UNITED STATES BANKRUPTCY COURT

FOR THE EASTERN DITRICT OF VIRGINIA 

Alexandria Division

In Re: )

CHAMPAGNE SERVICES, LLC )

) Case No. 16-11683-RGM

Debtor ) Chapter 11

)

)

MOTION TO EXTEND TIME TO FILE CERTIFICATE OF CHAPTER 11 

SMALL BUSINESS PLAND AND DISCLOSURE STATEMENT

COMES NOW the Debtor, Champagne Services, LLC, by and through counsel, 

Whitney Lawrimore Hughes of Westlake Legal Group, and respectfully move this 

Honorable Court for an Order extending Debtor’s time to file its Chapter 11 Small 

Business Plan and Disclosure Statement. In support thereof, Debtors state as follows:

1. A Voluntary Petition for Bankruptcy was filed on May 5, 2016.

2. An Order for Relief was then entered on May 12, 2016.

3. Pursuant to 11 U.S.C. 1121, Debtor is required to file a Plan and Statement for 

Disclosure within 180 days of the Order for Relief. However, the Code 

contemplates an extension for a small business to file its plan and disclosure 

statement within 300 days of the Order for Relief. 

4. The U.S. Trustee in this matter has indicated he is amenable to the extension 

of Debtor filing its plan and disclosure statement within 300 days. 

5. The 300 day deadline is contemplated by the Code for small businesses. 

6. The deadline to file within 180 days is not obtainable because Debtor’s 

application to employ counsel has not yet been approved and because it is a 

small business needing time to establish a viable plan. 

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7. However, there is no indication that the plan will not be approved once Debtor 

has sufficient time to prepare it. Therefore, the plan will, more likely then not, 

be confirmed by the Court within the combined filing and confirmation time 

line.

WHEREFORE, Debtor prays this Court will enter an Order permitting the 

extension of time to complete and to file the Chapter 11 Small Business Plan and 

Disclosure Statement to March 8, 2017; that this Motion be scheduled for hearing on 

October 18th, 2016 at 11:00 am before Judge Mayer; and for such other and further relief 

as this Honorable Court may deem just and proper.

Respectfully submitted,

Champagne Services, LLC

By Counsel

WESTLAKE LEGAL GROUP

/s/_Whitney Lawrimore Hughes______

Whitney Lawrimore Hughes, VSB 82331

46175 Westlake Drive, Suite 320

Potomac Falls, Virginia 20165

Telephone: (703) 406-7616

Facsimile: (703) 444-9498

wlawrimore@westlakelegal.com

Counsel for Debtor

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CERTIFICATE OF SERVICE

I hereby certify that this 3rd day of September, 2016, true copies of the foregoing 

document were sent via first class mail and ECF to the Trustee: 

Office of the United States Trustee

Region 4

115 S. Union Street, Suite 210

Alexandria, Virginia 20314

Can Capital Asset Servicing

155 North 400 West

Suite 315

Salt Lake City, UT 84103-1111

Accord Business Funding 

3730 Kirby Drive

Suite 720

Houston, TX 77098-3933

County of Loudoun Virginia

1 Harrison Street SE

1st Floor

Leesburg, Virginia 20175-3102

Internal Revenue Service

Centralized Insolvency Operations 

PO Box 7346

Philadelphia, PA 19101-7346

Loan Me

1900 S. State College Blvd

Suite 300

Anaheim, CA 92806-6152

Pearl Capital

9th Floor, 100 William Street

New York, NY 10038-0000

Pleasant Properties

905 Monroe Street

Herndon, VA 20170-3209

Can Capital Asset Servicing

2015 Vaughn Rd. NW

Building 500

Kennesaw, GA 30144

WEX BANK

PO BOX 6293

CAROL STREAM IL 60197-6293

Fundbox

300 Montgomery Street 

San Francisco, CA 94104

Geoffrey Crawley

16869 Ivandale Road

Hamilton, Virginia 20158

/s/__Whitney Lawrimore Hughes 

 Whitney Lawrimore Hughes

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