1 

95518419.1 

Katherine M. Devanney (SBN 24116281) 

Elizabeth F. Hayes (SBN 24069001) 

Polsinelli PC 

2950 N. Harwood Street, Suite 2100 

Dallas, TX 75201 

Telephone: (214) 397-0030 

Facsimile: (214) 397-0033 

kdevanney@polsinelli.com

ehayes@polsinelli.com 

COUNSEL TO THE DEBTOR

Andrew J. Nazar (Pro Hac Vice Pending) 

Polsinelli PC 

900 W. 48th Place, Suite 900 

Kansas City, Missouri 64112 

Telephone: (816) 753-1000 

Facsimile: (816) 753-1356 

anazar@polsinelli.com 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

In re: 

ICED TEA WITH LEMON, LLC, 

Debtor.

Chapter 7 

Case No. 24-41976-elm7 

MOTION FOR EXTENSION OF TIME FOR FILING 

SCHEDULES AND STATEMENT OF FINANCIAL AFFAIRS 

Iced Tea With Lemon, LLC (the “Debtor”), hereby moves this Court (the “Motion”) for 

entry of an Order, substantially in the form of Exhibit A attached hereto, pursuant to sections 

105(a) and 521 of title 11 of the United States Code (the “Bankruptcy Code”), Rule 1007(c) of 

the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule 1007-1(b) of the 

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

Rules”), granting the Debtor a thirteen day (13) extension of time for filing its schedules and 

statement of financial affairs to and including July 3, 2024. In support of the Motion, the Debtor 

represents the following: 

JURISDICTION AND VENUE

1. This Court has jurisdiction over this case pursuant to 28 U.S.C. § 1334. This matter 

is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2)(A). 

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2. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 

3. The statutory and other predicates for the relief requested herein are Bankruptcy 

Code sections 105(a) and 521, Bankruptcy Rule 1007(c), and Local Rule 1007-1(b). 

BACKGROUND 

4. On June 6, 2024, the Debtor filed its petition for relief under Chapter 7 of the 

Bankruptcy Code. In addition to the above captioned Debtor, six other affiliated entities also filed 

for relief under Chapter 7 of the Bankruptcy Code. 

5. After filing its petition, the Debtor provided operational and other pertinent 

information to the Chapter 7 Trustee, allowing the Trustee to quickly understand the Debtor’s 

business and operations and thus helping to preserve the value of the Chapter 7 estate. 

6. In addition, the Debtor, in compliance with Local Rule 1007-1(b), certifies that it 

conferred with the Office of the United States Trustee and the Chapter 7 Trustee to determine 

whether this Motion would be opposed. Both confirmed that the Motion would be unopposed. 

RELIEF REQUESTED 

7. Pursuant to Bankruptcy Code section 521 and Bankruptcy Rule 1007(c), the Debtor 

is obligated to file its schedules and statement of financial affairs within fourteen (14) days after 

filing its petition. 

8. By this Motion, the Debtor seeks an extension of thirteen (13) days to file its 

schedules and statement of financial affairs, or until, and including, July 3, 2024. This additional 

time will provide the Debtor with an opportunity to thoroughly prepare the schedules and will 

result in an accurate reporting of the information required to be disclosed therein. Prior to filing, 

the Debtor ran multiple businesses at multiple locations, and thus, the extra time will benefit all 

parties by ensuring accuracy for the Debtor and its affiliates. The Debtor is currently compiling 

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95518419.1 

the necessary information to accurately depict its current assets and financial information required 

to be disclosed in its schedules and to ensure it is complete. 

9. This is the Debtor’s first request for an extension and, at this time, the Debtor 

believes that no further extension will be required. 

NOTICE

10. Notice of this Motion will be provided to: (a) the U.S. Trustee; (b) the Chapter 7 

Trustee; and (c) any party that has requested notice pursuant to Bankruptcy Rule 2002. 

11. The Debtor respectfully submits that, in light of the relief requested herein, no other 

or further notice need be given. 

NO PRIOR REQUEST 

12. No previous request for the relief sought herein has been made to this Court or any 

other court. 

[Remainder of Page Intentionally Left Blank] 

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WHEREFORE, the Debtor respectfully requests that the Court enter the Proposed Order, 

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

such other and further relief as may be just and proper. 

Dated: June 11, 2024 POLSINELLI PC 

/s/ Katherine M. Devanney

Katherine M. Devanney (SBN 24116281) 

Elizabeth F. Hayes (SBN 24069001) 

2950 N. Harwood Street, Suite 2100 

Dallas, TX 75201 

Telephone: (214) 397-0030 

Facsimile: (214) 397-0033 

kdevanney@polsinelli.com

ehayes@polsinelli.com 

– and – 

Andrew J. Nazar (Pro Hac Vice Pending) 

900 W. 48th Place, Suite 900 

Kansas City, Missouri 

Telephone: (816) 753-1000 

Facsimile: (816) 753-1536 

anazar@polsinelli.com

COUNSEL TO THE DEBTOR 

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95518419.1 

CERTIFICATE OF CONFERENCE

The undersigned counsel certifies that in accordance with the Local Rule of the United 

States Bankruptcy Court for the Northern District of Texas 1007-1(b), it conferred with the Office 

of the United States Trustee and the Chapter 7 Trustee and the motion is unopposed. 

Dated: June 11, 2024 POLSINELLI PC 

/s/ Katherine M. Devanney

Katherine M. Devanney (SBN 24116281) 

Elizabeth F. Hayes (SBN 24069001) 

2950 N. Harwood Street, Suite 2100 

Dallas, TX 75201 

Telephone: (214) 397-0030 

Facsimile: (214) 397-0033 

kdevanney@polsinelli.com

ehayes@polsinelli.com 

– and – 

Andrew J. Nazar (Pro Hac Vice Pending) 

900 W. 48th Place, Suite 900 

Kansas City, Missouri 

Telephone: (816) 753-1000 

Facsimile: (816) 753-1536 

anazar@polsinelli.com

COUNSEL TO THE DEBTOR 

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95518419.1 

Exhibit A

Proposed Order 

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95518419.1 

UNITED STATES BANKRUPTCY COURT 

NORTHERN DISTRICT OF TEXAS 

FORT WORTH DIVISION 

In re: 

ICED TEA WITH LEMON, LLC, 

Debtor.

Chapter 7 

Case No. 24-41976-elm7 

ORDER GRANTING DEBTOR’S MOTION FOR EXTENSION OF TIME FOR FILING 

SCHEDULES AND STATEMENT OF FINANCIAL AFFAIRS 

Upon the motion (the “Motion”) of the above-captioned debtor (the “Debtor”) for entry 

of an order (the “Order”), pursuant to Bankruptcy Code sections 105(a) and 521, Bankruptcy Rule 

1007, and Local Rule 1007-1(b), granting the Debtor a thirteen (13) day extension of time for filing 

its schedules and statement of financial affairs; and this Court having jurisdiction to consider the 

Motion and the relief requested under 28 U.S.C. §§ 157 and 1334; and this Court having found 

that this is a core proceeding under 28 U.S.C. § 157(b)(1); and this Court being able to issue a final 

order consistent with Article III of the United States Constitution; and venue of this proceeding 

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and the Motion in this District being proper pursuant to 28 U.S.C. §§ 1408 and 1409; and this 

Court having found that the Debtor’s notice of the Motion and the opportunity for a hearing on the 

Motion were adequate and appropriate under the circumstances and no other notice need be 

provided; and this Court having found good cause for an extension of time; it is HEREBY 

ORDERED THAT: 

1. The Motion is granted as set forth herein. 

2. The time period within which the Debtor must file its schedules and statement of financial 

affairs is hereby extended thirteen (13) days until, and including, July 3, 2024. 

# # # End of Order # # # 

Submitted by: 

Katherine M. Devanney (SBN 24116281) 

Elizabeth F. Hayes (SBN 24069001) 

Polsinelli PC 

2950 N. Harwood Street, Suite 2100 

Dallas, TX 75201 

Telephone: (214) 397-0030 

Facsimile: (214) 397-0033 

kdevanney@polsinelli.com

ehayes@polsinelli.com 

– and – 

Andrew J. Nazar (Pro Hac Vice Pending) 

Polsinelli PC 

900 W. 48th Place, Suite 900 

Kansas City, Missouri 

Telephone: (816) 753-1000 

Facsimile: (816) 753-1536 

anazar@polsinelli.com

COUNSEL TO THE DEBTOR 

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CERTIFICATE OF SERVICE 

The undersigned hereby certifies that on June 11, 2024, she caused a true and correct copy 

of the foregoing to be served via ECF on all parties registered to receive ECF notice. 

/s/ Katherine M. Devanney 

Katherine M. Devanney 

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