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Full title: Affidavit of William K. Snyder in Support of Debtors' Objection to the Motion of Vicki L. Uloth to Modify Stay to Permit Continuation of State Litigation filed by Debtor Studio Movie Grill Holdings, LLC (RE: related document(s)438 Objection). (Veteto, Jeffery)

Document posted on Feb 1, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

HOLDINGS, LLC, et al,, (Jointly Administered) The Debtors in these Chapter 11 cases, along with the last four digits of each Debtor's federal tax identification number, include: Studio Movie Grill Holdings, LLC (6546) ("SMG Holdings"); OHAM Holdings, LLC (0966); Movie Grill Concepts Trademark Holdings, LLC (3096); Movie Grill Concepts I, Ltd. (6645); Movie Grill Concepts III, Ltd. (2793); Movie Grill Concepts IV, Ltd. (1454); Movie Grill Concepts IX, LLC (3736); Movie Grill Concepts VI, Ltd. (6895); Movie Grill Concepts VII, LLC (2291); Movie Grill Concepts X, LLC (6906); Movie Grill Concepts XI, LLC (2837); Movie Grill Concepts XII, LLC (6040); Movie Grill Concepts XIII, LLC (5299); Movie Grill Concepts XIV, LLC (4709); Movie Grill Concepts XIX, LLC (9646); Movie Grill Concepts XL, LLC (4454); Movie Grill Concepts XLI, LLC (4624); Movie Grill Concepts XLII, LLC (2309); Movie Grill Concepts XLIII, LLC (9721); Movie Grill Concepts XLIV, LLC (8783); Movie Grill Concepts XLV, LLC (2570); Movie Grill Concepts XV, LLC (4939); Movie Grill Concepts XVI, LLC (1033); Movie Grill Concepts XVII, LLC (1733); Movie Grill Concepts XVIII, LLC (8322); Movie Grill Concepts )0C, LLC (7300); Movie Grill Concepts XXI, LLC (1508); Movie Grill Concepts XXII, LLC (6748); Movie Grill Concepts XXIV, LLC (5114); Movie Grill Concepts XXIX, LLC (5857); Movie Grill Concepts XXV, LLC (4985); Movie Grill Concepts XXVI, LLC (5233); Movie Grill Concepts XXVII, LLC (4427); Movie Grill Concepts XXVIII, LLC (1554); Movie Grill Concepts XXX, LLC (1431); Movie Grill Concepts XXXI, LLC (3223); Movie Grill Concepts XXXII, LLC (0196); Movie Grill Concepts XXVIII, LLC (1505); Movie Grill Concepts XXXIV, LLC (9770); Movie Grill Concepts XXXIX, LLC (3605); Movie Grill Concepts XXXV, LLC (0571); Movie Grill Concepts XXXVI, LLC (6927); Movie Grill Concepts XXXVII, LLC (6401); Movie Grill Concepts XXXVIII, LLC (9657); Movie Grill Concepts XXIII, LLC (7893); Studio Club, LLC (3023); Studio Club IV, LLC (9440); Movie Grill Concepts XI, LLC (2837); Movie Grill Concepts XLI, LLC (4624); Movie Grill Concepts XLVI, LLC (2344); Movie Grill Concepts XLVII, LLC (5866); Movie Grill Concepts XLVIII, LLC (8601); Movie Grill Concepts XLIX, LLC (0537); Movie Grill Concepts L, LLC (5940); Movie Grill Concepts LI, LLC (7754); Movie Grill Concepts LII, LLC (8624); Movie Grill Concepts LIII, LLC (3066); Movie Grill Concepts LIV, LLC (2018); Movie Grill Concepts LV, LLC (4699); Movie Grill Partners 3, LLC (4200); Movie Grill Partners 4, LLC (1363); Movie Grill Partners 6, LLC (3334); and MGC ManagementI, LLC (3224).I, William K. Snyder, Chief Restructuring Officer of Studio Movie Grill Holdings, LLC and its debtor affiliates (collectively, the "Debtors" or the "SMG"), pursuant to 28 U.S.C. § 1746 hereby declare that the following is true to the best of my knowledge, information, and belief: 1. William Snyder, CRO • CR3 Partners, LLC, acting on behalf of Studio Movie Grill Holdings, LLC and its Debtor A

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Texas Bar No. 22028800 Jeffery M. Veteto Texas Bar No. 24098548 Jay A. Ferguson Texas Bar No. 24094648 LAW OFFICES OF FRANK J. WRIGHT, PLLC 2323 Ross Avenue, Suite 730 Dallas, Texas 75201 Telephone: (214) 935-9100 COUNSEL TO DEBTORS AND DEBTORS-IN-POSSESSION IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION In re: Chapter 11 STUDIO MOVIE GRILL Case No. 20-32633-SGJ HOLDINGS, LLC, et al,, (Jointly Administered) Debtors.' 1 The Debtors in these Chapter 11 cases, along with the last four digits of each Debtor's federal tax identification number, include: Studio Movie Grill Holdings, LLC (6546) ("SMG Holdings"); OHAM Holdings, LLC (0966); Movie Grill Concepts Trademark Holdings, LLC (3096); Movie Grill Concepts I, Ltd. (6645); Movie Grill Concepts III, Ltd. (2793); Movie Grill Concepts IV, Ltd. (1454); Movie Grill Concepts IX, LLC (3736); Movie Grill Concepts VI, Ltd. (6895); Movie Grill Concepts VII, LLC (2291); Movie Grill Concepts X, LLC (6906); Movie Grill Concepts XI, LLC (2837); Movie Grill Concepts XII, LLC (6040); Movie Grill Concepts XIII, LLC (5299); Movie Grill Concepts XIV, LLC (4709); Movie Grill Concepts XIX, LLC (9646); Movie Grill Concepts XL, LLC (4454); Movie Grill Concepts XLI, LLC (4624); Movie Grill Concepts XLII, LLC (2309); Movie Grill Concepts XLIII, LLC (9721); Movie Grill Concepts XLIV, LLC (8783); Movie Grill Concepts XLV, LLC (2570); Movie Grill Concepts XV, LLC (4939); Movie Grill Concepts XVI, LLC (1033); Movie Grill Concepts XVII, LLC (1733); Movie Grill Concepts XVIII, LLC (8322); Movie Grill Concepts )0C, LLC (7300); Movie Grill Concepts XXI, LLC (1508); Movie Grill Concepts XXII, LLC (6748); Movie Grill Concepts XXIV, LLC (5114); Movie Grill Concepts XXIX, LLC (5857); Movie Grill Concepts XXV, LLC (4985); Movie Grill Concepts XXVI, LLC (5233); Movie Grill Concepts XXVII, LLC (4427); Movie Grill Concepts XXVIII, LLC (1554); Movie Grill Concepts XXX, LLC (1431); Movie Grill Concepts XXXI, LLC (3223); Movie Grill Concepts XXXII, LLC (0196); Movie Grill Concepts XXVIII, LLC (1505); Movie Grill Concepts XXXIV, LLC (9770); Movie Grill Concepts XXXIX, LLC (3605); Movie Grill Concepts XXXV, LLC (0571); Movie Grill Concepts XXXVI, LLC (6927); Movie Grill Concepts XXXVII, LLC (6401); Movie Grill Concepts XXXVIII, LLC (9657); Movie Grill Concepts XXIII, LLC (7893); Studio Club, LLC (3023); Studio Club IV, LLC (9440); Movie Grill Concepts XI, LLC (2837); Movie Grill Concepts XLI, LLC (4624); Movie Grill Concepts XLVI, LLC (2344); Movie Grill Concepts XLVII, LLC (5866); Movie Grill Concepts XLVIII, LLC (8601); Movie Grill Concepts XLIX, LLC (0537); Movie Grill Concepts L, LLC (5940); Movie Grill Concepts LI, LLC (7754); Movie Grill Concepts LII, LLC (8624); Movie Grill Concepts LIII, LLC (3066); Movie Grill Concepts LIV, LLC (2018); Movie Grill Concepts LV, LLC (4699); Movie Grill Partners 3, LLC (4200); Movie Grill Partners 4, LLC (1363); Movie Grill Partners 6, LLC (3334); and MGC Management I, LLC (3224).

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DEBTORS' OBJECTION TO THE MOTION OF VICKI L. ULOTH TO MODIFY STAY TO PERMIT CONTINUATION OF STATE COURT LITIGATION I, William K. Snyder, Chief Restructuring Officer of Studio Movie Grill Holdings, LLC and its debtor affiliates (collectively, the "Debtors" or the "SMG"), pursuant to 28 U.S.C. § 1746 hereby declare that the following is true to the best of my knowledge, information, and belief: 1. In accordance with the Order (I) AuthorkingDebtors to Employ and Retain CR3 Partners, to Provide a Chief Restructuring Officer and Additional Personnel and (II) Designating William Snyder as the Chief Restructuring Officer as of the Petition Date Effective October 23, 2020 [Dkt. No. 328] entered in the above-styled bankruptcy proceeding, I am the Chief Restructuring Officer of the Debtors. 2. I have personal knowledge of the facts stated herein, or such facts are based on my review of the Debtors' operations, including the Debtors' books and records, and infoiiiiation obtained from Debtors' employees. 3. I submit this declaration in support of Debtors' Objection to the Motion of Vicki L. Uloth to Modi j Stay to Permit Continuation of State Court Litigation [Dkt. No. 438] (the "Objection")4. The Debtors' bankruptcy filings were necessitated by the negative market effects on the in-person entertainment industry caused by the still ongoing COVID-19 pandemic. The Debtors filed their bankruptcies for the purpose of preserving the value of their assets for the benefit of all stakeholders. Throughout this case, the Debtors have relied upon debtor-in-possession financing, in addition to their decreased revenue, to fund business operations and the administrative expenses associated with the bankruptcy proceedings. 5. Pursuant to the Debtors' general liability insurance policy, as may be applicable to Ms. Uloth's claims, a deductible of $25,000 must be met by the Debtors. Accordingly, the Debtors could be responsible for at least the first $25,000. In fact, if such judgment or settlement was less than that figure, the Debtors might not even have insurance proceeds available for such claims.

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and negotiate a plan. If the automatic stay were to be modified or lifted in order to allow the Litigation (as defined in the Objection) to proceed, it could have negative impacts on these ongoing reorganization efforts through diversion of resources. Individuals that might otherwise be able to devote their attention to the bankruptcy cases might instead be required to review documents, respond to discovery requests, and participate in depositions. Such activities represent a potentially substantialcost by way of distraction. 7. Debtors do not believe that any prejudice will result from continuing the automatic stay with respect to the Litigation for the duration of these bankruptcy cases. Debtors currently anticipate confirmation of a bankruptcy plan within the next two (2) months. All parties with claims against the Debtors will have the opportunity through the claims resolution process to liquidate those claims, at the appropriate time; such time simply has not come. Moreover, the Bankruptcy Code provides a mechanism to estimate claims for voting purposes, if necessary. 8. At the present time, it is necessary for Debtors to focus their efforts 'on plan negotiations and their bankruptcy cases to ensure compliance with bankruptcy obligations and to maximize value for all creditors and parties-in-interest. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on February 2, 2021. William Snyder, CRO • CR3 Partners, LLC, acting on behalf of Studio Movie Grill Holdings, LLC and its Debtor Affiliates