Full title: Amended Notice of Agenda for Hearings Scheduled March 26, 2021 filed by Debtor Studio Movie Grill Holdings, LLC (RE: related document(s)831 Notice of Agenda for Hearings Scheduled for March 26, 2021 filed by Debtor Studio Movie Grill Holdings, LLC (RE: related document(s)700 Amended chapter 11 plan filed by Debtor Studio Movie Grill Holdings, LLC (RE: related document(s)619 Chapter 11 plan).).). (Wright, Frank)
Document posted on Mar 24, 2021 in the bankruptcy, 8 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 4, 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 ManagementTexas Comptroller of Public Accounts’ Objection to Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: Texas Comptroller of Public Accounts
Denton County, Texas’ Objection to Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors
Party: Denton County, Texas
Tax Authorities’ Objection to Confirmation of Second Amended Joint Plan o
Page 1
Frank J. Wright
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
ATTORNEYS FOR STUDIO MOVIE
GRILL HOLDINGS, LLC, et al.
IN THE UNITED STATES BANKRUPTCY COURT
NORTHERN DISTRICT OF TEXAS
DALLAS DIVISION
IN RE: §
§
STUDIO MOVIE GRILL HOLDINGS, LLC, § CASE NO. 20-32633-SGJ et al.,1 §
§ Chapter 11
§
DEBTORS. § Jointly Administered
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 4, 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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NOTICE OF AGENDA FOR HEARINGS SCHEDULED FOR
MARCH 26, 2021, AT 9:30 A.M. BEFORE THE HONORABLE STACEY G.C.
JERNIGAN AT THE UNITED STATES BANKRUTPCY COURT, LOCATED AT
1100 COMMERCE STREET, ROOM 1254, DALLAS, TEXAS
This Agenda sets forth items in the order Debtors intent to present to the Court. The status of each is set forth below.
1. Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors [Dkt. No. 619], as amended and supplemented.
Moving Party: Debtors
Nature of the Matter: Confirmation of the Debtors’ Plan of Reorganization Docket Number: Dkt. No. 619 (as amended by Dkt. No. 700, and as supplemented by Dkt. Nos. 702 and 705
Status of the Matter: Going Forward.
Additional Pleadings in Support of the Motion:
Amended Joint Disclosure Statement for Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors [Dkt. No. 616] Order Granting Motion for Entry of an Order (A) Approving Disclosure Statement in Support of the Joint Plan of Reorganization, (B) Scheduling a Hearing to Consider Confirmation of the Joint Plan of Reorganization, (C) Establishing Voting and Objection Deadlines, and (D) Approving Balloting, Solicitation, Notice, and Voting Procedures [Dkt. No. 630] Notice of Hearing and Deadline to Object to the Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors [Dkt. No. 633] Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors [Dkt. No. 700]
Notice of Filing of Supplement to the Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors [Dkt. No. 702] Notice of Filing of Second Supplement to the Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors [Dkt. No. 705] Objections and Responses:
Maricopa County Treasurer’s Objection to Debtors’ Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: Maricopa County Treasurer
Docket Number: 685
Status: Under Negotiation.
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Objection of Certain PACA Creditors to Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors
Party: Family Tree Produce, Inc., Hardie’s Fruit & Vegetable Company, LP, Piazza Produce, LLC, and Royal Food Service,
Inc.
Docket Number: 710
Status: Resolved and Withdrawn at Dkt. No. 826.
Texas Comptroller of Public Accounts’ Objection to Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: Texas Comptroller of Public Accounts
Docket Number: 713
Status: Resolved by Confirmation Order Language.
Denton County, Texas’ Objection to Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors
Party: Denton County, Texas
Docket Number: 716
Status: Under Negotiation.
Regency Lighting’s Objection to Confirmation of Debtors’ Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: Regency Enterprises, Inc. d/b/a Regency Lighting
Docket Number: 717
Status: Unresolved.
United States Trustee’s Objection to Confirmation of Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: United States Trustee
Docket Number: 718
Status: Unresolved in Part, Under Negotiation in Part.
Debtors and the United States Trustee are unable to resolve the United States Trustee’s objection to the release, exculpation, and opt-out release language in the Debtors’ Joint Plan of Reorganization. Remaining issues remain under negotiation.
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Limited Objection of the State of Texas to the Debtors’ Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: State of Texas
Docket Number: 721
Status: Resolved by Confirmation Order Language.
Objection of AmREIT SSPF Berkeley, LP to Confirmation of the Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: AmREIT SSPF Berkeley, LP
Docket Number: 723
Status: Under Negotiation. Objection may be resolved by lease amendment.
Limited Objection University Mall Soho Owner, LLC, University Mall Portwood, LLC, and University Mall TIC Owner, LLC to Confirmation of the Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: University Mall Soho Owner, LLC, University Mall Portwood, LLC, and University Mall TIC Owner, LLC
Docket Number: 724
Status: Resolved by Subject Lease Being Rejected.
The Certain Texas Taxing Entities’ Objection to the Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: Texas Comptroller of Public Accounts Plano Independent School District, Arlington Independent School District, Spring Branch Independent School District, Richardson Independent
School District, Grapevine-Colleyville Independent School District, City of Houston, Harris County Water Control and
Improvement District #145, and City of Colleyville
Docket Number: 726
Status: Under Negotiation
Limited Objection of Rosedale Bakersfield Retail VI, LLC to Confirmation of Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors
Party: Rosedale Bakersfield Retail VI, LLC
Docket Number: 727
Status: Resolved by Stipulation (uploaded to Court for review).
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Limited Objection of Spirit Realty, L.P. to Debtors’ Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: Spirit Realty, L.P.
Docket Number: 728
Status: Resolved by Agreement on Cure.
Objection of DS Properties 17, LP to Notice of Filing of Second Supplement to the Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors
Party: DS Properties 17, LP
Docket Number: 729
Status: Resolved by Agreement on Cure.
Tax Authorities’ Objection to Confirmation of Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: Dallas County, Harris County, Smith County, Tarrant County, Cypress-Fairbanks ISD and Lewisville ISD
Docket Number: 731
Status: Under Negotiation.
Veritex Community Bank’s Limited Objection to Confirmation of Plan of Reorganization Party: Veritex Community Bank
Docket Number: 732
Status: Resolved by Confirmation Order Language.
Objection to Second Amended Joint Plan of Reorganization
Party: Seminole Mall LP
Docket Number: 733
Status: Resolved by Lease Amendment and Withdrawn at Dkt. No.
836
Objection to Second Amended Joint Plan of Reorganization
Party: HMC Lewisville TC, LLC
Docket Number: 734
Status: Resolved by Confirmation Order Language.
Page 6
Regions Bank’s (A) Limited Objection to Confirmation of the Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors and (B) Reservation of Rights
Party: Regions Bank
Docket Number: 735
Status: Under Negotiation.
Limited Objection of Brixmor Operating Partnership 2, LLC to Debtors’ Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: Brixmor Operating Partnership 2, LLC
Docket Number: 736
Status: Part of Objection Resolved by Lease Amendment. Remaining Objections Under Negotiation.
11170 North Central’s Objection to Confirmation
Party: 11170 North Central, LP
Docket Number: 737
Status: Resolved by Lease Amendment and Withdrawn at Dkt. No.
776.
Tyler Broadway/Centennial LP’s Objection to Confirmation
Party: Tyler Broadway/Centennial LP
Docket Number: 738
Status: Resolved by Lease Amendment and Withdrawn at Dkt. No.
817.
Limited Objection of STORE Master Funding III, LLC to Debtors’ Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: STORE Master Funding III, LLC
Docket Number: 739 and 746
Status: Part of Objection Resolved by Lease Amendment. Remaining Objections Under Negotiation.
Objection to Second Amended Joint Plan of Reorganization
Party: 69th Street Retail Owner LP
Docket Number: 740
Status: Resolved by Lease Amendment.
Page 7
EPT Dallas, LLC’s Objection to Confirmation Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors Party: EPT Dallas, LLC
Docket Number: 741
Status: Unresolved.
Limited Objection and Reservation of Rights of Walt Disney Studios Motion Pictures and Twentieth Century Fox Film Corporation to Second Amended Joint Plan of Reorganization for Studio Movie Grill Holdings, LLC and Jointly Administered Debtors
Party: Walt Disney Studios Motion Pictures and Twentieth Century Fox Film Corporation
Docket Number: 743
Status: Resolved by Confirmation Order Language.
Limited Objection of BRE RC Lincoln Square TX LP to Confirmation of the Debtors’ Chapter 11 Plan and to the Debtors’ Proposed Cure Amounts
Party: BRE RC Lincoln Square TX LP
Docket Number: 768
Status: Resolved by Lease Amendment
Schultz Parties’ Comment and Limited Objection to Plan
Party: Brian Schultz and Blackbox Management, LLC
Docket Number: 837
Status: Unresolved.
2. Debtors’ Emergency Motion for Entry of an Order confirming Applicability of Amendment to 11 U.S.C. § 365(d)(4) or Alternatively, Extending the Debtors’ Time to Assume or Reject Unexpired Leases of Non-Residential Real Property Pursuant to 11 U.S.C. § 365(d)(4) [Docket No. 660] filed by the Debtors.
Moving Party: Debtors
Nature of the Motion: Seeking an Order Confirming Applicability of the Consolidated Appropriations Act, 2021’s Amendment
to Section 365(d)(4) to these Case, or Alternatively, for
Extension of Time to Assume or Reject Unexpired
Leases of Non-Residential Real Property.
Docket Number: 660
Status of the Matter: Going Forward.
Additional Pleadings in Support of the Motion:
Page 8
Order Granting in Part and Continuing in Part Debtors’ Emergency Motion for Entry of an Order confirming Applicability of Amendment to 11 U.S.C. § 365(d)(4) or Alternatively, Extending the Debtors’ Time to Assume or Reject Unexpired Leases of Non-Residential Real Property Pursuant to 11 U.S.C. § 365(d)(4)
Objections and Responses:
None.
NOTICE
The pleadings in these cases and supporting papers are available on the Court’s website at:
ecf.txnb.uscourts.gov. You may obtain copies of all pleadings on the website maintained by Donlin Recano & Company for the Debtors.
DATED: March 25, 2021 Respectfully submitted,
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
Emails: frank@fjwright.lawjeff@fjwright.lawjay@fjwright.law
2323 Ross Avenue, Suite 730
Dallas, Texas 75201
Telephone: (214) 935-9100
ATTORNEYS FOR STUDIO MOVIE
GRILL HOLDINGS, LLC, et al.