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Full title: Joinder by The Official Committee of Unsecured Creditors to Debtors Amended Motion for Entry of an Order Confirming Inapplicability of the Automatic Stay or, Alternatively, Relief from Automatic Stay to Proceed with State Court Litigation filed by Creditor Committee Official Committee of Unsecured Creditors (RE: related document(s)649 Amended Motion for relief from stay (related document: 423)). (Manns, Ryan)

Document posted on Feb 18, 2021 in the bankruptcy, 5 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Jointly Administered JOINDER OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS TO DEBTORS’ AMENDED MOTION FOR ENTRY OF AN ORDER CONFIRMING INAPPLICABILITY OF THE AUTOMATIC STAY OR, ALTERNATIVELY, RELIEF FROM AUTOMATIC STAY TO PROCEED WITH STATE COURT LITIGATION A complete list of the Debtors in these chapter 11 cases may be obtained on the website of the Debtors’ claims and noticing agent at https://www.donlinrecano.com/Clients/smgh/Index or, Alternatively, Relief from Automatic Stay to Proceed with State Court Litigation [Docket No. On October 23, 2020 (the “Petition Date”), each of the Debtors filed a voluntary petition with this Court under chapter 11 of the Bankruptcy Code.Michael Esqueda; (ii) Segars Group LLC; (iii) BwanaTheater Partners, LLC; (iv) Spirit Realty, L.P.; and (v) Performance Food Group, Inc. 3.laura.smith@nortonrosefulbright.com Local Counsel to the Official Committee of Unsecured Creditors -and- PACHULSKI STANG ZIEHL & JONES LLP Jeffrey N. Pomerantz (admitted pro hac vice)

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Jeffrey N. Pomerantz (admitted pro hac vice) Kristian W. Gluck (SBT 24038921) Maxim B. Litvak (SBT 24002482) Ryan E. Manns (SBT 24041391) PACHULSKI STANG ZIEHL & JONES LLP Laura L. Smith (SBT 24066039) 10100 Santa Monica Boulevard, 13th Floor NORTON ROSE FULBRIGHT US LLP Los Angeles, CA 90067 2200 Ross Avenue, Suite 3600 Tel: (310) 277-6910 Dallas, TX 75201-7932 Facsimile: (310) 201-0760 Telephone: (214) 855-8000 jpomerantz@pszjlaw.com Facsimile: (214) 855-8200 mlitvak@pszjlaw.com kristian.gluck@nortonrosefulbright.com ryan.manns@nortonrosefulbright.com Robert J. Feinstein (admitted pro hac vice) laura.smith@nortonrosefulbright.com Steven W. Golden (SBT 24099681) PACHULSKI STANG ZIEHL & JONES LLP 780 Third Avenue, 34th Floor New York, NY 10017 rfeinstein@pszjlaw.com sgolden@pszjlaw.com Tel: (212) 561-7700 Facsimile: (212) 561-7777 COUNSEL FOR THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION In re: § Case No. 20-32633-SGJ § STUDIO MOVIE GRILL HOLDINGS, LLC, et al.,1 § Chapter 11 § Debtors. § Jointly Administered JOINDER OF THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS TO DEBTORS’ AMENDED MOTION FOR ENTRY OF AN ORDER CONFIRMING INAPPLICABILITY OF THE AUTOMATIC STAY OR, ALTERNATIVELY, RELIEF FROM AUTOMATIC STAY TO PROCEED WITH STATE COURT LITIGATION The Official Committee of Unsecured Creditors (the “Committee”) of Studio Movie Grill Holdings, LLC, et al. (the “Debtors”) hereby submits joins (this “Joinder”) to the Debtors’ Amended Motion for Entry of an Order Confirming Inapplicability of the Automatic Stay 1 A complete list of the Debtors in these chapter 11 cases may be obtained on the website of the Debtors’ claims and noticing agent at https://www.donlinrecano.com/Clients/smgh/Index

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or, Alternatively, Relief from Automatic Stay to Proceed with State Court Litigation [Docket No. 649] (the “Motion”).2 In support of the Joinder, the Committee respectfully represents as follows: I. BACKGROUND 1. On October 23, 2020 (the “Petition Date”), each of the Debtors filed a voluntary petition with this Court under chapter 11 of the Bankruptcy Code. The Debtors are operating their businesses and managing their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No trustee or examiner has been appointed in these cases. 2. On November 16, 2020, the Office of the United States Trustee appointed the Committee pursuant to section 1102 of the Bankruptcy Code. The Committee consists of the following five (5) members: (i) Michael Esqueda; (ii) Segars Group LLC; (iii) BwanaTheater Partners, LLC; (iv) Spirit Realty, L.P.; and (v) Performance Food Group, Inc. 3. On February 11, 2021, the Debtors filed the Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors [Docket No. 619] (the “Plan”). The Plan is the result of extensive, good-faith negotiations among the Debtors, the Committee, and the Debtors’ secured lenders. Among other things, the Plan provides for the contribution of the Lawsuit against Panterra to the GUC Trust. II. JOINDER 4. The Committee joins in the Motion and concurs with the Debtors that the automatic stay does not apply to the Petition Debtors’ causes of action against Panterra. As the ultimate beneficiary of this litigation, the Committee believes it is appropriate for the Debtors’ causes of action in the Lawsuit to proceed expediently. 2 Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in the Motion and Plan (as defined herein), as applicable.

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III. CONCLUSION WHEREFORE, for all of the foregoing reasons, the Committee requests that the Court grant the Motion, and grant such other and further relief as is appropriate and just.

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Dated: February 19, 2021 Respectfully submitted, NORTON ROSE FULBRIGHT US LLP By: /s/ Ryan E. Manns Kristian W. Gluck (SBT 24038921) Ryan E. Manns (SBT 24041391) Laura L. Smith (SBT 24066039) 2200 Ross Avenue, Suite 3600 Dallas, Texas 75201-7932 Tel: (214) 855-8000 Facsimile: (214) 855-8200 kristian.gluck@nortonrosefulbright.com ryan.manns@nortonrosefulbright.com laura.smith@nortonrosefulbright.com Local Counsel to the Official Committee of Unsecured Creditors -and- PACHULSKI STANG ZIEHL & JONES LLP Jeffrey N. Pomerantz (admitted pro hac vice) Maxim B. Litvak (SBT 24002482) 10100 Santa Monica Boulevard, 13th Floor Los Angeles, CA 90067 Tel: (310) 277-6910 Facsimile: (310) 201-0760 jpomerantz@pszjlaw.com mlitvak@pszjlaw.com Robert J. Feinstein (admitted pro hac vice) Steven W. Golden (SBT 24099681) 780 Third Avenue, 34th Floor New York, NY 10017 Tel: (212) 561-7700 Facsimile: (212) 561-7777 rfeinstein@pszjlaw.com sgolden@pszjlaw.com Lead Counsel to the Official Committee of Unsecured Creditors

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CERTIFICATE OF SERVICE The undersigned attorney hereby certifies that a true and correct copy of the foregoing Joinder was served upon the counsel and parties of record, electronically through the Bankruptcy Court’s Electronic Case Filing System on those parties that have consented to such service, on the 19th day of February, 2021. /s/ Ryan E. Manns