Official Form 201 Voluntary Petition for Non-Individuals Filing for Bankruptcy page 1 

Official Form 201

Voluntary Petition for Non-Individuals Filing for Bankruptcy 06/22

If more space is needed, attach a separate sheet to this form. On the top of any additional pages, write the debtor’s name and the case 

number (if known). For more information, a separate document, Instructions for Bankruptcy Forms for Non-Individuals, is available.

1. Debtor’s name ______________________________________________________________________________________________________

2. All other names debtor used

in the last 8 years

Include any assumed names,

trade names, and doing business

as names

______________________________________________________________________________________________________

______________________________________________________________________________________________________

______________________________________________________________________________________________________

______________________________________________________________________________________________________

______________________________________________________________________________________________________

3. Debtor’s federal Employer

Identification Number (EIN) ___ ___ – ___ ___ ___ ___ ___ ___ ___

4. Debtor’s address Principal place of business

______________________________________________

Number Street

______________________________________________

______________________________________________

County 

Mailing address, if different from principal place 

of business

_______________________________________________

Number Street

_______________________________________________

P.O. Box

_______________________________________________ 

City State ZIP Code

Location of principal assets, if different from 

principal place of business

_______________________________________________

Number Street

_______________________________________________

_______________________________________________ 

City State ZIP Code

5. Debtor’s website (URL) ____________________________________________________________________________________________________

 Fill in this information to identify the case:

 Check if this is an

amended filing

United States Bankruptcy Court for the:

(State) 

Case number (If known): _________________________ Chapter _____

______________________________________________ 

City State ZIP Code 

11

High Country Watersports, LLC

Tommy's Colorado

4 6 0 8 9 6 1 6 0

12900 W 43rd Dr

Golden CO 80403

https://www.tommysboats.com/

Northern______ District of Texas______

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Document Page 1 of 18
Debtor _______________________________________________________ Case number (if known)_____________________________________ Name

 Official Form 201 Voluntary Petition for Non-Individuals Filing for Bankruptcy page 2

6. Type of debtor  Corporation (including Limited Liability Company (LLC) and Limited Liability Partnership (LLP)) 

 Partnership (excluding LLP)

 Other. Specify: __________________________________________________________________

7. Describe debtor’s business

A. Check one:

 Health Care Business (as defined in 11 U.S.C. § 101(27A))

 Single Asset Real Estate (as defined in 11 U.S.C. § 101(51B))

 Railroad (as defined in 11 U.S.C. § 101(44))

 Stockbroker (as defined in 11 U.S.C. § 101(53A))

 Commodity Broker (as defined in 11 U.S.C. § 101(6))

 Clearing Bank (as defined in 11 U.S.C. § 781(3))

 None of the above

B. Check all that apply: 

 Tax-exempt entity (as described in 26 U.S.C. § 501)

 Investment company, including hedge fund or pooled investment vehicle (as defined in 15 U.S.C. 

§ 80a-3)

 Investment advisor (as defined in 15 U.S.C. § 80b-2(a)(11))

C. NAICS (North American Industry Classification System) 4-digit code that best describes debtor. See 

http://www.uscourts.gov/four-digit-national-association-naics-codes . 

___ ___ ___ ___

8. Under which chapter of the 

Bankruptcy Code is the 

debtor filing? 

A debtor who is a “small business 

debtor” must check the first subbox. A debtor as defined in 

§ 1182(1) who elects to proceed 

under subchapter V of chapter 11 

(whether or not the debtor is a 

“small business debtor”) must 

check the second sub-box.

Check one:

 Chapter 7 

 Chapter 9

 Chapter 11. Check all that apply: 

 The debtor is a small business debtor as defined in 11 U.S.C. § 101(51D), and its

aggregate noncontingent liquidated debts (excluding debts owed to insiders or 

affiliates) are less than $3,024,725. If this sub-box is selected, attach the most 

recent balance sheet, statement of operations, cash-flow statement, and federal 

income tax return or if any of these documents do not exist, follow the procedure in 

11 U.S.C. § 1116(1)(B).

 The debtor is a debtor as defined in 11 U.S.C. § 1182(1), its aggregate 

noncontingent liquidated debts (excluding debts owed to insiders or affiliates) are 

less than $7,500,000, and it chooses to proceed under Subchapter V of 

Chapter 11. If this sub-box is selected, attach the most recent balance sheet, 

statement of operations, cash-flow statement, and federal income tax return, or if 

any of these documents do not exist, follow the procedure in 11 U.S.C. 

§ 1116(1)(B).

 A plan is being filed with this petition. 

 Acceptances of the plan were solicited prepetition from one or more classes of 

creditors, in accordance with 11 U.S.C. § 1126(b).

 The debtor is required to file periodic reports (for example, 10K and 10Q) with the 

Securities and Exchange Commission according to § 13 or 15(d) of the Securities 

Exchange Act of 1934. File the Attachment to Voluntary Petition for Non-Individuals Filing 

for Bankruptcy under Chapter 11 (Official Form 201A) with this form. 

 The debtor is a shell company as defined in the Securities Exchange Act of 1934 Rule 

12b-2.

 Chapter 12

High Country Watersports, LLC

4 4 1 2

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Document Page 2 of 18
Debtor _______________________________________________________ Case number (if known)_____________________________________ Name

 Official Form 201 Voluntary Petition for Non-Individuals Filing for Bankruptcy page 3

9. Were prior bankruptcy cases

filed by or against the debtor

within the last 8 years?

If more than 2 cases, attach a

separate list.

 No

 Yes. District _______________________ When _______________ Case number _________________________

MM / DD / YYYY

District _______________________ When _______________ Case number _________________________

MM / DD / YYYY

10. Are any bankruptcy cases

pending or being filed by a

business partner or an

affiliate of the debtor?

List all cases. If more than 1,

attach a separate list.

 No

 Yes. Debtor _____________________________________________ Relationship _________________________

__________________ 

MM / DD / YYYY 

Case number, if known ________________________________

11. Why is the case filed in this

district?

Check all that apply:

 Debtor has had its domicile, principal place of business, or principal assets in this district for 180 days

immediately preceding the date of this petition or for a longer part of such 180 days than in any other

district.

 A bankruptcy case concerning debtor’s affiliate, general partner, or partnership is pending in this district.

12. Does the debtor own or have

possession of any real

property or personal property

that needs immediate

attention?

 No

 Yes. Answer below for each property that needs immediate attention. Attach additional sheets if needed.

Why does the property need immediate attention? (Check all that apply.)

 It poses or is alleged to pose a threat of imminent and identifiable hazard to public health or safety.

What is the hazard? _____________________________________________________________________

 It needs to be physically secured or protected from the weather.

 It includes perishable goods or assets that could quickly deteriorate or lose value without

attention (for example, livestock, seasonal goods, meat, dairy, produce, or securities-related

assets or other options).

 Other _______________________________________________________________________________

Where is the property?_____________________________________________________________________

Number Street

____________________________________________________________________

Is the property insured?

 No

 Yes. Insurance agency ____________________________________________________________________

Contact name ____________________________________________________________________

Phone ________________________________ 

Statistical and administrative information

_______________________________________ _______ ________________

City State ZIP Code 

High Country Watersports, LLC

See Schedule 1 Affiliate

✓

✓

✓

✓

District Northern District of Texas_____________________ When 

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Document Page 3 of 18
Debtor _______________________________________________________ Case number (if known)_____________________________________ Name

Official Form 201 Voluntary Petition for Non-Individuals Filing for Bankruptcy page 4

13. Debtor’s estimation of

available funds

Check one:

 Funds will be available for distribution to unsecured creditors.

 After any administrative expenses are paid, no funds will be available for distribution to unsecured creditors.

14. Estimated number of

creditors

 1-49

 50-99

 100-199

 200-999

 1,000-5,000

 5,001-10,000

 10,001-25,000

 25,001-50,000

 50,001-100,000

 More than 100,000

15. Estimated assets

 $0-$50,000

 $50,001-$100,000

 $100,001-$500,000

 $500,001-$1 million

 $1,000,001-$10 million

 $10,000,001-$50 million

 $50,000,001-$100 million

 $100,000,001-$500 million

 $500,000,001-$1 billion

 $1,000,000,001-$10 billion

 $10,000,000,001-$50 billion

 More than $50 billion

16. Estimated liabilities

 $0-$50,000

 $50,001-$100,000

 $100,001-$500,000

 $500,001-$1 million

 $1,000,001-$10 million

 $10,000,001-$50 million

 $50,000,001-$100 million

 $100,000,001-$500 million

 $500,000,001-$1 billion

 $1,000,000,001-$10 billion

 $10,000,000,001-$50 billion

 More than $50 billion

Request for Relief, Declaration, and Signatures

WARNING -- Bankruptcy fraud is a serious crime. Making a false statement in connection with a bankruptcy case can result in fines up to 

$500,000 or imprisonment for up to 20 years, or both. 18 U.S.C. §§ 152, 1341, 1519, and 3571.

17. Declaration and signature of

authorized representative of

debtor

The debtor requests relief in accordance with the chapter of title 11, United States Code, specified in this

petition.

I have been authorized to file this petition on behalf of the debtor.

I have examined the information in this petition and have a reasonable belief that the information is true and

correct.

I declare under penalty of perjury that the foregoing is true and correct. 

Executed on _________________

MM / DD / YYYY

_____________________________________________

Signature of authorized representative of debtor

Title _________________________________________ 

High Country Watersports, LLC

3

3

3

3

MONICA BLACKER

Printed name

_______________________________________

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Document Page 4 of 18
Debtor _______________________________________________________ Case number (if known)_____________________________________ Name

 Official Form 201 Voluntary Petition for Non-Individuals Filing for Bankruptcy page 5

High Country Watersports, LLC

18. Signature of attorney _____________________________________________ Date _________________

Signature of attorney for debtor MM / DD / YYYY

_________________________________________________________________________________________________

Printed name

_________________________________________________________________________________________________

Firm name

10440 N. Central Expressway, Suite 800 _________________________________________________________________________________________________

Number Street

____________________________________________________ ____________ ______________________________

City State ZIP Code 

____________________________________ 

Contact phone 

__________________________________________

Email address

______________________________________________________ ____________

Bar number State

Liz Boydston 

Gutnicki LLP

Dallas Texas 75225

(469) 895-4413 lboydston@gutnicki.com

24053684 TX

/s/ Liz Boydston 05/20/2024

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Document Page 5 of 18
Schedule 1

Pending Bankruptcy Cases Filed by Debtor and Affiliates of Debtor

On the date hereof, each of the affiliated entities listed below, including the debtor in 

this chapter 11 case, filed a voluntary petition for relief under chapter 11 of title 11 of the 

United States Code in the United States Bankruptcy Court for the Northern District of Texas 

(the “Court”). A motion will be filed with the Court requesting that the chapter 11 cases of the 

entities listed below be consolidated for procedural purposes only and jointly administered, 

pursuant to Rule 1015(b) of the Federal Rules of Bankruptcy Procedure, under the case number 

assigned to the chapter 11 case of Tommy’s Fort Worth, LLC. 

Debtor Tax ID #

1 High Country Watersports, LLC 46-0896160

2 MKB Florida Holdings, LLC 46-1075698

3 Tommy’s California Fresno, LLC 85-3898597

4 Tommy’s Castaic, LLC 86-3507501

5 Tommy’s Chattanooga, LLC 87-1100839

6 Tommy’s Detroit, LLC 82-4235242

7 Tommy’s Fort Worth, LLC 87-3993473

8 Tommy’s Grand Rapids, LLC 47-3259224

9 Tommy’s Las Vegas, LLC 85-3877721

10 Tommy’s Lewisville, LLC 87-4014750

11 Tommy’s Phoenix, LLC 85-3863036

12 Tommy’s Stockton, LLC 92-0551338

13 Tommy's California Ventura, LLC 85-3845149

14 Tommy's Holding Company, LLC 84-3392662

15 Tommy's Knoxville, LLC 87-1128052

16 Tommy's Rancho Cordova, LLC 92-0541070

17 Walloon Lake Village Marina, LLC 46-0720277

Schedule 1 - Page 1

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Document Page 6 of 18
WRITTEN CONSENT OF MATTHEW BORISCH, PRESIDENT OF

TOMMY’S FORT WORTH, LLC, ET AL.

May 20, 2024

Under the provisions of the LLC Agreements of Tommy’s Fort Worth, LLC; Tommy’s 

Holding Company, LLC; Tommy’s Grand Rapids, LLC; Tommy’s Castaic, LLC; Tommy’s 

Lewisville, LLC; High Country Watersports, LLC; Walloon Lake Village Marina, LLC; MKB 

Florida Holdings, LLC; Tommy’s Detroit, LLC; Tommy’s California Fresno, LLC; Tommy’s 

Phoenix, LLC; Tommy’s Las Vegas, LLC; Tommy’s Chattanooga, LLC; Tommy’s California 

Ventura, LLC ; Tommy’s Rancho Cordova, LLC; Tommy’s Stockton, LLC; and Tommy’s 

Knoxville, LLC (collectively, the “Companies”), Matthew Borisch, as President of the Companies,

hereby consents in writing that the following resolutions be adopted:

WHEREAS Mr. Borisch has had the opportunity to consult with the management, and the 

Companies’ legal advisors and has fully considered presentations by each and each of the strategic 

alternatives available to the Companies.

A. Commence Chapter 11 Cases

NOW IT IS THEREFORE RESOLVED that the Companies file, or cause to be filed, 

voluntary petitions for relief under chapter 11 of the Bankruptcy Code in the United States 

Bankruptcy Court for the Northern District of Texas (the “Bankruptcy Court”) and perform any 

and all such acts as are reasonable, advisable, expedient, convenient, proper or necessary to affect 

the foregoing; and it is further

RESOLVED that the Chief Restructuring Officer (the “CRO”) and President Matthew 

Borisch (each, an “Authorized Person” and collectively, the “Authorized Persons”), acting singly 

or jointly, be, and hereby is, authorized, empowered, and directed, with full power of delegation, to 

negotiate, execute, deliver, and file with the Bankruptcy Court, in the name and on behalf of the 

Companies, and under its corporate seal or otherwise, all plans, petitions, schedules, statements, 

motions, lists, applications, pleadings, papers, affidavits, declarations, orders and other documents; 

and it is further

RESOLVED that the Authorized Persons be, and each of them, acting singly or jointly, 

hereby is, authorized, empowered, and directed, with full power of delegation, in the name and on 

behalf of the Companies, to take and perform any and all further acts and deeds that such Authorized 

Person deems necessary, appropriate, or desirable in connection with the Companies’ bankruptcy 

cases and in furtherance of the restructuring of the Companies’ debts and obligations, all as consistent 

with these resolutions and to carry out and put into effect the purposes of these resolutions, and the 

transactions contemplated by these resolutions, their authority thereunto to be evidenced by the 

taking of such actions; and it is further

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2

B. Retention of Advisors

RESOLVED that the following professionals be engaged and retained on behalf of the 

Companies: (i) Gutnicki LLP as general bankruptcy counsel; (ii) Force 10 Partners LLC to provide 

Monica Blacker to serve as the CRO and provide personnel in support of the CRO; (iii) Omni Agent 

Solutions, Inc. as claims and noticing agent; each to represent and assist the Companies in carrying 

out their duties and responsibilities under the Bankruptcy Code and applicable law, and to take any 

and all actions to advance the Companies’ rights and interests (including, without limitation, the law 

firms filing any pleadings and responses, and making any filings with regulatory agencies or other 

governmental authorities); and it is further

RESOLVED that the Authorized Persons be, and each of them, acting singly or jointly, 

hereby is, authorized, directed and empowered, on behalf of and in the name of the Companies, to 

execute appropriate retention agreements with and pay appropriate retainers to the foregoing 

professionals and such other professionals as they deem necessary, appropriate or desirable, upon 

such terms and conditions as they shall approve, to render services to the Companies, and to cause 

to be filed appropriate applications for authority to retain the services of such professionals; and it is 

further

RESOLVED that the Authorized Persons be, and each of them, acting singly or jointly, 

hereby is, authorized, empowered, and directed to employ any other professionals to assist the

Companies in carrying out their duties under the Bankruptcy Code to prepare for and in the 

bankruptcy cases; and the Authorized Persons be, and each of them, acting singly or jointly, hereby 

is, authorized, empowered, and directed to execute and file all necessary documents and agreements

and to pay retainers necessary to employ and retain all assistance by legal counsel, accountants, 

financial advisors, and other professionals and to take and perform any and all further acts and deeds

that the Authorized Persons deem necessary, proper, or desirable in connection with the bankruptcy 

cases, with a view toward successful prosecution of such cases; and it is further

C. Financing

RESOLVED that the Authorized Persons be, and each of them, acting singly or jointly, 

hereby is, authorized, directed and empowered, on behalf of and in the name of the Companies, to 

negotiate and obtain postpetition financing and/or use of cash collateral, including under one or more 

debtor-in-possession credit facilities, as such Authorized Person deems necessary, appropriate, or 

desirable in connection with the Companies bankruptcy cases and to carry out and put into effect the 

purposes of these resolutions; and to enter into any guarantees and to pledge and grant liens on the 

Companies’ assets in support of such financing, and in connection therewith to execute appropriate 

loan agreements and related ancillary documents; with the actions of the Authorized Persons taken 

pursuant to this resolution, including the execution, acknowledgement, delivery and verification of 

all such financing related documents, being deemed conclusive evidence of the approval and the 

necessity, desirability or appropriateness thereof; and it is further

RESOLVED that the Authorized Persons be, and each of them, acting singly or jointly, 

hereby is, authorized, directed and empowered, on behalf of and in the name of the Companies, to 

take all such further actions, including, without limitation, to pay or approve the payment of all fees 

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3

and expenses payable in connection with any such financing transaction(s) and all fees and expenses 

incurred by or on behalf of the Companies in connection with these resolutions, in accordance with 

the terms of any financing related documents, which shall in its sole judgment be necessary, 

appropriate, or desirable to perform any of the Companies’ obligations under or in connection with 

such financing arrangements and to carry out fully the intent of these resolutions; and it is further

D. General

RESOLVED that the Authorized Persons, be, and each of them, acting singly or jointly, 

hereby is, authorized, directed and empowered, on behalf of and in the name of the Companies, 

authorized, empowered, and directed, with full power of delegation, in the name and on behalf of 

the Companies, to take and perform any and all further acts or deeds, including (a) the negotiation 

of such additional agreements, amendments, modifications, supplements, consents, waivers, reports, 

documents, instruments, applications, notes or certificates not now known but which may be 

required, (b) the execution, delivery, performance and filing (if applicable) of any of the foregoing, 

and (c) the payment of all fees, consent payments, taxes, indemnities and other expenses, as any 

such Authorized Person, in his or her sole discretion, may approve or deem necessary, appropriate, 

or desirable to carry out the intent and accomplish the purposes of the foregoing resolutions and the 

transactions contemplated thereby, all of such actions, executions, deliveries, filings, and payments 

to be conclusive evidence of such approval or that such Authorized Person deemed the same to meet 

such standard; and it is further

RESOLVED that any person dealing with any Authorized Person in connection with any of 

the foregoing matters shall be conclusively entitled to rely upon the authority of such Authorized 

Person and by his or her execution of any document, agreement or instrument, the same to be a valid 

and binding obligation of such Companies enforceable in accordance with their terms; and it is 

further

RESOLVED that each Authorized Person is hereby authorized to certify and deliver to any 

person to whom such certification and delivery may be deemed necessary or desirable in the opinion 

of such Authorized Person, a true copy of the foregoing resolutions; and it is further

RESOLVED that all actions heretofore taken, and all agreements, instruments, reports and 

documents executed, delivered or filed through the date hereof, by any Authorized Person of the 

Companies in, for and on behalf of the Companies, in connection with the matters described in or 

contemplated by the foregoing resolutions, are hereby approved, adopted, ratified and confirmed in 

all respects as the acts and deeds of the Companies as of the date such action or actions were taken.

[Remainder of Page Intentionally Left Blank]

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4 

IN WITNESS WHEREOF, the undersigned have executed this Consent effective as of the date 

set forth above. 

Name: Matthew Borisch 

Title: President

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Document Page 10 of 18
1

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

)

In re: ) Chapter 11

)

TOMMY’S FORT WORTH, LLC, et al.,

1 ) Case No. 24-[___]

)

Debtors. ) (Joint Administration Requested)

)

CONSOLIDATED CORPORATE OWNERSHIP 

STATEMENT AND LIST OF EQUITY SECURITY HOLDERS

Pursuant to Rules 1007(a)(1) and 7007.1 of the Federal Rules of Bankruptcy Procedure, 

the above-captioned debtors and debtors in possession (each, a “Debtor”) hereby state as follows:

1. The following Debtors, along with each Debtor’s respective address, are 100%

owned by non-debtor Matthew A. Borisch: 

a. Tommy’s California Fresno, LLC, 120 Ottawa Ave. NW, Grand Rapids, MI

49053;

b. Tommy’s Castaic, LLC, 31970 Castaic Rd, Castaic, CA 91384;

c. Tommy’s Chattanooga, LLC, 120 Ottawa Ave. NW, Grand Rapids, 

MI 49053;

d. Tommy’s Fort Worth, LLC, 9804 Camp Bowie W Blvd, Fort Worth, TX

76116;

e. Tommy’s Holding Company, LLC, 120 Ottawa Ave. NW, Grand Rapids,

Michigan 49053;

1

 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification 

number, are: Tommy’s Fort Worth, LLC (3473); Tommy’s Holding Company, LLC (2662); Tommy’s Grand 

Rapids, LLC (9224); Tommy’s Castaic, LLC (7501); Tommy’s Lewisville, LLC (4750); High Country 

Watersports, LLC (6160); Walloon Lake Village Marina, LLC (0277); MKB Florida Holdings, LLC (5698); 

Tommy’s Detroit, LLC (5242); Tommy’s California Fresno, LLC (8597); Tommy’s Phoenix, LLC (3036); 

Tommy’s Las Vegas, LLC (7721); Tommy’s Chattanooga, LLC (0839); Tommy’s California Ventura, 

LLC (5149); Tommy’s Rancho Cordova, LLC (1070); Tommy’s Stockton, LLC (1338); and Tommy’s 

Knoxville, LLC (8052). The corporate headquarters and the mailing address for the Debtors is 146 Monroe 

Center NW, Suite 820, Grand Rapids, Michigan.

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2

f. Tommy’s Knoxville, LLC, 11470 Outlet Dr., Knoxville, TN 37932;

g. Tommy’s Las Vegas, LLC, 615 W Lake Mead Pkwy., Henderson, NV

89015;

h. Tommy’s Lewisville, LLC, 375 Oakridge Blvd, Lewisville, TX 75057;

i. Tommy’s Phoenix, LLC, 33 W Broadway Rd, Mesa, AZ 85210; and

j. Tommy's California Ventura, LLC, 120 Ottawa Ave. NW, Grand Rapids,

MI 49053.

2. The following Debtors, along with each Debtor’s respective address, are 100%

owned by non-debtor the Matthew Allen Borisch Trust, which is in turn 100% owned by nondebtor Matthew A. Borisch: 

a. High Country Watersports, LLC, 12900 W 43rd Dr., Golden, CO 80403;

b. MKB Florida Holdings, LLC, 16212 State Rte. 50, Clermont, FL 34711;

c. Tommy’s Grand Rapids, LLC, 247 Morrissey Dr. NE, Comstock Park, MI 49321;

and

d. Walloon Lake Village Marina, LLC, 4075 M-75, Walloon Lake, MI 49796.

3. The following Debtors, along with each Debtor’s respective address, are 100%

owned by Debtor Tommy’s Holding Company LLC, which is in turn 100% owned by non-debtor 

Matthew A. Borisch: 

a. Tommy’s Detroit, LLC, 495 Summit Dr., Waterford Twp., MI 48328;

b. Tommy’s Rancho Cordova, LLC, 11361 Folsom Blvd, Rancho Cordova, CA

95742; and

c. Tommy’s Stockton, LLC, 1325 W Fremont St, Stockton, CA 95203.

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Document Page 12 of 18
UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF TEXAS

Chapter 11 or Chapter 9 Cases: List of Creditors Who Have the 30 Largest 

Unsecured Claims and Are Not Insiders

Case No. (If known)

Debtor name Tommy’s Fort Worth, LLC 

A list of creditors holding the 30 largest unsecured claims must be filed in a Chapter 11 or Chapter 9 case. Include claims which the debtor

Name of creditor and complete 

mailing address, including zip 

code.

Name, telephone number, and 

email address of creditor contact

Nature of the 

claim 

Amount of unsecured claim 

Official Form 204

(for example, 

trade debts, bank 

loans, 

professional 

services, and 

government 

contracts)

If the claim is fully unsecured, fill in only 

unsecured claim amount. If claim is partially 

secured, fill in total claim amount and 

deduction for value of collateral or setoff to 

calculate unsecured claim.

Indicate if 

claim is 

contingent, 

unliquidated, 

or disputed

Total Claim, if 

partially 

secured

Deduction for 

value of 

collateral or 

setoff

Unsecured claim

12/15

disputes. Do not include claims by any person who is an , as defined in 11 U.S.C. § 101(31). Also, do not include claims by insider

secured creditors, unless the unsecured claim resulting from inadequate collateral value places the creditor among the holders of the 30

largest unsecured claims.

Check if this is an 

amended filing

FLOORPLAN & $105,687,453.80

REVOLVER

M&T Bank

345 Main St

Buffalo, NY 14203

M&T Bank

Email: smitzner@mtb.com

1 Disputed $105,687,453.80

Mercantile Bank LINE OF CREDIT $4,740,610.92

310 Leonard St NW

Grand Rapids, MI 49504

Mercantile Bank

Email: jkarl@mercbank.com

2 $4,740,610.92

Larson Marine SELLER NOTE $3,243,800.96

4340 Rivera Dr

Stockton, CA 95204

3 Larson Marine

SALES TAX & $2,849,829.97

PENALTIES

California Dept of Tax & Fee 

Administration

P.O. Box 942879

Sacramento, CA 94279

4 California Dept of Tax & Fee Administration

Michigan Treasury SALES TAX $1,077,731.49

P.O. Box 30324

Lansing, MI 48909

5 Michigan Treasury

Cvar (Waterski America) SELLER NOTE $823,252.52

413 Stonecrest

Argyle, TX 76226

Cvar (Waterski America)

Email: timccvar@gmail.com

6

Official Form 204 Chapter 11 or Chapter 9 Cases: List of Creditors Who Have the 30 Largest Unsecured Claims Page 1

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Document Page 13 of 18
Name of creditor and complete 

mailing address, including zip 

code.

Name, telephone number, and 

email address of creditor contact

Nature of the 

claim 

Amount of unsecured claim 

(for example, 

trade debts, bank 

loans, 

professional 

services, and 

government 

contracts)

If the claim is fully unsecured, fill in only 

unsecured claim amount. If claim is partially 

secured, fill in total claim amount and 

deduction for value of collateral or setoff to 

calculate unsecured claim.

Indicate if 

claim is 

contingent, 

unliquidated, 

or disputed

Total Claim, if 

partially 

secured

Deduction for 

value of 

collateral or 

setoff

Unsecured claim

Debtor name Tommy’s Fort Worth, LLC Case No. (If known)

(Continuation Sheet)

Moses Powersports SELLER NOTE $671,665.44

7981 Hampton Cove Dr

Ooltewah, TN 37363

Moses Powersports

Email: CWFinch@firsthorizon.com

7

SALES TAX & $523,953.49

PENALTIES

Tennessee Dept of Revenue

500 Deaderick St

Nashville, TN 37242

8 Tennessee Dept of Revenue

SALES TAX & $422,893.39

PENALTIES

State of Arizona

Dept of Revenue

1600 W Monroe

Phoenix, AZ 85007

9 State of Arizona

BUILDING $381,754.31

LEASES

Key Bank

11501 Outlook St, Ste 300

Overland Park, KS 66211

Key Bank

Email: scrawford@storecapital.com

10

Boulder Boats SELLER NOTE $372,469.00

11500 S Eastern Ave, Ste 210

Henderson, NV 89052

11 Boulder Boats

Barefoot International, LLC TRADE AP $301,217.89

L - 4131

Columbus, OH 43260

Barefoot International, LLC

Email: 

ARKWSAOBI@KENTWATERSPORTS.C

OM

12

SALES TAX & $295,996.99

PENALTIES

Colorado Dept of Revenue

P.O. Box 912758

Denver, CO 80291

13 Colorado Dept of Revenue

Official Form 204 Chapter 11 or Chapter 9 Cases: List of Creditors Who Have the 30 Largest Unsecured Claims Page 2

Case 24-90002-11 Doc 1 Filed 05/20/24 Entered 05/20/24 23:28:04 Desc Main

Document Page 14 of 18
Name of creditor and complete 

mailing address, including zip 

code.

Name, telephone number, and 

email address of creditor contact

Nature of the 

claim 

Amount of unsecured claim 

(for example, 

trade debts, bank 

loans, 

professional 

services, and 

government 

contracts)

If the claim is fully unsecured, fill in only 

unsecured claim amount. If claim is partially 

secured, fill in total claim amount and 

deduction for value of collateral or setoff to 

calculate unsecured claim.

Indicate if 

claim is 

contingent, 

unliquidated, 

or disputed

Total Claim, if 

partially 

secured

Deduction for 

value of 

collateral or 

setoff

Unsecured claim

Debtor name Tommy’s Fort Worth, LLC Case No. (If known)

(Continuation Sheet)

David M Tisdale & Co RENT $210,758.00

5657 W Maple Rd

W Bloomfield, MI 48322

David M Tisdale & Co

Email: dtiz@aol.com

14

CUSTOMER $189,000.00

DEPOSIT 

Troy Hawkins

7304 Mcconnell Dr

Kernersville, NC 27284

Troy Hawkins

Email: ethawkins@yahoo.com

15

SALES TAX & $158,218.15

PENALTIES

Nevada Tax Center

700 E Warm Springs

Las Vegas, NV 89119

16 Nevada Tax Center

Glaspro, Inc TRADE AP $151,612.66

dba Zap & Phase 5

Venice, FL 34292

Glaspro, Inc

Email: SALES@GLASPROINC.COM

17

CORPORATE $148,982.12

INSURANCE 

(DUE 5/31)

First Insurance Funding

450 Skokie Blvd

Northbrook, IL 60062

First Insurance Funding

Email: 

firstinsite@firstinsurancefunding.com

18

TRADE AP - $145,994.04

BOATS

Avalon & Tahoe Mfg, Inc

903 Michigan Ave

Alma, MI 48801

Avalon & Tahoe Mfg, Inc

Email: tiffany@avalonpontoons.com

19

Marine Outfitters SELLER NOTE $140,000.00

Attn: Shannon Mcphail

280 Country Rd 35

Athens, TN 37303

Marine Outfitters

Email: shanmcph1969@gmail.com

20

Official Form 204 Chapter 11 or Chapter 9 Cases: List of Creditors Who Have the 30 Largest Unsecured Claims Page 3

Case 24-90002-11 Doc 1 Filed 05/20/24 Entered 05/20/24 23:28:04 Desc Main

Document Page 15 of 18
Name of creditor and complete 

mailing address, including zip 

code.

Name, telephone number, and 

email address of creditor contact

Nature of the 

claim 

Amount of unsecured claim 

(for example, 

trade debts, bank 

loans, 

professional 

services, and 

government 

contracts)

If the claim is fully unsecured, fill in only 

unsecured claim amount. If claim is partially 

secured, fill in total claim amount and 

deduction for value of collateral or setoff to 

calculate unsecured claim.

Indicate if 

claim is 

contingent, 

unliquidated, 

or disputed

Total Claim, if 

partially 

secured

Deduction for 

value of 

collateral or 

setoff

Unsecured claim

Debtor name Tommy’s Fort Worth, LLC Case No. (If known)

(Continuation Sheet)

Protective Asset Protection TRADE AP $133,041.00

P.O. Box 830634

Birmingham, AL 35283-0634

Protective Asset Protection

Email: contractprocessing@protective.com

21

Asd Concrete LLC CONSTRUCTION $129,600.00

1527 Hwy 114, Ste 500

Grapevine, TX 76051

22 Asd Concrete LLC

Orion Construction CONSTRUCTION $127,397.72

32 Market Ave SW

Grand Rapids, MI 49503

Orion Construction

Email: jsmigielski@orionbuilt.com

23

Square One Distribution, Inc TRADE AP $125,108.33

35214 Se Center St

Snoqualmie, WA 98065

Square One Distribution, Inc

Email: kerley@squareoneco.com

24

LIEN PAYOFF $117,701.18

DUE ON TRADE 

IN

David Hawkesworth

7304 Mcconnell Dr

Kernersville, NC 27284

25 David Hawkesworth $117,701.18

Larsons Marine RENT $100,000.00

4340 Rivera Dr

Stockton, CA 95204

26 Larsons Marine

SALES TAX & $95,770.00

PENALTIES

City of Wheat Ridge

Tax Division

P.O. Box 912758

Denver, CO 80291

27 City of Wheat Ridge

Official Form 204 Chapter 11 or Chapter 9 Cases: List of Creditors Who Have the 30 Largest Unsecured Claims Page 4

Case 24-90002-11 Doc 1 Filed 05/20/24 Entered 05/20/24 23:28:04 Desc Main

Document Page 16 of 18
Name of creditor and complete 

mailing address, including zip 

code.

Name, telephone number, and 

email address of creditor contact

Nature of the 

claim 

Amount of unsecured claim 

(for example, 

trade debts, bank 

loans, 

professional 

services, and 

government 

contracts)

If the claim is fully unsecured, fill in only 

unsecured claim amount. If claim is partially 

secured, fill in total claim amount and 

deduction for value of collateral or setoff to 

calculate unsecured claim.

Indicate if 

claim is 

contingent, 

unliquidated, 

or disputed

Total Claim, if 

partially 

secured

Deduction for 

value of 

collateral or 

setoff

Unsecured claim

Debtor name Tommy’s Fort Worth, LLC Case No. (If known)

(Continuation Sheet)

Summit Real Estate Holdings RENT $91,500.00

5657 W Maple Rd

W Bloomfield, MI 48322

Summit Real Estate Holdings

Email: dtiz@aol.com

28

Amg Operations LLC TRADE AP $89,620.21

3501 Fruitridge Ave NW, Ste A

Walker, MI 49544

Amg Operations LLC

Email: ar@acmemarine.com

29

LIEN PAYOFF $89,510.59

DUE ON TRADE 

IN

Dave Melendy

913 Laurel Hill Rd

Knoxville, TN 37923

Dave Melendy

Email: davidmelendy@gmail.com

30 $89,510.59

Official Form 204 Chapter 11 or Chapter 9 Cases: List of Creditors Who Have the 30 Largest Unsecured Claims Page 5

Case 24-90002-11 Doc 1 Filed 05/20/24 Entered 05/20/24 23:28:04 Desc Main

Document Page 17 of 18
Official Form 202 

Declaration Under Penalty of Perjury for Non-Individual Debtors

Official Form 202 

Declaration Under Penalty of Perjury for Non-Individual Debtors 12/15

An individual who is authorized to act on behalf of a non-individual debtor, such as a corporation or partnership, must sign and submit 

this form for the schedules of assets and liabilities, any other document that requires a declaration that is not included in the document, 

and any amendments of those documents. This form must state the individual’s position or relationship to the debtor, the identity of the 

document, and the date. Bankruptcy Rules 1008 and 9011. 

WARNING -- Bankruptcy fraud is a serious crime. Making a false statement, concealing property, or obtaining money or property by fraud in 

connection with a bankruptcy case can result in fines up to $500,000 or imprisonment for up to 20 years, or both. 18 U.S.C. §§ 152, 1341, 

1519, and 3571. 

Declaration and signature

I am the president, another officer, or an authorized agent of the corporation; a member or an authorized agent of the partnership; or 

another individual serving as a representative of the debtor in this case.

I have examined the information in the documents checked below and I have a reasonable belief that the information is true and correct:

 Schedule A/B: Assets–Real and Personal Property (Official Form 206A/B)

 Schedule D: Creditors Who Have Claims Secured by Property (Official Form 206D)

 Schedule E/F: Creditors Who Have Unsecured Claims (Official Form 206E/F)

 Schedule G: Executory Contracts and Unexpired Leases (Official Form 206G)

 Schedule H: Codebtors (Official Form 206H)

 Summary of Assets and Liabilities for Non-Individuals (Official Form 206Sum)

 Amended Schedule ____

 Chapter 11 or Chapter 9 Cases: List of Creditors Who Have the 20 Largest Unsecured Claims and Are Not Insiders (Official Form 204)

 Other document that requires a declaration__________________________________________________________________________________

I declare under penalty of perjury that the foregoing is true and correct. 

Executed on 05/20/2024

MM / DD / YYYY 

___/s/ Monica S. Blacker_______________________________________ Signature of individual signing on behalf of debtor

_____Monica S. Blacker______________________________________________

Printed name

Chief Restructuring Officer

______________________________________ 

Position or relationship to debtor

(State) 

Northern District of Texas

Debtor Name: High Country Watersports, LLC

United States Bankruptcy Court for the:

Case number (If known): _________________________

 Fill in this information to identify the case and this filing: 

X

Corporate Ownership Statement 

Case 24-90002-11 Doc 1 Filed 05/20/24 Entered 05/20/24 23:28:04 Desc Main

Document Page 18 of 18