegrams, telexes, electronically transmitted 

messages, e-mails, or by any document, and any oral contact by such means as face-to-face 

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PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO MULTIBAND GLOBAL RESOURCES, 

INC.—Page 4 

meetings or conversations and telephone conversations that are transcribed, notated, or in any other 

manner memorialized in written, typed, or recorded form. 

11. “Document(s)” means all written, recorded or graphic matter, whether in hard copy 

or generated or stored electronically or magnetically or by any other means, including without 

limitation, all papers, books, records, letters, photographs, tangible things, correspondence, 

communications, telegrams, cables, telex messages, memoranda, notes, notations, work papers, 

transcripts, minutes, reports, recordings of telephone or other conversations, interviews, 

conferences or other meetings, affidavits, statements, summaries, opinions, reports, studies, 

analyses, evaluations, contracts, agreements, jottings, agendas, bulletins, notices, announcements, 

advertisements, instructions, charges, brochures, publications, schedules, lists, journals, statistical 

records or calculations, desk calendars, appointment books, diaries, tabulations, programs, data 

process input and output, microfilm, ledgers, journals or books of account, records and invoices 

reflecting business operations, records kept by electronic, photographic or mechanical means, any 

notes or drafts relating to the foregoing, and all things similar to any of the foregoing, however 

denominated. “Document” or “documents” shall also mean and include the original, drafts of the 

original and each non-identical copy (whether different from the original because of marginal notes 

or in whatever respect), including translations, of any written or graphic matter, whether typed, 

printed, recorded, filmed, produced by hand, or reproduced by any other mechanical process or 

means. 

12. “FFT” means Frinzi Family Trust. 

13. “Financial Document” means any document related to or evidencing the financial 

condition of a company, including a financial statement, cash flow statement, balance sheet, or 

income statement, whether internal or created for or provided to a third person. 

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PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO MULTIBAND GLOBAL RESOURCES, 

INC.—Page 5 

14. “Frinzi” means James Frinzi. 

15. “GNET ATC” means GNET ATC, LLC. 

16. “Including” means ‘including but not limited to’, and is not restrictive or limiting. 

17. “Multiband” means Multiband Field Services, Inc. 

18. “Person” means any natural person or any company, corporation, partnership, 

association, joint venture, sole proprietorship, governmental agency, and any other legally 

recognized entity. 

19. “Relate”, “related to” “relating” or “relating to” refers to any act, work, meeting, 

oral or written communication, or document, referring, directly or indirectly, in any way to the 

described facts, or evidencing, directly or indirectly, such facts. 

20. “You” and “your” shall mean Multiband Global Resources, LLC and all of your 

representatives or agents. 

 

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PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO MULTIBAND GLOBAL RESOURCES, 

INC.—Page 6 

III. REQUESTS 

REQUEST NO. 1 

All of your corporate governance documents in place at any time since formation, including 

any membership agreement or operating agreement and amendments, bylaws and amendments, 

resolutions, member consents, and Document or instrument appointing or removing any person as 

a member, manager, or officer. 

RESPONSE: 

REQUEST NO. 2 

Any agreement between you and Frinzi, including any employment agreement, promissory 

note, severance agreement, and con-compete agreement. 

RESPONSE: 

REQUEST NO. 3 

Any Document or Communication demonstrating your initial capitalization and any 

subsequent changes to such capitalization. 

RESPONSE: 

REQUEST NO. 4 

All federal and state tax returns filed for you or on your behalf for the years 2020, 2021, 

2022, and 2023, and any amendments thereto. 

RESPONSE: 

REQUEST NO. 5 

All bank statements since January 1, 2021 through the present for any account held by you 

in your name or to which you had access, including any depository account. 

RESPONSE: 

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PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO MULTIBAND GLOBAL RESOURCES, 

INC.—Page 7 

REQUEST NO. 6 

All promissory notes pursuant to which you are a maker, obligor, or co-maker or obligation, 

executed at any time since January 1, 2021, and any other Document or instrument, including any 

guarantee, by which you owed any person any debt since January 1, 2021, and all Documents and 

Communications concerning: (i) the creation of any such promissory note or other Document or 

instrument; (ii) the execution thereof; (iii) any amendment, modification, release, or termination 

thereof; (iv) any repayment thereon; or (v) any default thereof or thereon. 

RESPONSE: 

REQUEST NO. 7 

All Documents and Communications between you, on the one hand, and American Metals 

Recovery and Recycling, Inc., n/k/a MBG Holdings, Inc., at any time prior to May 1, 2022, 

including with respect to any agent or representative thereof, including any letter of intent, 

purchase offer, or bid. 

RESPONSE: 

REQUEST NO. 8 

All Documents and Communications between you, on the one hand, and AMR Resources, 

LLC, at any time prior to May 1, 2022, including with respect to any agent or representative 

thereof, including any letter of intent, purchase offer, or bid. 

RESPONSE: 

REQUEST NO. 9 

All Documents and Communications between you, on the one hand, and OnePath Systems, 

LLC, at any time prior to May 1, 2022, including with respect to any agent or representative 

thereof, including any letter of intent, purchase offer, or bid. 

RESPONSE: 

REQUEST NO. 10 

All Documents and Communications between you, on the one hand, and Repository 

Services, LLC, including the Share Purchases Agreement, any draft thereof, and all 

Communications regarding the negotiation or execution thereof. 

RESPONSE: 

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PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO MULTIBAND GLOBAL RESOURCES, 

INC.—Page 8 

REQUEST NO. 11 

All Documents and Communications between you, on the one hand, and MSouth Equity 

Partners, and any affiliate, subsidiary, agent, representative, investment banker, or partner thereof, 

regarding AMR Resources, LLC or OnePath Systems, LLC, including any bid you made for the 

assets of any of the foregoing. 

RESPONSE: 

REQUEST NO. 12 

All Documents and Communications between you, on the one hand, and Stauber Law 

Office. 

RESPONSE: 

REQUEST NO. 13 

All Documents and Communications between you, on the one hand, and Hill Innovative 

Law, LLC or David Hill. 

RESPONSE: 

REQUEST NO. 14 

All Documents and Communications related to any transfer of funds by Goodman to you, 

including any agreement or promissory note for the same, or authorization by Goodman or any 

director, officer, or employee thereof for the same. 

RESPONSE: 

REQUEST NO. 15 

All Documents and Communications related to any transfer of funds by GNET ATC to 

you, including the alleged transfer of $962,000.00 on December 30, 2021, including any agreement 

or promissory note for the same, or authorization by GNET ATC or any director, officer, or 

employee thereof for the same. 

RESPONSE: 

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PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO MULTIBAND GLOBAL RESOURCES, 

INC.—Page 9 

REQUEST NO. 16 

All Documents and Communications related to any transfer of funds by Multiband to you, 

including the alleged transfer of $4.4 million on or about January 4, 2022, including any agreement 

or promissory note for the same, or authorization by Multiband or any director, officer, or 

employee thereof for the same. 

RESPONSE: 

REQUEST NO. 17 

Your internal financial books and records, including QuickBooks, related to how you 

booked any transfer to you of any funds by Goodman, GNET ATC, or Multiband. 

RESPONSE: 

REQUEST NO. 18 

All Documents and Communications related to, referring to, or regarding that certain 

Subcontract Services Agreement dated December 31, 2021 between GNET ATC and you, 

including all such Documents and Communications related to the negotiation thereof, the 

execution thereof, and any performance (or lack of performance) thereunder, any termination or 

cancellation thereof, any assignment or transfer thereof, including the Underlying Contract (as 

defined therein)), including any bill or invoice or reconciliation of amounts owing. 

RESPONSE: 

REQUEST NO. 19 

All Documents and Communications related to, referring to, or regarding any transfers or 

payments to you or by you pursuant to that certain Subcontract Services Agreement dated 

December 31, 2021 between GNET ATC and you, including from the End Customer (as defined 

therein). 

RESPONSE: 

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PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO MULTIBAND GLOBAL RESOURCES, 

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REQUEST NO. 20 

All Documents and Communications related to, referring to, or regarding any benefit or 

consideration you provided to Goodman or GNET ATC for any payments or transfers made to you 

under that certain Subcontract Services Agreement dated December 31, 2021 between GNET ATC 

and you, including any wages, salaries, taxes, or expenses you incurred or you paid under or 

pursuant to said contract. 

RESPONSE: 

REQUEST NO. 21 

All Documents and Communications between you, on the one hand, and any person, 

including 18920 NW 11th, LLC, Steven Zakharyayev, Evelina Pinkhasova, James Goodman, or 

Shalom Auerbach, regarding any alleged Amended Secured Promissory Note dated December 20, 

2021 in the original principal amount of $4,500,000.00, payable by Multiband or any security 

agreement related to the same, including all such Documents and Communications concerning the 

funding, corporate approval, negotiation, execution, delivery or performance of or under the same. 

RESPONSE: 

REQUEST NO. 22 

All Documents and Communications related to any alleged December 20, 2021 promissory 

note from Multiband to you, including any such note and security agreement related to the same, 

and including all such Documents and Communications concerning the funding, corporate 

approval, negotiation, execution, delivery or performance of or under the same. 

RESPONSE: 

REQUEST NO. 23 

All Documents and Communications related to any loan or funding of any loan by you to 

Multiband, or related to any other consideration you may have provided to Multiband in exchange 

for any promissory note or loan allegedly payable by Multiband to you. 

RESPONSE: 

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PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO MULTIBAND GLOBAL RESOURCES, 

INC.—Page 11 

REQUEST NO. 24 

All Documents and Communications related any asset purchase agreement between you 

and American Metals Recovery and Recycling, Inc., n/k/a MBG Holdings, Inc., including any 

such agreement effective as of August 21, 2022, and including the funding, corporate approval, 

negotiation, execution, delivery or performance of or under the same. 

RESPONSE: 

REQUEST NO. 25 

All Documents and Communications related to any purchase by you of any real estate, 

including certain real property and improvements located at 521 N. Horseshoe Bay Blvd., 

Horseshoe Bay, Texas, and certain real property consisting of approximately .7 acres, and 

identified as Lot 44 at the La Serena Loop, Horseshoe Bay, Texas 78657, and including any 

purchase and sale agreement brokerage agreement, promissory note, or deed of trust related to the 

same. 

RESPONSE: 

REQUEST NO. 26 

All Documents and Communications related to any sale or transfer by you of any real 

estate, including real property and improvements, to any person, including the FFT, and including 

certain real property and improvements located at 521 N. Horseshoe Bay Blvd., Horseshoe Bay, 

Texas, and certain real property consisting of approximately .7 acres, and identified as Lot 44 at 

the La Serena Loop, Horseshoe Bay, Texas 78657, and including any purchase and sale agreement 

brokerage agreement, promissory note, or deed of trust related to the same. 

RESPONSE: 

REQUEST NO. 27 

All Documents and Communications related to any consideration provided to you for any 

real estate sold or transferred by you, including to the FFT and including certain real property and 

improvements located at 521 N. Horseshoe Bay Blvd., Horseshoe Bay, Texas, and certain real 

property consisting of approximately .7 acres, and identified as Lot 44 at the La Serena Loop, 

Horseshoe Bay, Texas 78657, no matter what the form of such consideration may have been or 

who it may have been provided by. 

RESPONSE: 

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PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO MULTIBAND GLOBAL RESOURCES, 

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REQUEST NO. 28 

All Documents and Communications related to any salary, wages, expense reimbursement, 

dividend, distribution, loan, advance, bonus, or other payment or transfer to Frinzi. 

RESPONSE: 

REQUEST NO. 29 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 5 

RESPONSE: 

REQUEST NO. 30 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 6. 

RESPONSE: 

REQUEST NO. 31 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 7. 

RESPONSE: 

REQUEST NO. 32 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 9. 

RESPONSE: 

REQUEST NO. 33 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 10. 

RESPONSE: 

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PLAINTIFFS’ FIRST SET OF REQUESTS FOR PRODUCTION TO MULTIBAND GLOBAL RESOURCES, 

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REQUEST NO. 34 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 12. 

RESPONSE: 

REQUEST NO. 35 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 13. 

RESPONSE: 

REQUEST NO. 36 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 15. 

RESPONSE: 

REQUEST NO. 37 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 19. 

RESPONSE: 

REQUEST NO. 38 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 20. 

RESPONSE: 

REQUEST NO. 39 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 21. 

RESPONSE: 

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REQUEST NO. 40 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 22. 

RESPONSE: 

REQUEST NO. 41 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 23. 

RESPONSE: 

REQUEST NO. 42 

All Documents and Communications that relate to or that you contend support your answer 

to Interrogatory No. 24. 

RESPONSE: 

 Dated at Dallas Texas this 11th day of August, 2023. 

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

jvasek@munsch.com 

ATTORNEYS FOR THE PLAINTIFFS 

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CERTIFICATE OF SERVICE 

 The undersigned hereby certifies that, on this the 11th day of August, 2023, he caused a 

true and correct copy of this document to be served on counsel of record for all parties in this 

Adversary Proceeding, by e-mail and by U.S. first class mail, postage prepaid, as follows: 

Jason M. Rudd, Esq. 

Wick Phillips Gould & Martin, LLP 

3131 McKinney Avenue, Suite 500 

Dallas, TX 75204 

jason.rudd@wickphillips.com

Debbie E. Green, Esq. 

McDermott Will & Emery LLP 

2501 North Harwood Street 

Suite 1900 

Dallas, Texas 75201 

dgreen@mwe.com 

/s/ Davor Rukavina 

 Davor Rukavina, Esq. 

4864-7451-5063v.1 013229.00016 

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