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Full title: Amended application (re:63 Application to extend time to file schedules.) filed by Tea Olive I, LLC. (Kinsella, Steven) (Entered: 01/21/2021)

Document posted on Jan 20, 2021 in the bankruptcy, 5 pages and 0 tables.

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA In re: Tea Olive I, LLC d/b/a Stock+Field, Case No.: 21-30037 Chapter 11 Case Debtor. APPLICATION TO EXTEND TIME TO FILE SCHEDULES AND STATEMENTS TO: The parties in interest as specified in Local Rule 9013-3(a)(2). 1. Tea Olive I, LLC dba Stock + Field (the “Debtor”) filed a voluntary petition for relief under chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”) on January 10, 2021. 2. Pursuant to Rule 1007 of the Federal Rules of Bankruptcy Procedures (the “Bankruptcy Rules”) and Local Rule 1007, the Debtor’s schedules and statements of financial affairs (collectively, the “Schedules and Statements”) are currently due on or before January 25, 2021. 3. This Court has jurisdiction over this Application (the “Application”) pursuant to 28 U.S.C. §§ 157 and 1334, Bankruptcy Rule 5005 and Local Rule 1070-1. This is a core proceeding. 4. This Application arises under 11 U.S.C. § 521(a)(1), Bankruptcy Rule 1007(c) and Local Rule 1007-4(b), and is filed pursuant to Local Rule 9013-4(c). RELIEF REQUESTED 5. By this Application, the Debtor seeks entry of an order extending the deadline by which the Debtor must file its schedules and statements by an additional 14 days.

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BASIS FOR THE RELIEF REQUESTED 6. Completion of the Schedules and Statements requires an expenditure of significant time and effort by an essential small group of the Debtor’s employees. This relatively small essential group has been very busy dealing with all of the various Applications that have been filed with the Court since the case began, in addition to negotiating with lenders; locating information for the creditor matrix (which includes approximately 1,100 entries); and handling other aspects of the Debtor’s efforts to maintain operations and address the lenders, landlords, employee, customers, and vendor issues raised by the filing of the Debtor’s chapter 11 case. 7. The Debtor believes that the quantity of information that must be assembled and compiled and the many employee and professional hours required for the completion of accurate and reliable Schedules and Statements constitutes good and sufficient cause for granting the extension of time requested herein. 8. The Debtor believes that extending the deadline through and including February 8, 2021 will be sufficient to complete, verify, and file the Schedules and Statements. The proposed February 8, 2021 deadline will give the Debtor time to ensure that the Schedules and Statements are complete and accurate, which will benefit all parties in interest. The proposed deadline would also still require that the Schedules and Statements be filed ahead of the meeting of creditors scheduled under Section 341 of the Bankruptcy Code on February 11, 2021. 9. The Debtor believes it will file the Schedules and Statements on or before February 8, 2021. Nonetheless, the Debtor reserves the right to seek further extensions from this Court for good cause shown.

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10. Based on the foregoing, the Debtor submits that the relief requested herein is necessary and appropriate, is in the best interests of its estate and creditors, and should be granted in all respects. 11. This Application is verified, and is accompanied by a proposed order. WHEREFORE, the Debtor respectfully request that this Court enter an order (a) extending the time by which the Debtor must file the Schedules and Statements through and including February 8, 2021, and (b) granting such other and further relief as is just and proper. Dated: January 21, 2021 /s/ Steven R. Kinsella Clinton E. Cutler (#0158094) James C. Brand (#0387362) Steven R. Kinsella (#0392289) Samuel M. Andre (#0399669) FREDRIKSON & BYRON, P.A. 200 South Sixth Street, Suite 4000 Minneapolis, MN 55402-1425 (612) 492-7000 PROPOSED ATTORNEYS FOR THE DEBTOR 71733577 v2

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VERIFICATION I, Matthew F. Whebbe, Chief Manager of the Debtor, declare under penalty of perjury that the facts set forth in the preceding Application are true and correct according to the best of my knowledge, information, and belief. Dated: January _2_1_, 2021 Signed: Matthew F. Whebbe Chief Manager of Tea Olive I, LLC d/b/a Stock+Field

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF MINNESOTA In re: Tea Olive I, LLC d/b/a Stock+Field, Case No.: 21-30037 Chapter 11 Case Debtor. ORDER EXTENDING THE TIME TO FILE SCHEDULES AND STATEMENT OF FINANCIAL OF AFFAIRS This case came before the court on the Debtor’s Application to Extend Time to File Schedules and Statements. Capitalized terms not defined in this order have the meanings ascribed to them in the Application. Based on the Application and all of the files, records, and proceedings in these cases, IT IS ORDERED: The time within which Debtor must file the Schedules and Statements is extended through and including February 8, 2021. Dated: William J. Fisher United States Bankruptcy Judge