1

4855-4711-9256v.1 013229.00016

UNITED STATES BANKRUPTCY COURT

NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

In re:

GOODMAN NETWORKS, INC.,

Debtor.

§

§

§

§

§ 

Case No. 22-31641-mvl7

(Chapter 7)

SCOTT M. SEIDEL, TRUSTEE, et al.,

Plaintiff,

v.

JAMES FRINZI, et al., 

Defendants.

§

§

§

§

§

§

§

§

§

§ 

Adv. No. 23-03036-mvl

JOINT MOTION TO CONTINUE HEARING ON MOTION TO COMPEL

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

NOW COME plaintiffs Scott Seidel, as chapter 7 trustee (the “Trustee”) for Goodman 

Networks, Inc., GNET ATC, LLC, and Multiband Field Services, Inc. (collectively, the 

“Plaintiffs”), along with defendants James Frinzi (“Mr. Frinzi”), Multiband Global Resources, 

LLC (“MGR”), and the Frinzi Family Trust (collectively, the “Defendants”), and file this Joint 

Motion to Continue Hearing on Motion to Compel, in support of which they would respectfully 

show as follows:

1. On October 25, 2023, the Plaintiffs filed their Plaintiffs’ Motion to Compel 

Discovery Responses and Production from Defendant Multiband Global Resources, LLC (Dkt. 

No. 22, the “Motion to Compel”), which they originally set for hearing on November 21, 2023 

(the “Hearing”).

Case 23-03036-mvl Doc 41 Filed 12/19/23 Entered 12/19/23 16:19:36 Desc Main

Document Page 1 of 2
2

4855-4711-9256v.1 013229.00016

2. As a result of MGR retaining new counsel, the Plaintiffs agreed to continue the 

Hearing to December 20, 2023. While MGR has begun to produce documents, various issues 

remain unresolved in connection with the Motion to Compel. For example, and without limitation, 

MGR has not produced any bank statements. 

3. Mr. Frinzi and MGR have represented to the Trustee that (a) they have requested 

the bank statements from JPMorgan Chase; (b) JPMorgan Chase has informed them that the bank 

statements have been mailed; and (c) they will produce the bank statements promptly upon receipt. 

Mr. Frinzi and MGR reaffirm those representations by their counsel’s signature to this motion.

4. Under these circumstances, and based on these representations, the Plaintiffs have 

agreed to continue the Hearing another 30 days to allow the parties more time to resolve all 

outstanding issues consensually.

WHEREFORE, PREMISES CONSIDERED, the Plaintiffs and the Defendants 

respectfully request that the Court continue the hearing approximately another 30 days.

RESPECTFULLY SUBMITTED this 19th day of December, 2023.

/s/ Julian P. Vasek

Davor Rukavina, Esq.

Tex. Bar No. 24030781

Thomas D. Berghman, Esq.

Tex. Bar No. 24082683

Julian P. Vasek, Esq.

Tex. Bar No. 24070790

MUNSCH HARDT KOPF & HARR P.C.

500 N. Akard St., Ste. 4000

Dallas, Texas 75201

214-855-7500

Email: drukavina@munsch.com

Email: tberghman@munsch.com

Email: jvasek@munsch.com

COUNSEL FOR THE PLAINTIFFS

/s/ Paul T. Elkins

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

Email: jason.rudd@wickphillips.com

Email: paul.elkins@wickphillips.com

COUNSEL FOR THE DEFENDANTS 

Case 23-03036-mvl Doc 41 Filed 12/19/23 Entered 12/19/23 16:19:36 Desc Main

Document Page 2 of 2