4/22

Fill in this information to identify your case:

Debtor 1 Matthew Brandon Martorello

Debtor 2

(Spouse, if filing)

United States Bankruptcy Court for the: Northern District of Texas

Case number

(if know)

Official Form 107

Statement of Financial Affairs for Individuals Filing for Statement of Financial Affairs for Individuals Filing for Bankruptcy Bankruptcy

Be as complete and accurate as possible. If two married people are filing together, both are equally responsible for supplying correct information. If more space is needed, attach

a separate sheet to this form. On the top of any additional pages, write your name and case number (if known). Answer every question.

Part 1: Give Details About Your Marital Status and Where You Lived Before

Part 2: Explain the Sources of Your Income

First Name Middle Name Last Name

First Name Middle Name Last Name

24-90016-mxm-11 Check if this is

an amended

filing

What is your current marital status?

 Married

 Not married

1.

During the last 3 years, have you lived anywhere other than where you live now?

 No

 Yes. List all of the places you lived in the last 3 years. Do not include where you live now.

2.

Within the last 8 years, did you ever live with a spouse or legal equivalent in a community property state or territory?(Community

property states and territories include Arizona, California, Idaho, Louisiana, Nevada, New Mexico, Puerto Rico, Texas, Washington, and

Wisconsin.)

 No

 Yes. Make sure you fill out Schedule H: Your Codebtors (Official Form 106H)

3.

Did you have any income from employment or from operating a business during this year or the two previous calendar years?

Fill in the total amount of income you received from all jobs and all businesses, including part-time activities.

If you are filing a joint case and you have income that you receive together, list it only once under Debtor 1.

 No

 Yes. Fill in the details.

Debtor 1

Sources of income

Check all that apply

Gross income

(before deductions and

exclusions)

Debtor 2

Sources of income

Check all that apply

Gross income

(before deductions and

exclusions)

4.

From January 1 of current year until the date

you filed for bankruptcy:

Wages, commissions,

bonuses, tips

Operating a business

$ 324,000.00

Wages, commissions,

bonuses, tips

Operating a business

$ 

For last calendar year:

(January 1 to December 31, 2023

Wages, commissions,

bonuses, tips

Operating a business

$ 484,586.00

Wages, commissions,

bonuses, tips

Operating a business

$ 

For the calendar year before that:

(January 1 to December 31, 2022

Wages, commissions,

bonuses, tips

Operating a business

$ 487,285.00

Wages, commissions,

bonuses, tips

Operating a business

$ 

Did you receive any other income during this year or the two previous calendar years?

Include income regardless of whether that income is taxable. Examples of other income are alimony; child support; Social Security,

unemployment, and other public benefit payments; pensions; rental income; interest; dividends; money collected from lawsuits; royalties;

and gambling and lottery winnings. If you are filing a joint case and you have income that you received together, list it only once under

Debtor 1.

5.

Official Form 107 Statement of Financial Affairs for Individuals Filing for Bankruptcy page 1 of 11

Case 24-90016-mxm11 Doc 37 Filed 10/23/24 Entered 10/23/24 21:32:48 Desc Main

Document Page 1 of 16
Part 3: List Certain Payments You Made Before You Filed for Bankruptcy

Debtor 1 Debtor 2

Sources of income

Describe below.

Gross income from each

source

(before deductions and

exclusions)

Sources of income

Describe below.

Gross income from each

source

(before deductions and

exclusions)

From January 1 of current

year until the date you

filed for bankruptcy:

Eventide and Braviant

Salary

Interests, Dividends,

Distributions

$

$ 3,324.40

For last calendar year:

(January 1 to December 31,

2023

Eventide and Braviant

Salary

Interests, Dividends,

Distributions

$

$ 407,515.82

For the calendar year

before that:

(January 1 to December 31,

2022

Eventide and Braviant

Salary

Interests, Dividends,

Distributions

$

$ 585,631.70

List each source and the gross income from each source separately. Do not include income that you listed in line 4.

 No

 Yes. Fill in the details.

Dates of payment Total amount paid Amount you still owe Was this payment

for...

Are either Debtor 1’s or Debtor 2’s debts primarily consumer debts?

 No. Neither Debtor 1 nor Debtor 2 has primarily consumer debts. Consumer debts are defined in 11 U.S.C. § 101(8) as

“incurred by an individual primarily for a personal, family, or household purpose.”

During the 90 days before you filed for bankruptcy, did you pay any creditor a total of $7,575* or more?

 No. Go to line 7.

Yes. List below each creditor to whom you paid a total of $7,575* or more in one or more payments and

the total amount you paid that creditor. Do not include payments for domestic support obligations, such

as child support and alimony. Also, do not include payments to an attorney for this bankruptcy case.

* Subject to adjustment on 4/01/25 and every 3 years after that for cases filed on or after the date of adjustment.

 Yes. Debtor 1 or Debtor 2 or both have primarily consumer debts.

During the 90 days before you filed for bankruptcy, did you pay any creditor a total of $600 or more?

 No. Go to line 7.

 Yes. List below each creditor to whom you paid a total of $600 or more and the total amount you paid that

creditor. Do not include payments for domestic support obligations, such as child support and

alimony. Also, do not include payments to an attorney for this bankruptcy case.

6.

09/20/2024

08/12/2024

07/25/2024

07/17/2024

07/09/2024

06/25/2024

06/24/2024

08/12/2024

$ 44,095.76 $ 42,006.61

 Mortgage

 Car

 Credit card

 Loan repayment

 Suppliers or

vendors

 Other 

Citibank

Creditor’s Name

Bankruptcy Dep

PO Box 790034

Street Number

Saint Louis

City

MO

State

63179

ZIP Code

Debtor Case number(if known) 24-90016-mxm-11 Matthew Brandon Martorello

First Name Middle Name Last Name

Official Form 107 Statement of Financial Affairs for Individuals Filing for Bankruptcy page 2 of 11

Case 24-90016-mxm11 Doc 37 Filed 10/23/24 Entered 10/23/24 21:32:48 Desc Main

Document Page 2 of 16
Part 4: Identify Legal Actions, Repossessions, and Foreclosures

09/10/2024 $ 28,733.00 $ Unknown

 Mortgage

 Car

 Credit card

 Loan repayment

 Suppliers or

vendors

 Other 

CPA Services and Tax

Returns

David French & Assoc

Creditor’s Name

609 Castle Ridge Rd Ste 445

Street Number

Austin

City

TX

State

78746

ZIP Code

06/28/2024 $ 50,000.00 $ 0.00

 Mortgage

 Car

 Credit card

 Loan repayment

 Suppliers or

vendors

 Other 

Galloway v. Martorello QSF

Creditor’s Name

P.O. Box 23489

Street Number

Jacksonville

City

FL

State

32241

ZIP Code

Dates of payment Total amount paid Amount you still owe Reason for this payment

Within 1 year before you filed for bankruptcy, did you make a payment on a debt you owed anyone who was an insider? Insiders

include your relatives; any general partners; relatives of any general partners; partnerships of which you are a general partner;

corporations of which you are an officer, director, person in control, or owner of 20% or more of their voting securities; and any managing

agent, including one for a business you operate as a sole proprietor. 11 U.S.C. § 101. Include payments for domestic support obligations,

such as child support and alimony.

 No.

 Yes. List all payments to an insider.

7.

$ Unknown $ 0.00

See Gift Section, mortgage

payment forbearance. One

year of payments would

approximate $9240.

Alexis Morris

Creditor’s Name

3861 Gaspar Dr

Street Number

Dallas

City

TX

State

75220

ZIP Code

Within 1 year before you filed for bankruptcy, did you make any payments or transfer any property on account of a debt that benefited an

insider?

Include payments on debts guaranteed or cosigned by an insider.

 No.

 Yes. List all payments that benefited an insider.

8.

Nature of the case Court or agency Status of the

case

Within 1 year before you filed for bankruptcy, were you a party in any lawsuit, court action, or administrative proceeding?

List all such matters, including personal injury cases, small claims actions, divorces, collection suits, paternity actions, support or custody modifications,

and contract disputes.

 No

 Yes. Fill in the details.

9.

Application of usury law dispute,

and extension of potential

liability, regarding a loan

originated by a tribal lender on

its reservation where borrower

online was in Massachusetts.;

Date filed: 10/31/2018

 Pending

 On appeal

 Concluded

Case title: 

Duggan v. Martorello, et al.

Case number: 

1:18-cv-12277-JGD

US District Court - Massachusetts

Court Name

1 Courthouse Way Suite 2300

Street Number

Boston

City

MA

State

02210

ZIP Code

Debtor Case number(if known) 24-90016-mxm-11 Matthew Brandon Martorello

First Name Middle Name Last Name

Official Form 107 Statement of Financial Affairs for Individuals Filing for Bankruptcy page 3 of 11

Case 24-90016-mxm11 Doc 37 Filed 10/23/24 Entered 10/23/24 21:32:48 Desc Main

Document Page 3 of 16
Part 5: List Certain Gifts and Contributions

Application of usury law dispute,

and extension of potential

liability, regarding a loan

originated by a tribal lender on

its reservation where borrower

online was in Oregon.; Date

filed: 09/11/2018

 Pending

 On appeal

 Concluded

Case title: 

Smith v. Martorello, et al

Case number: 

3:18-cv-01651-AR

US District Court - Oregon

Court Name

1000 Southwest 3rd Ave

Street Number

Portland

City

OR

State

97204-2944

ZIP Code

Defendants sold securities

without a license, and

misinformed buyers about the

securities. Defendants filed

counterclaims for commissions.;

Date filed: 12/05/2022

 Pending

 On appeal

 Concluded

Case title: 

Matthew Martorello, et al v The

Summit Investment Group,

LLC, et al

Case number: 

3:22-cv-01602-CVR

US District Court- Puerto Rico

Court Name

300 Recinto Sur St Suite 325

Street Number

San Juan

City

PR

State

00901

ZIP Code

Dispute regarding applicable

usury law, and extension of

potential liability, regarding loans

originated by a tribal lender on

its reservation where involving

borrowers online in Virginia.

Virginia consumer class action,

borrowers from 6/22/2013 -

12/20/2019.; Date filed:

06/22/2017

 Pending

 On appeal

 Concluded

Case title: 

Williams v. Big Picture Loans,

LLC

Case number: 

3:17-cv-461-REP

US District Court - Eastern District of Virginia

Court Name

701 E Broad Street

Street Number

Richmond

City

VA

State

23219

ZIP Code

BPL sued Eventide's legal

representative law firms, and the

lawyers personally, and Debtor

as Manager of Eventide alleging

that BPL's lawyers were

defrauded by the Eventide

agents when they asserted

rulings in Virginia constituted a

material adverse effect under

the terms of a Loan and Security

Agreement; Date filed:

08/27/2024

 Pending

 On appeal

 Concluded

Case title: 

Big Picture Loans, LLC v Matt

Martorello, et al

Case number: 24-cv-05

Lac Vieux Desert Band - Tribal Court

Court Name

E23968 Pow Wow Trail PO Box 39

Street Number

Watersmeet

City

MI

State

49969

ZIP Code

Application of usury law dispute,

and extension of potential

liability, regarding loans

originated by a tribal lender on

its reservation involving certain

online borrowers.; Date filed:

06/11/2018

 Pending

 On appeal

 Concluded

Case title: 

Galloway et al v. Big Picture

Loans, LLC et al

Case number: 

3:18-cv-00406-REP

US District Court - Eastern District of Virginia

Court Name

701 East Broad Street

Street Number

Richmond

City

VA

State

23219

ZIP Code

Within 1 year before you filed for bankruptcy, was any of your property repossessed, foreclosed, garnished, attached, seized, or levied?

Check all that apply and fill in the details below.

 No. Go to line 11.

 Yes. Fill in the information below.

10.

Within 90 days before you filed for bankruptcy, did any creditor, including a bank or financial institution, set off any amounts

from your accounts or refuse to make a payment because you owed a debt?

 No

 Yes. Fill in the details

11.

Within 1 year before you filed for bankruptcy, was any of your property in the possession of an assignee for the benefit of

creditors, a court-appointed receiver, a custodian, or another official?

 No

 Yes

12.

Within 2 years before you filed for bankruptcy, did you give any gifts with a total value of more than $600 per person?

 No

 Yes. Fill in the details for each gift.

13.

Debtor Case number(if known) 24-90016-mxm-11 Matthew Brandon Martorello

First Name Middle Name Last Name

Official Form 107 Statement of Financial Affairs for Individuals Filing for Bankruptcy page 4 of 11

Case 24-90016-mxm11 Doc 37 Filed 10/23/24 Entered 10/23/24 21:32:48 Desc Main

Document Page 4 of 16
Part 6: List Certain Losses

Part 7: List Certain Payments or Transfers

Gifts with a total value of more than $600

per person

Describe the gifts Dates you gave

the gifts

Value

Person’s relationship to you sister

776.01 in mortgage payment forgiveness since hardship

estimated in 2020, paid principal off 5/16/24. 776.01 * 24

months = stated value. Date given is the start of the 2 year

period.

09/20/2022 $ 18,624.24

Alexis Morris

Person to Whom You Gave the Gift

3861 Gaspar Dr

Street Number

Dallas

City

TX

State

75220

ZIP Code

Gifts or contributions to charities that total

more than $600

Describe what you contributed Date you

contributed

Value

Donation to ESD Booster Club 10/24/2022 $ 1,000.00

Gifts or contributions to charities that total

more than $600

Describe what you contributed Date you

contributed

Value

School General Fund 10/24/2022 $ 2,500.00

Within 2 years before you filed for bankruptcy, did you give any gifts or contributions with a total value of more than $600 to any charity?

 No

 Yes. Fill in the details for each gift or contribution.

14.

Episcopal School of Dallas Fund

Charity’s Name

ESD Boost

Street Number

Dallas

City

TX

State

75229

ZIP Code

Episcopal School of Dallas Fund

Charity’s Name

ESD Fund

Street Number

Dallas

City

TX

State

75229

ZIP Code

Within 1 year before you filed for bankruptcy or since you filed for bankruptcy, did you lose anything because of theft, fire, other disaster, or

gambling?

 No

 Yes. Fill in the details.

15.

Description and value of any property transferred Date payment or

transfer was

made

Amount of

payment

Money. Also $10 via Venmo. $8400 was invoiced 3/18/2024

but $6840 was paid 3/21/24. Unclear as to difference.

3/21/2024

1/5/2024

$ 6,840.00

$ 6,840.00

Within 1 year before you filed for bankruptcy, did you or anyone else acting on your behalf pay or transfer any property to

anyone you consulted about seeking bankruptcy or preparing a bankruptcy petition?

Include any attorneys, bankruptcy petition preparers, or credit counseling agencies for services required in your bankruptcy.

 No

 Yes. Fill in the details.

16.

Vida Law Firm

Person Who Was Paid

3000 Central Dr

Street Number

Bedford

City

TX

State

76021

ZIP Code

https://www.vida-law.com/

Email or website address

Person Who Made the Payment, if Not You

Debtor Case number(if known) 24-90016-mxm-11 Matthew Brandon Martorello

First Name Middle Name Last Name

Official Form 107 Statement of Financial Affairs for Individuals Filing for Bankruptcy page 5 of 11

Case 24-90016-mxm11 Doc 37 Filed 10/23/24 Entered 10/23/24 21:32:48 Desc Main

Document Page 5 of 16
Description and value of any property transferred Date payment or

transfer was

made

Amount of

payment

Cash 03/13/2024

09/09/2024

$ 937.50

$ 187.50

Description and value of any property transferred Date payment or

transfer was

made

Amount of

payment

Paid invoice 11/06/2023 $ 6,100.00

$ 

Description and value of any property transferred Date payment or

transfer was

made

Amount of

payment

01/19/2024

02/23/2024

$ 9,281.25

$ 12,825.00

Description and value of any property transferred Date payment or

transfer was

made

Amount of

payment

04/15/2024

08/20/2024

$ 3,543.75

$ 14,512.50

Meadows Collier

Person Who Was Paid

901 Main St

Ste 3700

Street Number

Dallas

City

TX

State

75202

ZIP Code

https://www.meadowscollier.com/

Email or website address

Person Who Made the Payment, if Not You

Vida Law Firm

Person Who Was Paid

3000 Central Dr

Street Number

Bedford

City

TX

State

76021

ZIP Code

https://www.vida-law.com/

Email or website address

Rebecca Martorello (Spouse)

Person Who Made the Payment, if Not You

Winikka Law PLLC

Person Who Was Paid

6060 North Central Expressway

Suite 500

Street Number

Dallas

City

TX

State

75206

ZIP Code

Email or website address

Person Who Made the Payment, if Not You

Winikka Law PLLC

Person Who Was Paid

6060 North Central Expressway

Suite 500

Street Number

Dallas

City

.

State

75206

ZIP Code

Email or website address

Person Who Made the Payment, if Not You

Debtor Case number(if known) 24-90016-mxm-11 Matthew Brandon Martorello

First Name Middle Name Last Name

Official Form 107 Statement of Financial Affairs for Individuals Filing for Bankruptcy page 6 of 11

Case 24-90016-mxm11 Doc 37 Filed 10/23/24 Entered 10/23/24 21:32:48 Desc Main

Document Page 6 of 16
Description and value of any property transferred Date payment or

transfer was

made

Amount of

payment

09/10/2024

09/20/2024

$ 51,300.00

Winikka Law PLLC $ 19,068.75

Person Who Was Paid

6060 North Central Expressway

Suite 500

Street Number

Dallas

City

TX

State

75206

ZIP Code

Email or website address

Person Who Made the Payment, if Not You

Within 1 year before you filed for bankruptcy, did you or anyone else acting on your behalf pay or transfer any property to

anyone who promised to help you deal with your creditors or to make payments to your creditors?

Do not include any payment or transfer that you listed on line 16.

 No

 Yes. Fill in the details.

17.

Description and value of

property transferred

Describe any property or payments received

or debts paid in exchange

Date transfer

was made

Within 2 years before you filed for bankruptcy, did you sell, trade, or otherwise transfer any property to anyone, other than

property transferred in the ordinary course of your business or financial affairs?

Include both outright transfers and transfers made as security (such as the granting of a security interest or mortgage on your property).

Do not include gifts and transfers that you have already listed on this statement.

 No

 Yes. Fill in the details.

18.

Person’s relationship to you Spouse

2011 Mercedes Benz ML 350

for trade-in credit on new car

purchase (estimated 10k),

$10,000.00

none 12/31/2022

Rebecca Martorello

Person Who Received Transfer

3805 Greenbrier Dr

Number Street

Dallas

City

TX

State

75225

ZIP Code

Person’s relationship to you Spouse

Assigned Debtor's undivided

one-half interest in his

homestead

08/14/2023

Rebecca Martorello

Person Who Received Transfer

3805 Greenbrier Dr

Number Street

Dallas

City

TX

State

75225

ZIP Code

Person’s relationship to you Spouse

Car Purchase, $66,534.71 12/31/2022

Rebecca Martorello

Person Who Received Transfer

3805 Greenbrier Dr

Number Street

Dallas

City

TX

State

75225

ZIP Code

Debtor Case number(if known) 24-90016-mxm-11 Matthew Brandon Martorello

First Name Middle Name Last Name

Official Form 107 Statement of Financial Affairs for Individuals Filing for Bankruptcy page 7 of 11

Case 24-90016-mxm11 Doc 37 Filed 10/23/24 Entered 10/23/24 21:32:48 Desc Main

Document Page 7 of 16
Part 8: List Certain Financial Accounts, Instruments, Safe Deposit Boxes, and Storage Units

Part 9: Identify Property You Hold or Control for Someone Else

Describe any property or payments received or debts paid in exchange Date transfer

was made

Within 10 years before you filed for bankruptcy, did you transfer any property to a self-settled trust or similar device of which

you are a beneficiary?(These are often called asset-protection devices.)

 No

 Yes. Fill in the details.

19.

Name of trust Matthew B Martorello

Management Trust - Revocable

$10 and Pour Over Will at Death and manage Debtor's estate if he becomes

incapacitated, $10.00

07/16/2018

Within 1 year before you filed for bankruptcy, were any financial accounts or instruments held in your name, or for your benefit,

closed, sold, moved, or transferred?

Include checking, savings, money market, or other financial accounts; certificates of deposit; shares in banks, credit unions,

brokerage houses, pension funds, cooperatives, associations, and other financial institutions.

 No

 Yes. Fill in the details.

20.

Do you now have, or did you have within 1 year before you filed for bankruptcy, any safe deposit box or other depository for

securities, cash, or other valuables?

 No

 Yes. Fill in the details.

21.

Who else has or had access to it? Describe the contents Do you still have

it?

(Storage unit 1 items -- kids items,

maternity clothing, misc household

goods, carpet or rugs, furniture, certain

nominal art works)., $500.00

 No

 Yes

(Storage unit 2 items -- kids items,

maternity clothing, misc household

goods, carpet or rugs, furniture, certain

nominal art works)., $500.00

 No

 Yes

Have you stored property in a storage unit or place other than your home within 1 year before you filed for bankruptcy

 No

 Yes. Fill in the details.

22.

Extra Space

Name of Storage Facility

4920 McKinney Ave

Number Street

Dallas

City

TX

State

75205

ZIP Code

Rebecca Martorello

Name

3805 Greenbrier Dr

Number Street

Dallas

City

TX

State

75205

ZIP Code

Public Storage

Name of Storage Facility

2439 Swiss Ave

Number Street

Dallas

City

TX

State

75204

ZIP Code

Rebecca Martorello

Name

3805 Greenbrier Dr

Number Street

Dallas

City

TX

State

75225

ZIP Code

Where is the property? Describe the property Value

In the storage units listed herein, there

could be some artwork items in there

which belong to BWH Texas, LLC estate.

The belongs in storage could also be

owned by Debtor's Spouse or children.

$ Unknown

Child UTMA account - Fidelity (Son 1)

$ 36,602.38

Do you hold or control any property that someone else owns? Include any property you borrowed from, are storing for,

or hold in trust for someone.

 No

 Yes. Fill in the details.

23.

BWH Texas, LLC

Owner’s Name

3805 Greenbrier Dr

Street Number

Dallas

City

TX

State

75225

ZIP Code

Street Number

.

City

TX

State

.

Martorello Son 1 ZIP Code

Owner’s Name

3805 Greenbrier Dr

Street Number

Dallas

City

TX

State

75225

ZIP Code

One Chase Manhattan Plaza

Street Number

New York

City

.

State

10005

ZIP Code

Debtor Case number(if known) 24-90016-mxm-11 Matthew Brandon Martorello

First Name Middle Name Last Name

Official Form 107 Statement of Financial Affairs for Individuals Filing for Bankruptcy page 8 of 11

Case 24-90016-mxm11 Doc 37 Filed 10/23/24 Entered 10/23/24 21:32:48 Desc Main

Document Page 8 of 16
Part 10: Give Details About Environmental Information

Part 11: Give Details About Your Business or Connections to Any Business

Child UTMA Account - Fidelity (Son 2)

$ 36,601.18

Child UTMA account - Fidelity (Son 3)

$ 2,253.78

Child UTMA account - Tolleson (Son 2)

$ 3,592.55

Child UTMA account - Tolleson (Son 1)

$ 1,412.24

Martorello Son 2

Owner’s Name

3805 Greenbrier Dr

Street Number

Dallas

City

TX

State

75225

ZIP Code

One Chase Manhattan Plaza

Street Number

New York

City

NY

State

10005

Martorello Son 3 ZIP Code

Owner’s Name

3805 Greenbrier Dr

Street Number

Dallas

City

TX

State

75225

ZIP Code

One Chase Manhattan Plaza

Street Number

New York

City

.

State

10005

Martorello Son 2 ZIP Code

Owner’s Name

3805 Greenbrier Dr

Street Number

Dallas

City

TX

State

75225

ZIP Code

5550 Preston Rd

Street Number

Dallas

City

TX

State

75205

Martorello Son 1 ZIP Code

Owner’s Name

3805 Greenbrier Dr

Street Number

Dallas

City

TX

State

75225

ZIP Code

5550 Preston Rd

Street Number

Dallas

City

TX

State

75205

ZIP Code

For the purpose of Part 10, the following definitions apply:

Environmental law means any federal, state, or local statute or regulation concerning pollution, contamination, releases of

hazardous or toxic substances, wastes, or material into the air, land, soil, surface water, groundwater, or other medium,

including statutes or regulations controlling the cleanup of these substances, wastes, or material.

Site means any location, facility, or property as defined under any environmental law, whether you now own, operate, or utilize

it or used to own, operate, or utilize it, including disposal sites.

Hazardous material means anything an environmental law defines as a hazardous waste, hazardous substance, toxic

substance, hazardous material, pollutant, contaminant, or similar term.

Report all notices, releases, and proceedings that you know about, regardless of when they occurred.

Has any governmental unit notified you that you may be liable or potentially liable under or in violation of an environmental law?

 No

 Yes. Fill in the details.

24.

Have you notified any governmental unit of any release of hazardous material?

 No

 Yes. Fill in the details.

25.

Have you been a party in any judicial or administrative proceeding under any environmental law? Include settlements and orders.

 No

 Yes. Fill in the details.

26.

Within 4 years before you filed for bankruptcy, did you own a business or have any of the following connections to any business?

 A sole proprietor or self-employed in a trade, profession, or other activity, either full-time or part-time

 A member of a limited liability company (LLC) or limited liability partnership (LLP)

 A partner in a partnership

 An officer, director, or managing executive of a corporation

 An owner of at least 5% of the voting or equity securities of a corporation

 No. None of the above applies. Go to Part 12.

 Yes. Check all that apply above and fill in the details below for each business.

27.

Debtor Case number(if known) 24-90016-mxm-11 Matthew Brandon Martorello

First Name Middle Name Last Name

Official Form 107 Statement of Financial Affairs for Individuals Filing for Bankruptcy page 9 of 11

Case 24-90016-mxm11 Doc 37 Filed 10/23/24 Entered 10/23/24 21:32:48 Desc Main

Document Page 9 of 16
Describe the nature of the business

GP share in a real estate development project.

Project was foreclosed on by the bank in '24 and

equity wiped out.

Name of accountant or bookkeeper

David French & Assoc

Employer Identification number

Do not include Social Security number or

ITIN.

EIN: 8 2 – 4 6 4 0 3 3 3

Dates business existed

From 03/08/2018 To Current

Describe the nature of the business

LP share in a real estate development project.

Project was foreclosed on by the bank in '24 and

equity wiped out.

Name of accountant or bookkeeper

David French & Assoc

Employer Identification number

Do not include Social Security number or

ITIN.

EIN: 8 2 – 4 6 7 6 3 4 7

Dates business existed

From 03/08/2018 To Current

Describe the nature of the business

100% owner. Holding entity for Jet Business

Loans, LLC ownership, a non-operating business

which hopes for recovery from an approximate

$700k uncollectible debt and that debtor's claims

being executed by one of its third-party vendors.

Name of accountant or bookkeeper

David French & Assoc

Employer Identification number

Do not include Social Security number or

ITIN.

EIN: 8 2 – 1 9 5 5 0 7 5

Dates business existed

From 02/14/2014 To Current

Describe the nature of the business

Inactive. Bank balance $43.77.

Name of accountant or bookkeeper

David French & Assoc

Employer Identification number

Do not include Social Security number or

ITIN.

EIN: 3 8 – 4 0 9 1 4 2 8

Dates business existed

From 08/01/2018 To Current

Describe the nature of the business

LLC management company. The entity is owed

indemnity and $115,544.46 from Eventide. It

owns very small interests in two restaurants. It

owns a 50% stake in a LLC holding entity that

raised capital for investment into a venture fund

where said entity may earn a performance fee,

and it has approximately $17k in cash.

Name of accountant or bookkeeper

David French & Assoc

Employer Identification number

Do not include Social Security number or

ITIN.

EIN: 4 7 – 2 7 8 7 2 2 0

Dates business existed

From 01/14/2015 To Current

Describe the nature of the business

Owner of 25.5% of Eventide Credit Acquisitions,

LLC. Indemnitee of Eventide, creditor of

Eventide. Owned minority non-controlling

interests in LLCs formed to launch a credit fund

which never launched and were terminated. But

still owns a 45% minority non-controlling interest

in the LLC owning the name (though not

operating).

Name of accountant or bookkeeper

David French & Assoc

Employer Identification number

Do not include Social Security number or

ITIN.

EIN: 4 7 – 4 2 1 9 4 5 9

Dates business existed

From 06/08/2015 To Current

GFGP Entity I, LP

Business Name

3805 Greenbrier Dr

Street Number

Dallas

City

TX

State

75225

ZIP Code

GFLP Entity 1, LP

Business Name

3805 Greenbrier Dr

Street Number

Dallas

City

TX

State

75225

ZIP Code

New Summit, LLC

Business Name

3805 Greenbrier Dr

Street Number

Dallas

City

TX

State

75225

ZIP Code

Gallant Distributions, LLC

Business Name

3805 Greenbrier Dr

Street Number

Dallas

City

TX

State

75225

ZIP Code

Liont, LLC

Business Name

3805 Greenbrier Dr

Street Number

Dallas

City

TX

State

75225

ZIP Code

Gallant Capital, LLC

Business Name

3805 Greenbrier Dr

Street Number

Dallas

City

TX

State

75225

ZIP Code

Within 2 years before you filed for bankruptcy, did you give a financial statement to anyone about your business? Include all financial 

institutions, creditors, or other parties.

 No. None of the above applies. Go to Part 12.

 Yes. Check all that apply above and fill in the details below for each business.

28.

Debtor Case number(if known) 24-90016-mxm-11 Matthew Brandon Martorello

First Name Middle Name Last Name

Official Form 107 Statement of Financial Affairs for Individuals Filing for Bankruptcy page 10 of 11

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Part 12: Sign Below

I have read the answers on this Statement of Financial Affairs and any attachments, and I declare under penalty of perjury that the 

answers are true and correct. I understand that 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 $250,000, or imprisonment for up to 20 years, or both.

18 U.S.C. §§ 152, 1341, 1519, and 3571.

Date 10/23/2024

/s/ Matthew Brandon Martorello

Signature of Debtor 1

Date 

Signature of Debtor 2

Did you pay or agree to pay someone who is not an attorney to help you fill out bankruptcy forms?

 No

 Yes. Name of person Attach the Bankruptcy Petition Preparer’s Notice, 

Declaration, and Signature (Official Form 119).

Debtor Case number(if known) 24-90016-mxm-11 Matthew Brandon Martorello

First Name Middle Name Last Name

Official Form 107 Statement of Financial Affairs for Individuals Filing for Bankruptcy page 11 of 11

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Matthew Brandon Martorello, Case 24-90016-mxm-11 Global Notes to Schedules/Statements

MATTHEW BRANDON MARTORELLO, CASE 24-90016-MXM-11 

GENERAL NOTES AND STATEMENTS OF LIMITATIONS, METHODOLOGY, AND 

DISCLAIMERS REGARDING DEBTOR’S SCHEDULE OF ASSETS AND LIABILITIES 

AND STATEMENT OF FINANCIAL AFFAIRS 

On September 20, 2024, (the “Petition Date”), Matthew Brandon Martorello (the “Debtor”) 

commenced his case under title 11 of the United States Code (the “Bankruptcy Code”) in the United 

States Bankruptcy Court for the Northern District of Texas (the “Bankruptcy Court”), Case No. 

24-90016-mxm-11. The Debtor is authorized to manage his property as debtor-in-possession 

pursuant to section 1107(a) of the Bankruptcy Code. 

OVERVIEW OF GENERAL NOTES

The Debtor has herewith filed his Schedules of Assets and Liabilities (“Schedules”) and Statements 

of Financial Affairs (“Statements”). These General Notes and Statement of Limitations, 

Methodology, and Disclaimers Regarding Debtor’s Schedules and Statements (the “General 

Notes”) relate to the Debtor’s Schedules and Statements and set forth the basis upon which the 

Schedules and Statements are presented. These General Notes comprise an integral part of the 

Schedules and Statements and should be referred to and considered in connection with any 

review of the Schedules and Statements. The General Notes are in addition to any specific notes 

contained in the Debtor’s Schedules or Statements. Nothing contained in the Schedules and 

Statements shall constitute a waiver of any rights or claims of the Debtor against any third party, 

or in or with respect to any aspect of the chapter 11 case. 

The Schedules and Statements have been prepared, pursuant to section 521 of the Bankruptcy Code 

and Bankruptcy Rule 1007, by the Debtor with the assistance of his counsel. While the Debtor has 

made reasonable efforts to ensure that the Schedules and Statements are accurate and as complete 

as possible based on information that was available to him at the time of preparation, given the 

complexity and substantial business interests of the Debtor over the years and the complexity of the multiple 

litigation claims, subsequent information or discovery could provide more information about the items 

identified in the Schedules and Statements, and inadvertent errors or omissions may have occurred. 

The Debtor is the Manager of Eventide Credit Acquisitions, LLC (“Eventide”) and the President 

of Liont LLC, the Manager for BWH Texas, LLC (“BWH”). Eventide and BWH are both debtors 

and debtors in possession in this Court, jointly administered under Case 23-90007-mxm-11. 

Nothing contained in the Schedules and Statements shall constitute a waiver of any of the Debtor’s 

rights with respect to the chapter 11 cases.

Matthew Martorello: Schedules and Statements Global Notes

1. Amendment. Reasonable efforts have been made to prepare and file complete and 

accurate Schedules and Statements. Despite these efforts, inadvertent errors or omissions may 

exist. The Debtor reserves all rights to, but are not required to, amend or supplement, or both, the 

Schedules and Statements from time to time as is necessary and appropriate. 

2. Recharacterization. The Debtor has made reasonable efforts to correctly 

characterize, classify, categorize, and designate assets, liabilities, executory contracts, unexpired 

leases, and other items reported in the Schedules and Statements. However, the Debtor may have 

improperly characterized, classified, categorized, or designated certain items. The Debtor thus 

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Matthew Brandon Martorello, Case 24-90016-mxm-11 Global Notes to Schedules/Statements

reserves all of rights to recharacterize, reclassify, recategorize, or redesignate items reported in the 

Schedules and Statements as necessary or appropriate as additional information becomes available. 

3. Causes of Action. Despite the reasonable efforts to identify all known assets, the 

Debtor may not have listed all the causes of action or potential causes of action against third parties 

as assets in its Schedules and Statements. The Debtor reserves rights with respect to any claims or 

causes of action he may have, and neither these Global Notes nor the Schedules and Statements 

shall be deemed a waiver of any such claims or causes of action or in any way prejudice or impair 

the assertion of such claims or causes of action. 

4. Claim Description. Any failure to designate a claim in the Schedules and 

Statements as “contingent,” “unliquidated,” or “disputed” does not constitute an admission that 

such claim or amount is not “contingent,” unliquidated,” or “disputed.” The Debtor reserves the 

right to dispute, or to assert offsets or defenses to, any claim reflected on these Schedules on any 

grounds, including, without limitation, amount, liability, priority, status, or classification, or to

otherwise subsequently designate any claim as “contingent,” “unliquidated,” or “disputed.” 

Moreover, the Debtor reserves all rights to, but are not required to, amend the Schedules and 

Statements as necessary and appropriate, including modifying claims descriptions and 

designations. 

5. Unliquidated Claim Amounts. Claim amounts that could not be readily quantified 

by the Debtor are scheduled as “unliquidated.” To the extent the Debtor is able to ascertain or 

estimate all or a portion of the claim amounts, he may have listed the known or estimated claim 

amount and marked the claims as unliquidated, pending final resolution of outstanding issues 

necessary to determine the total claim amount with certainty. 

6. Totals. All totals that are included in the Schedules and Statements represent totals 

of all the known amounts included in the Schedules and Statements and exclude items identified 

as “undetermined” or “unliquidated.” To the extent that there are undetermined or unliquidated 

amounts, the actual totals may be materially different from the listed totals. 

Specific Disclosures with Respect to the Debtor’s Schedules

7. Schedule A/B. Bank account balances are as of the petition filing on September 

20, 2024 in all cases but one, which could differ from the reported value by an estimated tens of 

dollars or less. With respect to tax refunds owed, the Debtor has noted an unused NOL 

Carryforward on item 28. The amount of the NOL Carryforward is $19,985,324. The value, 

however, is listed as unknown as it is unclear whether it could ever be monetized. 

The Debtor’s family residence at 3805 Greenbriar Drive is titled solely in name of the Debtor’s 

spouse, and the Debtor therefore has not listed it as his asset. The Debtor, however, asserts a 

homestead exemption in whatever equitable or other interest he has or may later be determined to 

have in that home. 

The Debtor owns 100% of Liont LLC. Liont LLC owns a computer, printer and home office 

furniture. Liont owns legal title to those items, but the Debtor uses those items both for Liont 

business and for personal matters and has listed those items as business-related property in which 

the Debtor could be said to have an equitable interest. 

The Debtor and his spouse have had separate property agreements pursuant to a pre-nuptial 

agreement established in March 2012, and amended and restated as recently as 2018 upon their 

relocation to Texas, and they maintain their property separately. Pursuant to their agreements, 

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Matthew Brandon Martorello, Case 24-90016-mxm-11 Global Notes to Schedules/Statements

they have no community property. 

The Debtor’s membership at Trinity Forest Golf Club is frozen and no payments have been made 

or will be required. The Debtor does not know the redemption value, but believes it would have 

allotted a 20 to 25% recovery based on the value at the time of purchase (less than $50k), though 

it has substantially decreased in value since his purchase. 

In litigation pending in the Eastern District of Virginia, Williams v. Big Picture Loans, LLC et al. 

Case 3:17-cv-461-REP, the consumer borrower plaintiffs filed a Motion to Repatriate Foreign 

Assets, seeking an “accounting of all foreign assets, directly or indirectly, owned, controlled, 

managed, transferred by, or affiliated with Mr. Martorello; and delivery of all such assets to the 

registry of this Court or to an escrow account maintained and established by a third-party” to 

facilitate collection on a judgment against the Debtor. The Debtor opposed that motion. The court 

in Virginia has not considered the motion. In 2010, the Debtor, through his counsel, and Guardian 

Trust Corporation as trustee, settled a Cook Islands irrevocable spendthrift discretionary trust (the 

“Bluetech Trust”). Guardian Trust Corporation was a subsidiary of a large and reputable 

international trust management company, duly licensed in the Cook Islands. The Debtor’s mother 

and siblings were the beneficiaries. In 2013, the Guardian Trust Corporation settled a Nevis 

irrevocable discretionary spendthrift trust (the “Capstone Trust”). Bluetech was the sole 

beneficiary of the Capstone Trust and the trustee for the Capstone Trust was Asiatrust Nevis 

Limited. The Debtor has not made any contributions to Bluetech since 2013. The Bluetech Trust’s 

corpus stemmed not from the Debtor, but almost entirely from the Bluetech Trust’s ownership 

distributions from a holding company over several businesses, which the Debtor also owned in 

part and managed. The Debtor has never made any contributions to the Capstone Trust. The 

Capstone Trust was amended and restated in 2018, and the Debtor’s spouse and three children 

became the direct beneficiaries rather than Bluetech. The Bluetech Trust and the Capstone Trust 

are both foreign trusts pursuant to section 7701(a)(31) of the Internal Revenue Code and grantor 

trusts pursuant to section 679 of the Internal Revenue Code. As “grantor trusts” Matt is deemed 

the “tax owner” of each trust for U.S. tax purposes, even though he has no control over, and is not 

a beneficiary of, either trust. As the U.S. tax owner, Matt is responsible for reporting the trusts’ 

assets, income and transfers to the IRS. The consumer borrower plaintiffs in the Williams case 

assert that all these assets that Matt is required to report as the “tax owner” should be available to 

pay their judgment against the Debtor, which payment the Debtor could effectuate under threat of 

contempt and imprisonment, and that the Bluetech and Capstone trusts are de-facto self-settled 

trusts. The Debtor disputes that the assets of the Capstone Trust (the Bluetech Trust was 

terminated in 2023) or similarly characterized trusts (or entities owned by such trusts)—which are 

reported on the Debtor’s tax returns because the Debtor or his spouse is the “tax owner”—are his 

assets or that he has any legal or equitable interest in those assets, nor any rights or authority to 

access, transmit or send those assets to this estate, and is therefore not listing the assets of such 

trusts on his Schedules or as self-settled. Because the Williams plaintiffs assert otherwise, 

however, the Capstone Trust assets and those of similarly situated trusts (or entities owned by such 

trusts) are, under Brown v. Chestnut (In re Chestnut), 422 F.3d 298, 301 (5th Cir. 2005), arguably 

property of the Debtor’s estate and thus the automatic stay unquestionably applies to any attempts 

to collect or exercise control over those assets, which the Williams plaintiffs have asserted are in 

fact property of the Debtor’s estate. This Court, exercising its exclusive jurisdiction over property 

of the estate, will likely need to resolve this dispute and enforce the automatic stay against stated 

intentions to violate the stay by pursuing the control over and recovery of these assets elsewhere. 

The Debtor has listed a possible fraudulent conveyance action relating to his prior ownership of 

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Matthew Brandon Martorello, Case 24-90016-mxm-11 Global Notes to Schedules/Statements

shares in a private, regulated company (the “Regulated Company”) that has become very 

successful. The substance of the claim stems from a commonplace estate planning effort to 

enable the equity in the Regulated Company to grow free from federal estate tax for the benefit 

of the Debtor’s descendants. The Debtor’s shares, held through a Texas limited partnership in 

which the Debtor initially held 100% of the limited partner and general partner interests, were 

sold in 2018 (via a transfer of limited partner interests) to Texas trusts in exchange for two 

promissory notes, which currently aggregate a little over $20 million and are the Debtor’s 

primary asset in this case along with his rights to indemnity from Eventide. The Debtor had been 

a trustee for those trusts in some periods past, but no longer controls those trusts and was never a 

beneficiary of those trusts. Substantial payments had been made on the notes prior to October 

2021 when the note was restructured to address the impacts on the Regulated Company that 

occurred because of the pandemic, increasing inflation and lost markets due to regulatory 

changes. The maturity date on the notes is now 9/30/41 and the notes pay IRS AFR (at that time 

1.74%) with all interest and principal deferred to maturity. In 2022, the Regulated Company 

entered negotiations with a third-party purchaser for a sale of the shares in stages at a valuation 

of over $100 million. In connection with that potential transaction, the purchaser required that a 

new sister trust and LLC be formed, and the shares be transferred to the new structure to help 

insulate the Regulated Company from licensing risks considering the pending litigation against 

the Debtor. The new sister trust and LLC committed to transfer cash inflows from the shares to 

the original trust and obligor on the notes for purposes of paying the notes. Shortly before the 

anticipated consummation of that deal, however, inflation spiked, the Yen crashed and the global 

corporation shut down all acquisitions. In January 2024, the consumer borrower plaintiffs in 

Williams v. Big Picture Loans, LLC et al. Case 3:17-cv-461-REP, pending in Eastern District of 

Virginia, filed a motion seeking to set aside the Debtor’s transfer of the Regulated Company 

shares. Before any response to that motion was due, however, the Debtor and the consumer 

borrower plaintiffs entered into a contingent, global settlement relating to the Debtor’s potential

liability to consumers nationwide that obtained loans from the LVD Tribe through May 1, 2024, 

which settlement provided for a stay of all litigation pending the process for determining if the 

required funding for the settlement could be accomplished. The Debtor does not believe there is 

any merit to this potential fraudulent transfer claim given, among other things, the third-party 

valuations of the shares, the notes, and the Debtor’s solvency that were done for purposes of the 

transfer and the time period in which it occurred. More importantly, though, pursuit of the 

potential fraudulent transfer claim relating to the Debtor’s transfer of the shares could severely 

risk both the value of the estate’s assets and the value of the Regulated Company given the 

licensing requirements and approvals required by the highly regulated bank partners of the 

Regulated Company that are necessary for greater than 10% owners. Unwinding the transaction 

to bring the shares into the Debtor’s estate could create a major licensing and regulatory 

challenge for the Regulated Company, possibly collapsing the value of the shares and thereby the 

value of the Debtor’s notes. 

8. Schedule F: Creditors Holding Unsecured Non-Priority Claims. The inclusion of 

any litigation in these Schedules and Statements does not constitute an admission by the Debtor of 

liability, the validity of any action, or the amount or treatment of any claims, defenses, 

counterclaims, or cross-claims or the amount or treatment of any potential claim resulting from any 

current or future litigation. 

9. Schedule G: Executory Contracts and Unexpired Leases. The Debtor hereby 

reserves the right to dispute the validity, status, or enforceability of any contracts, agreements or 

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Matthew Brandon Martorello, Case 24-90016-mxm-11 Global Notes to Schedules/Statements

leases set forth in Schedule G and to amend or supplement such Schedule as necessary. Nothing 

herein shall be construed as a concession or evidence that any of the contracts, agreements or leases

identified on Schedule G: (i) constitute an executory contract within the meaning of section 365 of 

the Bankruptcy Code or other applicable law; or (ii) have not expired or been terminated or 

otherwise are not current in full force and effect. The Debtor reserves the rights, claims and causes 

of action with respect to the contracts and agreements listed on the Schedule, including the right 

to dispute or challenge the characterization or the structure of any transaction or document.

10. Schedules I/J. The Debtor’s spouse is paying family living expenses and has paid 

their various and separate litigation fees, including the prepetition payment of the $150,000 

retainer to Winikka Law PLLC and a post-petition payment of a $200,000 retainer to Meadows 

Collier for their joint representation of the Debtor and his spouse. Any stub period accounts 

payable (invoices for a service period that includes in part a prepetition period) from various 

utilities and related subscription or service providers at the time of the bankruptcy filing were paid 

by the Debtor’s spouse to maintain such services for their collective benefit. Accordingly, those 

service providers do not have prepetition claims against the Debtor. These service providers 

include: AT&T, Terminix, Atmos Energy, Change4Electric, University Park gas, waste and trash 

services, pool care, Netflix and related subscriptions and lawn care provider Opulent Gardens, 

Park House and Equinox memberships (spouse). The Debtor’s spouse also recently paid in full for 

home insurance (6 months) and auto and umbrella insurance (annual) and is paying the Debtor’s 

automobile loan payments. Prior to the petition date, the Debtor paid for his kids’ school tuition 

for the full school year and has paid his CPA for his bookkeeping and tax requirements and filings 

(via retainer). Family health insurance through the Debtor’s employer is currently being deducted

from the Debtor’s salary. The Debtor ceased all 401(k) payment withdrawals from his W2 salary 

upon filing his bankruptcy petition. 

Specific Disclosures with Respect to the Debtor’s Statements

11. Question 4: Income from Employment. The Debtor has included his accrued salary 

of $40,000 a month from Eventide Credit Acquisitions, LLC. Eventide, however, has not paid the 

Debtor’s salary since September 2023 when it filed for relief under chapter 11 of the Bankruptcy 

Code. 

12. Question 5: Other Income. Although not income, since September 2023, when the 

Debtor’s salary and indemnity rights from Eventide were cut off by Big Picture Loan LLC’s 

default on its debt obligations to Eventide, the Debtor has borrowed approximately $1,495,592 

from his spouse through 25 transactions, for litigation and ordinary living expenses. Of that

amount, $250,000 was documented as a Note, and the remainder subject to agreement for identical 

treatment. Until September 2023, the Debtor had funded family expenses, including paying his 

spouse’s credit card in the ordinary course. After September 2023, the Debtor’s spouse began 

paying her own credit card and the loans from his spouse ensued. 

13. Question 23: Property Held in Trust for Others. The filing of the Debtor’s petition 

caused the removal of the Debtor from his position as trustee over the following trusts and 

managership of their subsidiaries: the Martorello 2018 Children’s Trust, the RLM Management 

Trust, the RLM 2018 Family Trust, and the Martorello 2023 Children’s Trust. The Debtor’s AGI 

reporting will not match tax reporting due to differences between legal ownership, tax ownership 

and joint filings. 

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