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Full title: Motion for relief from stay Fee amount $188, Filed by Creditor INORCA SAS Objections due by 1/28/2021. (Attachments: # 1 Exhibit A # 2 Exhibit B) (Keen, Thomas)

Document posted on Jan 13, 2021 in the bankruptcy, 6 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Movant holds a purchase money security interest in property (theater seating) which was planned for installation at Debtor’s theater in Alpharetta, Georgia (“Northpoint Location).On or about January 15, 2020, Debtor, Studio Movie Grill Holdings, LLC, ordered luxury electric recliner chairs totaling $758,030.00 from Movant.Debtor agreed to pay Movant the amount of $654,640.00 in exchange for the supply and delivery of the Product to Debtor’s Studio Movie Grill Chisholm Trail location located at 5413 Sierra Springs Lane, Fort Worth, Texas (“Chisholm Location”).On October 16, 2020, Movant filed a Petition against Debtor in Cause No. DC-20-15679, District Court, Judicial District, Dallas County, Texas, seeking payment for the property sold to Debtor.As a result of the foregoing, Movant prays that this Court enter an order vacating and relaxing the stay as to Movant’s collateral, as provided by Section 362, U.S. Bankruptcy Code, as to Studio Movie Grill Holdings, LLC, permitting the Movant to enforce its security interests as though this stay had not been imposed.

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Thomas H. Keen, Esq. The Law Offices of Thomas H. Keen, PLLC Tel: (469) 241-1467 Fax: (972) 499-2446 State Bar No. 11163300 Attorney for INORCA SAS IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION IN RE: § § STUDIO MOVIE GRILL HOLDINGS, § Civil Action No. 20-32633-11 LLC, et al. § DEBTOR § MOTION FOR RELIEF FROM THE AUTOMATIC STAY Plaintiff, INORCA SAS (hereinafter called “Movant,”) by and through the undersigned attorney, complaining of Studio Movie Grill Holdings, LLC, et al., hereinafter called “Debtor,” and would show the Court as follows: 1. This Court has jurisdiction of this proceeding pursuant to §11 U.S.C. Section 362(d), §1301 and this proceeding has been filed in accordance with Rule 9014 of the Bankruptcy Rules. 2. Debtor filed a Petition under Chapter 13 of the U.S. Bankruptcy Code (the “Code”) on October 23, 2020. 3. Movant holds a purchase money security interest in property (theater seating) which was planned for installation at Debtor’s theater in Alpharetta, Georgia (“Northpoint Location). The Northpoint Location is listed by Debtor as a “deferred location” and is subject to an unexpired lease in which Debtor is the Tenant. 4. On or about January 15, 2020, Debtor, Studio Movie Grill Holdings, LLC, ordered luxury electric recliner chairs totaling $758,030.00 from Movant. Debtor agreed to pay Movant

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the amount of $758,030.00 in exchange for the supply and delivery of the Product to Debtor’s Studio Movie Grill Northpoint location located at 7730 Northpoint Pkwy, Alpharetta, Georgia (“Northpoint Location”). 5. On or about February 11, Debtor placed an order for additional items in the amount of $1,290.00. 6. Additionally, on or about March 5, 2020, Debtor, Studio Movie Grill Holdings, LLC, ordered luxury electric recliner chairs totaling $654,640.00 from Movant. Debtor agreed to pay Movant the amount of $654,640.00 in exchange for the supply and delivery of the Product to Debtor’s Studio Movie Grill Chisholm Trail location located at 5413 Sierra Springs Lane, Fort Worth, Texas (“Chisholm Location”). Only some of the theater seating has been installed at the Chisholm Location. 7. Movant attaches the purchase orders for the Northpoint Location in the amount of $758,3030.00, the purchase order for the Chisolm Location in the amount of $654,640.00, as well as the purchase order for $1,290.00 as “Exhibit A.” 8. Although Debtor initially moved to abandon the Chisholm lease, for now, it is continuing that lease. Debtor is now planning to install more of the seating at that Chisholm Location. 9. Movant’s attaches the proof of perfection of the secured interests for both locations as “Exhibit B.” 10. As more seating is physically installed at the referenced locations, it will increase Movant’s cost of repossessing property on which it holds secured claims. 11. Pre-Petition, Debtor failed to pay the invoice from Movant in the amount of $654,640.00 for the seating at the Chisholm Location.

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12. Pre-Petition, Debtor also failed to pay the invoice from Movant in the amount of $758,030.00 for the seating at the Northpoint Location. 13. On October 16, 2020, Movant filed a Petition against Debtor in Cause No. DC-20-15679, District Court, Judicial District, Dallas County, Texas, seeking payment for the property sold to Debtor. 14. The filing of the Bankruptcy Petition by Debtor placed an automatic stay on any recovery proceedings, and Movant has been prohibited from obtaining any relief herein, whether by “self help” or by judicial action. 15. Debtor has neither paid the balance due under the Agreement nor agreed to abandon the collateral to Movant. 16. Movant has established its right to the secured claim. Movant has deemed itself fully secured by the recliners and power supplies and other accessories to be installed at that Northpoint Location and the Chisholm Location in the amount of $758,030.00 and $654,640.00, respectively. 17. Debtor has no equity interest in Movant’s collateral. 18. Movant requests to lift the automatic stay in order to foreclose and remove the collateral from the leased locations. 19. By reason of the above, good and sufficient cause exists for vacating the stay so that Movant may proceed to collect payment and repossess the property. 20. Therefore, under §11 U.S.C., Section 362, the automatic stay should be lifted to allow foreclosure of Movant’s security interest in the collateral. PURSUANT TO LOCAL BANKRUPTCY RULE 4001-1(b), A RESPONSE IS REQURIED TO THIS MOTION, OR THE ALLEGATIONS IN THE MOTION MAY BE

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DEEMED ADMITTED, AND AN ORDER GRANTING THE RELIEF SOUGHT MAY BE ENTERED BY DEFAULT. ANY RESPONSE SHALL BE IN WRITING AND FILED WITH THE CLERK OF THE UNITED STATES BANKRUPTCY COURT AT THE EARLE CABELL FEDERAL BUILDING 1100 COMMERCE ST., RM. 1254, DALLAS, TX 75242-1496 BEFORE CLOSE OF BUSINESS JANUARY 22, 2021, WHICH IS AT LEAST 14 DAYS FROM THE DATE OF SERVICE HEREOF. A COPY SHALL BE SERVED UPON COUNSEL FOR THE MOVING PARTY AND ANY TRUSTEE OR EXAMINEE APPOINTED IN THE CASE. ANY RESPONSE SHALL INCLUDE A DETAILED AND COMPREHENSIVE STATEMENT AS TO HOW THE MOVANT CAN BE “ADEQUATELY PROTECTED” IF THE STAY IS TO BE CONTINUED. 21. Movant has been forced by the Debtor to retain legal counsel to protect its interests in this proceeding, and Debtor should be ordered to pay reasonable attorney’s fees for Movant. 22. The Court should order Debtor to return the collateral in its possession. The collateral is set out in the Petition above as the luxury recliners located at 7730 Northpoint Parkway, Alpharetta, Georgia and 5413 Sierra Springs Lane, Fort Worth, Texas. 23. As a result of the foregoing, Movant prays that this Court enter an order vacating and relaxing the stay as to Movant’s collateral, as provided by Section 362, U.S. Bankruptcy Code, as to Studio Movie Grill Holdings, LLC, permitting the Movant to enforce its security interests as though this stay had not been imposed. PRAYER Movant prays that per section 362(d) of the Bankruptcy Code, this Court enter an order, after due notice and hearing, which will terminate the automatic stay as to Movant, or alternatively,

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that Movant be afforded adequate protection, including but not limited to having all payments brought current and Movant be reimbursed for all of its reasonable attorney’s fees and expenses incurred herein and that Movant be granted such further relief at law or in equity to which Movant may be justly entitled to receive. Respectfully submitted, The Law Offices of Thomas H. Keen, PLLC By: /s/ Thomas H. Keen Thomas H. Keen State Bar No. 11163300 555 Republic Drive, Suite 325 Plano, Texas 75074 Tel: (469) 241-1467 Fax: (972) 432-7566 Attorney for INORCA SAS

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CERTIFICATE OF SERVICE I, Thomas H. Keen, hereby certify that a true and correct copy of the foregoing Document was on all parties consenting to electronic service of this case via the Court’s ECF system for the Northern District of Texas on January 14, 2021, pursuant to the Electronic Filing Procedures in this District. DEBTOR: Studio Movie Grill Holdings, LLC /s/ Thomas H. Keen THOMAS H. KEEN