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Full title: Stipulation , Agreement, and Order Approving Amanda Digby's Motion for relief from stay to Continue Prosecuting of State Court Action filed by Debtor Studio Movie Grill Holdings, LLC (related document # 585) Entered on 3/8/2021. (Tello, Chris)

Document posted on Mar 7, 2021 in the bankruptcy, 5 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

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 XX, 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 XXXIII, 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 ManagementThis stipulation, agreement, and order (the “Stipulation and Order”) is entered into by and among Studio Movie Grill Holdings, LLC and its debtor affiliates, as debtors and debtors in possession in the above-captioned chapter 11 cases (collectively, the “Debtors” or the “SMG”) and Amanda Digby, individually, (“Digby”).On February 3, 2021, Digby filed her Motion to Lift Stay (the “Motion”), seeking relief from the automatic stay to continue prosecution of her

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he following constitutes the ruling of the court and has the force and effect therein described. ned March 5, 2021 ____________________________________________________________________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 § 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 XX, 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 XXXIII, 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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STIPULATION, AGREEMENT, AND ORDER APPROVING AMANDA DIGBY’S MOTION FOR RELIEF FROM AUTOMATIC STAY TO CONTINUE PROSECUTING OF STATE COURT ACTION This stipulation, agreement, and order (the “Stipulation and Order”) is entered into by and among Studio Movie Grill Holdings, LLC and its debtor affiliates, as debtors and debtors in possession in the above-captioned chapter 11 cases (collectively, the “Debtors” or the “SMG”) and Amanda Digby, individually, (“Digby”). The Debtors and Digby are collectively referred to in this Stipulation and Order as the “Parties” and each as a “Party.” The Parties hereby stipulate and agree as follows: RECITALS A. On February 3, 2021, Digby filed her Motion to Lift Stay (the “Motion”), seeking relief from the automatic stay to continue prosecution of her pre-petition Georgia state court personal injury action entitled, Amanda Digby v. Movie Grill Concepts XIL, LLC dba Studio Movie Grill, before the Court of Fulton County, State of Georgia (the “State Court Action”). B. The Parties, on the terms and subject to the conditions set forth herein, have reached an agreement so as to allow the prosecution of the State Court Action against Movie Grill Concepts XIL, LLC (the “Party Debtor”) to settlement or judgment and to collect any settlement or judgment obtained solely from the Party Debtor’s insurer. STIPULATION & AGREEMENT 1. This Stipulation and Order shall have no force or effect unless and until it is approved by the Bankruptcy Court. 2. Modification of the Automatic Stay. Upon the approval of this Stipulation and Order by the Court, the automatic stay pursuant to Section 362 of the Bankruptcy Code shall be modified solely to the extent of permitting Digby to (a) prosecute to settlement or judgment the State Court Action against Party Debtor, and any subsequent appeals or writs of review taken by any of the parties thereto, solely for the purposes of determining the liability and damages, if any, of the Party Debtor and (b)

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collect any such settlement or judgment solely from the proceeds of the Party Debtor’s insurance policy, the full extent of any such judgment or settlement as may be available under such policy. 3. Waiver of Claims Against Estates. Digby hereby waives and relinquishes any claims that she ever had, now has, or hereafter can, shall, or may have against the assets or properties of the Debtors’ estates, without prejudice to her recovery, if any, from the Party Debtor’s insurer by way of compromise and settlement or judgment or otherwise, provide that such recovery is not made form the assets or properties of the Debtors and would not result in any costs to the Debtors. 4. Scope of Stay Relief. Except to the extent expressly set forth in Paragraph 2 hereof, the provisions of Section 362 of the Bankruptcy Code, including without limitation those provisions prohibiting execution, enforcement, or collection of any judgment that may be obtained against the Debtors and against any assets or properties of the Debtors’ estates (as defined in Section 541 of the Bankruptcy Code), shall remain in full force and effect, and neither Digby nor any of her agents, attorneys, or representatives shall take any action or attempt to cause any action to be taken to collect all or any portion of any such judgment from the assets or properties of the Debtors’ estates, without prejudice to her recovery, if any, from the Party Debtor’s insurer by way of compromise and settlement or judgment or otherwise, provide that such recovery is not made form the assets or properties of the Debtors and would not result in any costs to the Debtors. Nothing contained herein shall constitute or operate as a waiver or modification of the automatic stay so as to permit the prosecution against any of the Debtors of any claims by any person or entity other than Digby with respect to the State Court Action. 5. Authority. Each person or entity that executes this Stipulation and Order on behalf of a Party hereto represents that she or she is duly authorized to execute this Stipulation on behalf of such Party.

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6. Execution. This Stipulation and Order may be executed simultaneously in one or more counterparts, and by different parties hereto in separate counterparts, and with facsimile or email signatures being deemed originals, each of which when executed shall be deemed an original, but all of which taken together shall constitute one and the same instrument. 7. Benefit. This Stipulation and Order and all of the provisions hereof shall be binding upon, and inure to the benefit of, the Parties hereto and their respective successors and assigns. 8. Amendment. This Stipulation and Order may not be modified, altered, amended, or vacated in any way except by a writing signed by all Parties hereto. 9. Governing Law. This Stipulation and Order shall be governed by, and construed in accordance with, the laws of the State of Texas, except to the extent that the Bankruptcy Code applies, without regard to principles of conflicts of law that would require the application of laws of another jurisdiction. The Bankruptcy Court shall retain exclusive jurisdiction to resolve any dispute or controversies arising from this Stipulation and Order. # # # END OF ORDER # # # STIPULATED AND AGREED: LAW OFFICES OF FRANK J. WRIGHT, PLLC By: /s/ Frank J. Wright Frank J. Wright Texas Bar No. 22028800 Jeffery M. Veteto Texas Bar No. 24098548 Jay A. Ferguson Texas Bar No. 24094648

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2323 Ross Avenue, Suite 730 Dallas, Texas 75201 Telephone: (214) 935-9100 Emails: fwright@fjwright.law jeff@fjwright.law jay@fjwright.law ATTORNEYS FOR DEBTORS AND DEBTORS-IN-POSSESSION and THE PRITCHARD LAW FIRM By: /s/ David L. Pritchard David L. Pritchard Texas Bar No.16349990 1244 Southridge Court, Suite 102 Hurst, Texas 76053 Telephone: (817) 285-8017 Facsimile: (817)285-0224 Email: david@dlplegal.com ATTORNEY FOR AMANDA DIGBY