Liz Boydston (SBN 24053684) 

Alexandria Rahn (SBN 24110246) 

GUTNICKI LLP

10440 N. Central Expressway, Suite 800

Dallas, Texas 75231

Telephone: (469) 895-4413

Facsimile: (469) 895-4413 

lboydston@gutnicki.com 

arahn@gutnicki.com

PROPOSED COUNSEL TO THE DEBTORS 

AND DEBTORS IN POSSESSION

Max Schlan (Pro Hac Vice Pending)

Ren-Ann Wang (Pro Hac Vice Pending) 

GUTNICKI LLP

45 Rockefeller Plaza, Suite 2000 

New York, New York 10111 

Telephone: (646) 825-2330 

Facsimile: (646) 825-2330 

mschlan@gutnicki.com 

rwang@gutnicki.com 

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

In re:

TOMMY’S FORT WORTH, LLC,

Debtor. 

)

) 

) 

) 

) 

) 

)

Chapter 11

Case No. 24-90000-11

In re:

TOMMY’S LEWISVILLE, LLC, 

Debtor. 

)

) 

) 

) 

) 

)

Chapter 11

Case No. 24-90001-11

In re:

HIGH COUNTRY WATERSPORTS, LLC, 

Debtor. 

)

) 

) 

) 

) 

)

Chapter 11

Case No. 24-90002-11

In re:

TOMMY’S GRAND RAPIDS, 

Debtor. 

)

) 

) 

) 

) 

)

Chapter 11

Case No. 24-90003-11

In re:

MKB FLORIDA HOLDINGS, LLC, 

)

) 

) 

)

Chapter 11

Case No. 24-90004-11

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Document Page 1 of 19
2

Debtor. )

)

In re:

TOMMY’S CALIFORNIA FRESNO, 

LLC,

Debtor.

)

)

)

)

)

)

)

Chapter 11

Case No. 24-90005-11

In re:

TOMMY’S STOCKTON, LLC,

Debtor.

)

)

)

)

)

)

)

Chapter 11

Case No. 24-90006-11

In re:

TOMMY’S CALIFORNIA VENTURA, 

LLC,

Debtor.

)

)

)

)

)

)

Chapter 11

Case No. 24-90007-11

In re:

TOMMY’S CASTAIC, LLC,

Debtor.

)

)

)

)

)

)

Chapter 11

Case No. 24-90008-11

In re:

TOMMY’S KNOXVILLE, LLC,

Debtor.

)

)

)

)

)

)

)

Chapter 11

Case No. 24-90009-11

In re:

TOMMY’S CHATTANOOGA, LLC,

Debtor.

)

)

)

)

)

)

Chapter 11

Case No. 24-90010-11

In re:

TOMMY’S RANCHO CORDOVA, LLC,

)

)

)

)

)

Chapter 11

Case No. 24-90011-11

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Document Page 2 of 19
3 

Debtor. )

In re:

TOMMY’S DETROIT, LLC, 

Debtor. 

)

) 

) 

) 

) 

)

Chapter 11

Case No. 24-90012-11

In re:

WALLOON LAKE VILLAGE MARINA, 

LLC, 

Debtor. 

)

) 

) 

) 

) 

) 

)

Chapter 11

Case No. 24-90013-11

In re:

TOMMY’S LAS VEGAS, LLC, 

Debtor. 

)

) 

) 

) 

) 

)

Chapter 11

Case No. 24-90014-11

In re:

TOMMY’S PHOENIX, LLC, 

Debtor. 

)

) 

) 

) 

) 

)

Chapter 11

Case No. 24-90015-11

In re:

TOMMY’S HOLDING COMPANY, LLC,

Debtor. 

)

) 

) 

) 

) 

)

Chapter 11

Case No. 24-41734 

MOTION OF DEBTORS FOR ENTRY OF AN ORDER AUTHORIZING AND 

DIRECTING THE JOINT ADMINISTRATION OF DEBTORS’ CHAPTER 11 CASES

Tommy’s Fort Worth, LLC and each of its debtor-affiliates in the above-captioned 

chapter 11 cases, as debtors and debtors in possession (collectively, the “Debtors”), hereby submit 

this motion (this “Motion”) for entry of an order, substantially in the form attached hereto as 

Exhibit A, pursuant to §§ 105(a) and 342(c)(1) of title 11 of the United States Code (the 

“Bankruptcy Code”), Rule 1015(b) of the Federal Rules of Bankruptcy Procedure (the 

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Document Page 3 of 19
4 

“Bankruptcy Rules”), and Rule 1015-1 of the Local Rules of Bankruptcy Practice and Procedure 

of the United States Bankruptcy Court for the Northern District of Texas (the “Local Rules”), 

directing the joint administration of these chapter 11 cases (these “Chapter 11 Cases”) and the 

consolidation thereof for procedural purposes only. In support of this Motion, the Debtors rely 

upon, and incorporated by reference, the Declaration of Monica Blacker in Support of Chapter 11 

Petitions and First Day Pleadings (the “First Day Declaration”),1 filed contemporaneously with 

this Motion. In further support of this Motion, the Debtors respectfully state as follows: 

I. JURISDICTION AND VENUE

1. The United States Bankruptcy Court for the Northern District of Texas 

(the “Court”) has jurisdiction over these Chapter 11 Cases, the Debtors and their estates and this 

matter under 28 U.S.C. §§ 157 and 1334. This is a core proceeding within the meaning of 

28 U.S.C. § 157(b)(2). The Debtors consent to entry of a final order under Article III of the United 

States Constitution. 

2. Venue of these Chapter 11 Cases and this Motion in this District is proper under 

28 U.S.C. §§ 1408 and 1409. 

3. The statutory bases for the relief requested in this Motion are Bankruptcy Code 

§§ 342(c)(1) and 105(a), Bankruptcy Rules 1005 and 1015, and Local Rule 1015-1. 

II. BACKGROUND

4. On May 20, 2024, each of the Debtors filed voluntary petitions for relief under 

chapter 11 of the Bankruptcy Code. 

5. The Debtors are authorized to operate their businesses and manage their property 

as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. As of the 

1

 Capitalized terms used but not otherwise defined in this Motion shall have the meanings ascribed to them in 

the First Day Declaration.

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Document Page 4 of 19
5 

date hereof, no trustee, examiner, or official committee of unsecured creditors has been appointed 

in these Chapter 11 Cases. 

6. Additional factual background regarding the Debtors, including their business 

operations, capital structure, and the events leading to the filing of these Chapter 11 Cases, is set 

forth in detail in the First Day Declaration, which is fully incorporated by reference herein. 

III. RELIEF REQUESTED

7. By this Motion, the Debtors seek entry of an order, pursuant to sections 342(c)(1) 

and 105(a) of the Bankruptcy Code and Bankruptcy Rules 1005 and 1015, substantially in the form 

attached hereto as Exhibit A, (i) authorizing joint administration of these Chapter 11 Cases for 

procedural purposes only, and (ii) directing parties in interest to use a consolidated caption, 

indicating that any pleading they file relates to the jointly administered bankruptcy cases of 

Tommy’s Fort Worth, LLC, et al. Many of the motions, applications, hearings, and orders that will 

arise in these Chapter 11 Cases will affect all of the Debtors jointly. For that reason, the Debtors 

respectfully submit that their interests, as well as the interests of their creditors and other parties 

in interest, would be best served by the joint administration of these Chapter 11 Cases for 

procedural purposes only. 

8. The Debtors further seek entry of an order directing the Clerk of Court to maintain 

one file and one docket for all these Chapter 11 Cases under the case name Tommy’s Fort Worth, 

LLC. In addition, the Debtors seek the Court’s direction that separate docket entries be made on 

the docket of the other Cases substantially as follows: 

“An order has been entered in this case directing the procedural 

consolidation and joint administration of the chapter 11 cases of 

Tommy’s Fort Worth, LLC and its affiliates that have concurrently 

commenced chapter 11 cases. The docket in the chapter 11 case of 

Tommy’s Fort Worth, LLC, Case No. 24-90000-11 should be 

consulted for all matters affecting this case.”

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Document Page 5 of 19
6 

The Debtors further request that the caption of these Chapter 11 Cases be modified as follows to 

reflect their joint administration: 

IN THE UNITED STATES BANKRUPTCY COURT

FOR NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

)

In re: ) Chapter 11

)

TOMMY’S FORT WORTH, LLC, et al.,

1 ) Case No. 24-90000-11

)

Debtors. ) (Jointly Administered)

)

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). 

IV. BASIS FOR RELIEF

9. Bankruptcy Rule 1015(b)(4) provides that “if . . . two or more petitions are pending 

in the same court by or against . . . a debtor and an affiliate, the court may order joint administration 

of the estates” of the debtor and such affiliates. See Bankruptcy Rule 1015(b)(4). Local Rule 1015-

1 further provides, “[w]hen a case is filed for or against a debtor related to a debtor with a case 

pending in the Bankruptcy Court, a party in interest may file a motion for joint administration in 

each case.” Additionally, “[t]he filing of a joint petition shall be deemed an order directing joint 

administration for the purpose of Bankruptcy Rule 1015, unless the court orders otherwise.” Local 

Rule 1015-1(b). 

10. Section 101(2) of the Bankruptcy Code, defines the term “affiliate,” in pertinent 

part, as:

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Document Page 6 of 19
7

(A) an entity that directly or indirectly owns, controls, or holds with 

power to vote, 20 percent or more of the outstanding voting 

securities of the debtor . . . .

(B) a corporation 20 percent or more of whose outstanding voting 

securities are directly or indirectly owned, controlled, or held with 

power to vote, by the debtor, or by an entity that directly or indirectly 

owns, controls, or holds with power to vote, 20 percent or more of 

the outstanding voting securities of the debtor . . . .

(C) a person whose business is operated under a lease or operating 

agreement by a debtor, or person substantially all of whose property 

is operated under an operating agreement with the debtor; or

(D) an entity that operates the business or substantially all of the 

property of the debtor under a lease or operating agreement. 

See 11 U.S.C. § 101(2).

11. Section 342(c)(1) of the Bankruptcy Code requires, in relevant part, that notice 

“required to be given by the debtor to a creditor. . . shall contain the name, address, and last 4 digits 

of the taxpayer identification number of the debtor.” 11 U.S.C. § 342(c)(1). 

12. Section 105(a) of the Bankruptcy Code provides the Court with the power to grant 

the relief requested herein by permitting the Court to “issue any order, process, or judgment that 

is necessary or appropriate to carry out the provisions of the [Bankruptcy Code].” 

11 U.S.C. § 105(a). 

13. As set forth in the First Day Declaration, each Debtor filed a voluntary petitions 

under chapter 11 of the Bankruptcy Code. Matthew Borisch directly or indirectly owns 100% of 

the interests of each of the Debtors.

2 As such, the Debtors are “affiliates” as that term is defined 

2 Each debtor is owned directly by Matthew Borisch except for Walloon Lake Village Marina, LLC, MKB Florida 

Holdings, LLC, Tommy’s Grand Rapids, LLC and High Country Watersports, LLC, which are each wholly 

owned by the Matthew Allen Borisch Trust, which is in turn wholly owned by Matthew Borisch. Tommy’s 

Detroit, LLC, Tommy’s Stockton, LLC, and Tommy’s Rancho Cordova, LLC each are wholly owned by 

Tommy’s Holding Company, LLC, which is in turn wholly owned by Matthew Borisch.

Case 24-90003-elm11 Doc 2 Filed 05/21/24 Entered 05/21/24 11:44:04 Desc Main

Document Page 7 of 19
8

in Bankruptcy Code § 101(2). Accordingly, the Court is authorized to jointly administer these 

Chapter 11 Cases for procedural purposes only under Bankruptcy Rule 1015(b). 

14. The Debtors operate as an integrated business with common ownership and control. 

The Debtors also share the same financial and operational systems. As a result, many—if not all—

of the motions, hearings, and orders that will arise in these cases will affect all Debtors. Joint 

administration of these Chapter 11 Cases, therefore, will reduce fees and administrative burdens 

by avoiding duplicative filings, objections, notices, and hearings.

15. Joint administration will save time and money and avoid such duplicative and 

potentially confusing filings by permitting counsel for all parties in interest to, among other things, 

(a) use a single caption on the numerous documents that will be served and filed in these 

chapter 11 cases and (b) file the pleadings in one case rather than in multiple cases. Moreover, the 

Court will be relieved of the burden of entering duplicative orders and maintaining duplicative 

files. Also, joint administration will ease the burden on the Office of the United States Trustee in 

supervising these Chapter 11 Cases and will permit the Clerk of the Court to use a main docket for 

all of the Debtors’ cases, allowing the Debtors and other parties in interest to combine notices to 

creditors and other interested parties. Further, joint administration also will protect parties in 

interest by ensuring that parties in each of the Debtors’ respective cases will be apprised of the 

various matters before the Court in these Chapter 11 Cases. 

16. The rights of the respective creditors of each of the Debtors will not be adversely 

affected by joint administration of these cases, as this Motion only requests administrative—and 

not substantive—consolidation of the Debtors’ estates. Each creditor and other party in interest 

will maintain whatever rights it has against each particular estate in which it allegedly has a claim 

or right. Furthermore, joint administration will: (a) reduce the volume of pleadings that otherwise 

Case 24-90003-elm11 Doc 2 Filed 05/21/24 Entered 05/21/24 11:44:04 Desc Main

Document Page 8 of 19
9 

would be filed with the Clerk of the Court, (b) render the completion of various administrative 

tasks less costly, and (c) minimize the number of unnecessary delays associated with the 

administration of numerous separate Chapter 11 Cases. 

17. Joint administration is generally non-controversial, and courts in this jurisdiction 

routinely order joint administration in cases with multiple related debtors. See, e.g., In re Think 

Finance, LLC, et al., Case No. 17-33964 (Bankr. N.D. Tex. Oct. 23, 2017) [Dkt. No. 7]; In re 

Preferred Care, Inc., et al., Case No. 17-44642 (Bankr. N.D. Tex. Nov. 13, 2017) [Dkt. Nos. 89, 

104]; In re Williams Financial Group, Inc., et al., Case No. 17-33578 (Bankr. N.D. Tex. Sept. 24, 

2017) [Dkt No. 39]. Accordingly, based on the foregoing facts and authorities, the Debtors submit 

that the relief requested in this Motion should be granted. 

18. For these reasons, the Debtors submit that the relief requested herein is in the best 

interests of the Debtors, their estates, creditors, and other parties in interest and, therefore, should 

be granted. 

V. NOTICE

19. Notice of this Motion will be provided to the following parties or their counsel, if 

known: (a) the Office of the United States Trustee for Region 6; (b) the Debtors’ prepetition 

secured creditors; (c) the Internal Revenue Service; (d) all relevant state taxing authorities; (e) the 

parties included on the Debtors’ consolidated list of their thirty largest unsecured creditors; and (f) 

any party that has requested notice pursuant to Bankruptcy Rule 2002. In light of the nature of the 

relief requested herein, the Debtors submit that no other or further notice is required. 

VI. NO PRIOR REQUEST

20. No prior request for the relief sought herein has been made to this or any other 

court. 

Case 24-90003-elm11 Doc 2 Filed 05/21/24 Entered 05/21/24 11:44:04 Desc Main

Document Page 9 of 19
10 

WHEREFORE, the Debtors respectfully request that the Court (i) enter an order, 

substantially in the form attached hereto as Exhibit A, granting the relief requested in this Motion, 

and (ii) grant such other and further relief as the Court may deem just and proper. 

Dated: May 21, 2024 Respectfully submitted,

GUTNICKI LLP

/s/Liz Boydston 

Liz Boydston (SBN 24053684) 

Alexandria Rahn (SBN 24110246) 

Gutnicki LLP 

10440 N. Central Expressway, Suite 800

Dallas, Texas 75231

Telephone: (469) 895-4413 

Facsimile: (469) 895-4413 

lboydston@gutnicki.com

arahn@gutnicki.com

-andMax Schlan (Pro Hac Vice Pending) 

Ren-Ann Wang (Pro Hac Vice Pending) 

Gutnicki LLP 

45 Rockefeller Plaza, Suite 2000

New York, New York 10111

Telephone: (646) 825-2330 

Facsimile: (646) 825-2330 

PROPOSED COUNSEL TO THE DEBTORS AND 

DEBTORS IN POSSESSION

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Document Page 10 of 19
EXHIBIT A

Proposed Order

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Document Page 11 of 19
IN THE UNITED STATES BANKRUPTCY COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

In re:

TOMMY’S FORT WORTH, LLC,

Debtor.

)

)

)

)

)

)

)

Chapter 11

Case No. 24-90000-11

In re:

TOMMY’S LEWISVILLE, LLC,

Debtor.

)

)

)

)

)

)

Chapter 11

Case No. 24-90001-11

In re:

HIGH COUNTRY WATERSPORTS, LLC,

Debtor.

)

)

)

)

)

)

Chapter 11

Case No. 24-90002-11

In re:

TOMMY’S GRAND RAPIDS,

Debtor.

)

)

)

)

)

)

Chapter 11

Case No. 24-90003-11

In re:

MKB FLORIDA HOLDINGS, LLC, 

Debtor.

)

)

)

)

)

)

Chapter 11

Case No. 24-90004-11

In re:

TOMMY’S CALIFORNIA FRESNO, 

LLC,

Debtor.

)

)

)

)

)

)

)

Chapter 11

Case No. 24-90005-11

In re:

TOMMY’S STOCKTON, LLC,

)

)

)

)

Chapter 11

Case No. 24-90006-11

Case 24-90003-elm11 Doc 2 Filed 05/21/24 Entered 05/21/24 11:44:04 Desc Main

Document Page 12 of 19
2

Debtor. )

)

)

In re:

TOMMY’S CALIFORNIA VENTURA, 

LLC,

Debtor.

)

)

)

)

)

)

Chapter 11

Case No. 24-90007-11

In re:

TOMMY’S CASTAIC, LLC,

Debtor.

)

)

)

)

)

)

Chapter 11

Case No. 24-90008-11

In re:

TOMMY’S KNOXVILLE, LLC,

Debtor.

)

)

)

)

)

)

)

Chapter 11

Case No. 24-90009-11

In re:

TOMMY’S CHATTANOOGA, LLC,

Debtor.

)

)

)

)

)

)

Chapter 11

Case No. 24-90010-11

In re:

TOMMY’S RANCHO CORDOVA, LLC,

Debtor.

)

)

)

)

)

)

Chapter 11

Case No. 24-90011-11

In re:

TOMMY’S DETROIT, LLC,

Debtor.

)

)

)

)

)

)

Chapter 11

Case No. 24-90012-11

In re:

WALLOON LAKE VILLAGE MARINA, 

LLC,

)

)

)

)

)

)

Chapter 11

Case No. 24-90013-11

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Document Page 13 of 19
3 

Debtor. )

In re:

TOMMY’S LAS VEGAS, LLC,

Debtor. 

)

) 

) 

) 

) 

)

Chapter 11

Case No. 24-90014-11

In re:

TOMMY’S PHOENIX, LLC,

Debtor. 

)

) 

) 

) 

) 

)

Chapter 11

Case No. 24-90015-11

In re:

TOMMY’S HOLDING COMPANY, LLC,

Debtor. 

)

) 

) 

) 

) 

)

Chapter 11

Case No. 24-41734 

ORDER (I) DIRECTING JOINT ADMINISTRATION OF 

DEBTORS’ CHAPTER 11 CASES, AND (II) GRANTING RELATED RELIEF

Upon the Motion of the Debtors for Entry of an Order Authorizing and Directing the Joint 

Administration of the Debtors’ Chapter 11 Cases (the “Motion”),1 filed by the above-captioned 

debtors (collectively, the “Debtors”) for entry of an order (this “Order”) authorizing and directing 

the joint administration of the Debtors’ Chapter 11 Cases for procedural purposes only, all as 

further described in the Motion; and upon consideration of the First Day Declaration and the record 

of these chapter 11 cases; and this Court having found that (i) this Court has jurisdiction over 

the Debtors, their estates, property of their estates, and to consider the Motion and the relief 

requested therein under 28 U.S.C. §§ 157 and 1334, (ii) this is a core proceeding under 

28 U.S.C. § 157(b)(2)(A), (iii) venue of this Motion in this District is proper under 

1

 Capitalized terms used but not otherwise defined in this Order shall have the meanings ascribed to them in the 

Motion.

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Document Page 14 of 19
4 

28 U.S.C. §§ 1408 and 1409, and (iv) due and proper notice of the Motion and the hearing thereon 

has been given as set forth in the Motion and no further or other notice of the Motion is required 

under the circumstances; and this Court having reviewed the Motion and having heard the 

statements in support of the relief requested in the Motion at a hearing before this Court; and 

having determined that the legal and factual bases set forth in the Motion and the First Day 

Declaration establish just cause for the relief granted in this Order; and this Court having found 

and determined that the relief sought in the Motion is in the best interests of the Debtors’ estates, 

their creditors, and other parties in interest; and after due deliberation and sufficient cause 

appearing therefor, 

IT IS HEREBY ORDERED THAT: 

1. The Motion is GRANTED as set forth herein. 

2. The above-captioned Chapter 11 Cases shall be jointly administered by the Court 

and consolidated for procedural purposes only under the case of Tommy’s Fort Worth, LLC, Case 

No. 24-90000-11.

3. If, when filed, these Chapter 11 Cases were assigned to separate judges, all of these 

Chapter 11 Cases shall be transferred to the judge presiding over the case of Tommy’s Fort Worth, 

LLC, Case No. 24-90000-11.

4. Parties in interest are directed to use the proposed caption, attached hereto as 

Exhibit 1, which satisfies the requirements of Bankruptcy Code section 342(c), when filing a 

pleading with the Court in the Debtors’ Chapter 11 Cases, indicating that the pleading relates to 

the jointly administered Cases.

5. The Clerk of this Court shall make a docket entry in each Case (except that of 

Tommy’s Fort Worth, LLC) substantially as follows:

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Document Page 15 of 19
5

“An order has been entered in this case directing the procedural 

consolidation and joint administration of the Chapter 11 Cases of 

Tommy’s Fort Worth, LLC and its affiliates that have concurrently 

commenced chapter 11 cases. The docket in the chapter 11 case of 

Tommy’s Fort Worth, LLC, Case No. 24-90000-11 should be consulted 

for all matters affecting this case.”

6. The Debtors are authorized and empowered to take all actions necessary to 

effectuate the relief granted in this Order in accordance with the Motion.

7. Notice of the Motion as provided therein shall be deemed good and sufficient, and 

the requirements of Bankruptcy Rule 6004(a) and the Local Rules are satisfied by such notice.

8. Notwithstanding the applicability of any Bankruptcy Rule, the terms and conditions 

of this Order shall be immediately effective and enforceable upon its entry.

9. Notwithstanding the relief granted in this Order, any creditor filing a proof of claim 

against any Debtor shall file such proof of claim in the Case of each Debtor to which such claim 

relates.

10. Nothing contained in the Motion or this Order shall be deemed or construed as 

directing or otherwise effecting a substantive consolidation of these Cases.

11. Notwithstanding the relief granted in this Order, each of the Debtors shall file its 

own schedules and statements of financial affairs, which shall be docketed in its respective case.

12. This Court shall retain jurisdiction to hear and determine all matters arising from 

or related to the interpretation, implementation, or enforcement of this Order.

###End of Order####

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Document Page 16 of 19
Proposed Order Submitted By: 

GUTNICKI LLP

/s/ Liz Boydston 

Liz Boydston (SBN 24053684) 

Alexandria Rahn (SBN 24110246) 

10440 N. Central Expy., Suite 800

Dallas, Texas 75231

Telephone: (469) 935-6699 

Facsimile: (469) 895-4413 

lboydston@gutnicki.com 

arahn@gutnicki.com 

-andMax Schlan (Pro Hac Vice to be filed) 

Ren-Ann Wang (Pro Hac Vice to be filed) 

45 Rockefeller Plaza, Suite 2000 

New York, New York 10111 

Telephone: (646) 825-2330 

Facsimile: (646) 825-2330 

mschlan@gutnicki.com

rwang@gutnicki.com

Proposed Counsel to the Debtors and Debtors 

in Possession

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Document Page 17 of 19
EXHIBIT 1 

Proposed Caption 

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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. 24-90000-11

)

Debtors. ) (Jointly Administered)

)

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). 

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