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4421

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craig.martin@us.dlapiper.com

andrew.zollinger@us.dlapiper.com

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

Luxury American Design Holding, LLC 

Debtor. 

Chapter 7 

Case No. 24-_____________ 

EIN: 83-1722556 

In re: 

OKA USA LLC 

Debtor. 

Chapter 7 

Case No. 24-_____________ 

EIN: 30-1135576 

In re: 

OKA USA RETAIL LLC 

Debtor. 

Chapter 7 

Case No. 24-_____________ 

EIN: 85-3999714 

PETITION SCHEDULE 4 

Location of Principal Assets 

The assets of Debtor OKA USA Retail LLC are located at the following locations: 

 4531 McKinney Ave, Dallas, TX 75205, United States 

 3461 W Alabama St, Houston, TX 77027, United States 

 201 River Ridge Pkwy, Jeffersonville, IN 47111, United States 

 44 Main St, Westport, CT 06880, United States 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

Luxury American Design Holding, LLC 

Debtor. 

Chapter 7 

Case No. 24-_____________ 

EIN: 83-1722556 

In re: 

OKA USA LLC 

Debtor. 

Chapter 7 

Case No. 24-_____________ 

EIN: 30-1135576 

In re: 

OKA USA RETAIL LLC 

Debtor. 

Chapter 7 

Case No. 24-_____________ 

EIN: 85-3999714 

PETITION SCHEDULE 10 

Pending Bankruptcy Cases Filed by Affiliated Entities 

On the date hereof, each of the entities listed below filed a petition in the United States Bankruptcy 

Court for the Northern District of Texas for relief under chapter 7 of title 11 of the United States 

Code. 

OKA USA Retail LLC 

OKA USA LLC 

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IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

Luxury American Design Holding, LLC 

Debtor. 

Chapter 7 

Case No. 24-_____________ 

EIN: 83-1722556 

In re: 

OKA USA LLC 

Debtor. 

Chapter 7 

Case No. 24-_____________ 

EIN: 30-1135576 

In re: 

OKA USA RETAIL LLC 

Debtor. 

Chapter 7 

Case No. 24-_____________ 

EIN: 85-3999714 

CONSOLIDATED CORPORATE OWNERSHIP STATEMENT 

AND LIST OF EQUITY INTEREST HOLDERS 

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

following are corporations (as the term is defined in 11 U.S.C. § 101(9)), other than a governmental 

unit, that directly or indirectly own 10% or more of any class of any of the above-listed debtors 

(the “Debtors”) of this chapter 7 cases. 

OKA Direct Limited owns 100% of membership interests of Debtor Luxury American Design 

Holding, LLC. 

Debtor Luxury American Design Holding, LLC owns 100% of membership interests of 

Debtor OKA USA LLC. 

Debtor OKA USA LLC owns 100% of membership interests of Debtor OKA USA Retail 

LLC. 

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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 ______________ _________________________________________________________________________

MM / DD / YYYY Signature of individual signing on behalf of debtor

________________________________________________________________________

Printed name

______________________________________ 

Position or relationship to debtor

Debtor Name __________________________________________________________________ 

United States Bankruptcy Court for the: ______________________ District of __________ 

(State) 

Case number (If known): _________________________ 

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

x Consolidated Corporate Ownership Statement and List of Equity Holders

06/11/2024

Luxury American Design Holding, LLC

Northern Texas

Mark Saunders

Secretary

/s/ Mark Saunders

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OMNIBUS WRITTEN CONSENT 

OF 

THE SOLE MEMBER OF 

LUXURY AMERICAN DESIGN HOLDING, LLC 

June 11, 2024 

The undersigned, being the sole member (the “Member”) of Luxury American Design Holding, 

LLC, a Delaware limited liability company (“LADH”), which is sole member of OKA USA LLC, a Texas 

limited liability company (“OKA USA”), which is the sole member of OKA USA Retail LLC, a Delaware 

limited liability company (“OKA Retail”, and together with LADH and OKA USA, the “Companies”, and 

each individually a “Company”), in conformity with the provisions of the Delaware Limited Liability 

Company Act, and the Texas Business Organizations Code the Member hereby adopts the following written 

consent (the “Written Consent”) as of the date first set forth above: 

Chapter 7 Filing 

WHEREAS, the Member has surveyed potential restructuring options for each Company and 

considered presentations by management and the advisors to such Company regarding the assets, liabilities 

and short- and long-term liquidity situation of such Company, and the impact of the foregoing on such 

Company’s business, prospects and enterprise value; 

WHEREAS, the Member had the opportunity to consult with and ask questions of the 

management, the legal and financial advisors and other consultants to the applicable Company, and has 

fully considered each of the strategic alternatives available to such Company; and 

WHEREAS, in the judgment of the Member, after consulting with the management, legal and 

financial advisors of, and other consultants to, the Companies, it is desirable and in the best interests of the 

Companies, their creditors, their equity holders and other parties in interest, that the Companies each file 

or cause to be filed forthwith a voluntary petition for relief (such voluntary petition commencing a “Chapter 

7 Case”) under Chapter 7 of the United States Bankruptcy Code (Title 11 of the United States Code) (the 

“Bankruptcy Code”). 

RESOLVED, that each Company shall be, and hereby is, authorized to file or cause to be filed 

forthwith a Chapter 7 Case under the provisions of the Bankruptcy Code in the United States Bankruptcy 

Court for the Northern District of Texas, Dallas Division (the “Bankruptcy Court”); and it is further 

RESOLVED, that, to the extent not already appointed and currently serving as such pursuant to 

separate resolutions or consents of each Company, Mark Saunders is appointed as the secretary of each 

Company (the “Authorized Officer”), and the Authorized Officer, acting alone be, and hereby is, 

authorized, empowered and directed to execute and file on behalf of the applicable Company all petitions, 

schedules, lists, motions, certificates, declarations, papers and documents, and to take any and all action 

that any one or more deem necessary or proper to obtain such relief, including, without limitation, any 

action necessary to maintain the ordinary course operation of such Company’s business or to successfully 

prosecute the Chapter 7 Case; and it is further 

RESOLVED, each Company, and, by and through the Authorized Officer, each Company is 

hereby authorized, directed, and empowered (i) to execute and verify the bankruptcy petitions and all 

documents ancillary thereto, and to cause each petition to be filed with the Bankruptcy Court, such petition 

to be filed at such time as the Authorized Officer executing such petition shall determine and to be in the 

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form approved by the Authorized Officer executing such petition, with the execution thereof by the 

Authorized Officer being conclusive evidence of the approval thereof by the Authorized Officer; (ii) to 

make or cause to be made prior to the execution thereof any modifications to each petition or such ancillary 

documents that, in the judgment of such Authorized Officer, may be necessary, appropriate, or desirable in 

connection with each of the Company’s bankruptcy case, and (iii) to review the complete list of creditors 

of each Company (the “Creditor Matrix”) and to cause the Creditor Matrix to be filed with the Bankruptcy 

Court and to execute and file a declaration in support of such Creditor Matrix, which shall be filed at such 

time as the Authorized Officer shall determine and to be in the form approved by the Authorized Officer 

executing such Creditor Matrix, with the execution thereof by the Authorized Officer being conclusive 

evidence of the approval thereof by the Authorized Officer. 

FURTHER RESOLVED, that each Company is authorized, empowered and directed to employ 

the law firm of DLA Piper LLP (US), as general bankruptcy counsel to represent and assist each Company 

in preparing and filing the bankruptcy petitions and related forms, schedules, lists, statements and other 

papers or documents. 

General Authority 

RESOLVED, that the Authorized Officer be, and hereby is, authorized, directed and empowered, 

in the name and on behalf of each Company, or otherwise, to take all such further and other action in 

connection with the resolutions hereinabove adopted as they may deem necessary, advisable, or proper to 

effectuate the intent and accomplish the purposes of the foregoing resolutions and to incur all such fees and 

expenses as any such Authorized Officer deems to be necessary, appropriate or advisable to carry out the 

purposes of the foregoing resolutions and the transactions contemplated thereunder and/or to successfully 

complete the Chapter 7 Case, the taking of any such action or execution of any such documents and/or 

agreements to constitute conclusive evidence and the exercise of such discretionary authority; and it is 

further; and it is further 

RESOLVED, that the omission from these resolutions of any agreement or other arrangement 

contemplated by any of the agreements or instruments described in the foregoing resolutions or any action 

to be taken in accordance with any requirements of any of the agreements or instruments described in the 

foregoing resolutions shall in no manner derogate from the authority of the Authorized Officer to take all 

actions necessary, desirable, advisable or appropriate to consummate, effectuate, carry out or further the 

transactions contemplated by and the intent and purposes of the foregoing resolutions; and it is further 

RESOLVED, that the Member has received sufficient notice of the actions and transactions 

relating to the matters contemplated by the foregoing resolutions, as may be required by the organizational 

documents of each Company, or hereby waive any right to have received such notice; and it is further 

RESOLVED, that the Member hereby ratifies and confirms any and all acts heretofore taken in 

connection with the foregoing resolutions by the Authorized Officer on behalf of each Company in good 

faith in Authorized Officer’s capacities as such officer as the valid and binding acts of such Company duly 

approved by the Member. This consent may be executed by facsimile, telecopy or other electronic means 

or reproduction, and such execution shall be considered valid, binding and effective for all purposes. 

This consent shall be filed with the minutes of the proceedings of each respective Company. 

[remainder of page intentionally left blank]

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904133737.2

IN WITNESS WHEREOF, this unanimous written consent shall be effective as of the date first 

written above. 

SOLE MEMBER OF LUXURY AMERICAN 

DESIGN HOLDING, LLC: 

OKA Direct Limited

By: 

Name: 

Title: 

DocuSign Envelope ID: 5E152AF8-604F-421D-9B44-5E388E0446A9

CEO

Mark Saunders

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B2030 (Form 2030) (12/15) 

1610576048.1 

IN THE UNITED STATES BANKRUPTCY COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

In re: 

Luxury American Design Holding, LLC 

Debtor. 

Chapter 7 

Case No. 24-_____________ 

EIN: 83-1722556 

In re: 

OKA USA LLC 

Debtor. 

Chapter 7 

Case No. 24-_____________ 

EIN: 30-1135576 

In re: 

OKA USA RETAIL LLC 

Debtor. 

Chapter 7 

Case No. 24-_____________ 

EIN: 85-3999714 

DISCLOSURE OF COMPENSATION OF ATTORNEY FOR DEBTOR 

1. Pursuant to 11 U .S.C. § 329(a) and Fed. Bankr. P. 2016(b), I certify that I am the attorney for the

above named debtor(s) and that compensation paid to me within one year before the filing of the

petition in bankruptcy, or agreed to be paid to me, for services rendered or to be rendered on

behalf of the debtor(s) in contemplation of or in connection with the bankruptcy case is as

follows:

For legal services, I have agreed to accept..................................... $75,000.00 

Prior to the filing of this statement I have received ....................... $75,000.00 

Balance Due ................................................................................... $0.00 

2. The source of the compensation paid to me was:

 Debtor Other: OKA USA LLC paid a single, $75,000.00 flat fee on behalf of all 

the debtors for the filings of the debtors.

3. The source of compensation to be paid to me is:

 Debtor Other (specify) 

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B2030 (Form 2030) (12/15) 

1610576048.1 

4. I have not agreed to share the above-disclosed compensation with any other person unless 

they are members and associates of my law firm. 

 I have agreed to share the above-disclosed compensation with a other person or persons who 

are not members or associates of my law firm. A copy of the agreement, together with a list of the 

names of the people sharing in the compensation, is attached. 

5. In return for the above-disclosed fee, I have agreed to render legal service for all aspects of the 

bankruptcy case, including: 

a. Analysis of the debtor’s financial situation, and rendering advice to the debtor in 

determining whether to file a petition in bankruptcy;

b. Preparation and filing of any petition, schedules, statements of affairs and plan which 

may be required;

c. Representation of the debtor at the meeting of creditors and confirmation hearing, and 

any adjourned hearings thereof;

6. By agreement with the debtor(s), the above-disclosed fee does not include the following services: 

CERTIFICATION 

I certify that the foregoing is a complete statement of any agreement or arrangement for 

payment to me for representation of the debtor(s) in this bankruptcy proceeding. 

06/11/2024 /s/ R. Craig Martin

Date Signature of Attorney

DLA Piper LLP (US)

Name of law firm

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