UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

IN RE: CASE NO.: 19-17544-SMG

SEVEN STARS ON THE HUDSON, CORP., CHAPTER 11

Debtor

_________________________________/

DEBTOR’S MOTION TO ASSUME UNEXPIRED LEASE OF 

NONRESIDENTIAL PROPERTY PURSUANT TO BANKRUPTCY CODE §§

365(a)(d)(4)

Debtor-in-possession, Rockin’ Jump, LLC (“Debtor”), by and through its undersigned 

counsel, files Debtor’s Motion to Assume Unexpired Lease of Nonresidential Property Pursuant

to Bankruptcy Code §§ 365(a)(d)(4) (the “Motion”), and in support states the following facts: 

1. On June 5, 2019 (the “petition date”), the Debtor filed a Voluntary Petition under 

Chapter 11 of the United States Bankruptcy Code. Pursuant to Bankruptcy Code §§ 

1107 and 1108, Debtor continued in possession and operation of business and property, 

as a debtor-in-possession.

2. The Debtor operates a trampoline park at 5300 N. Powerline Road, Ft. Lauderdale, FL

(the “Premises”), under the name Rockin’ Jump, LLC. 

3. The Debtor is operating from the Premises pursuant to a lease (“Lease”), dated on or 

about November 23, 2015. The Lease is between MDH Powerline Holding, LLC 

(“Landlord”) and Debtor. A copy of the Lease agreement is attached as an exhibit to 

the adversary proceeding.

4. Prior to the commencement of this case, the Debtor was having various disputes with 

the Landlord. While in possession of the Premises, the Debtor began to continuously

suffer at the hands of the Landlord and its agent, XBK Management, LLC d/b/a 

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Extreme Action Park (“Xtreme”) beginning in late Fall 2017 because the Landlord

and/or its agent Xtreme (with the knowledge, acquiescence or ratification of the 

Landlord) breached the Lease as follows: removed Debtor’s internal signage; refused 

to fairly represent Debtor’s facilities on the facility maps; interfered with Debtor’s 

business; removed Debtor’s satellite desk; blocked customers from seeing the 

Premises; improperly fixed the leaky roof; ignored the flooding issue in the parking lot;

removed the Debtor from the Landlord’s website; deprived Debtor of his entitlement 

to 15% off food at events taking place at the Premises; put in unauthorized cameras 

that interfered with Debtor’s right to privacy; and interfered with the Lease’s covenant 

of quiet enjoyment. The Debtor advised the Landlord of these problems. The issues 

were not resolved to the satisfaction of the Debtor. Notwithstanding all of the 

foregoing, however, the Debtor has diligently continued to pay all rents due to 

Landlord, resolving to the seek relief as to the Landlord’s misconduct through this 

Court.

5. To that end, the Debtor sought to protect its interest in the Lease, as well as the vitality 

of the trampoline park, by commencing an adversary proceeding (“Adversary 

Proceeding”) on or about July 19, 2019, in the United States Bankruptcy Court for the 

Southern District of Florida Broward Division, in an action captioned Seven Stars on 

the Hudson Corporation, d/b/a Rockin’ Jump v. MDG Powerline Holding, LLC and 

XBK Management LLC, d/b/a Xtreme Action Park, case no. 19-01230-RBR 

(“Complaint”). Within the Complaint, the Debtor sought, inter alia, a declaratory 

judgment, breach of the Lease, including breach of the implied duty of good faith and 

fair dealing, breach of the covenant of quiet enjoyment, violation of the unfair and 

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deceptive trade practice act under Fla. Stat. § 501.204, assumption of the Lease, tortious 

interference with business relationships by Xtreme, and civil conspiracy. 

6. The Adversary Proceeding is still pending in this bankruptcy case. 

7. There has been no finding by any court of competent jurisdiction the Lease interest has 

been terminated. 

8. Accordingly, pursuant to Bankruptcy Code §§ 365(a)(d), the Debtor hereby moves this 

Court for an Order approving the Debtor’s assumption of the Lease, subject to the 

outcome of the Adversary Proceeding. By moving for such assumption, the Debtor is 

not waiving any claim it has asserted in the Adversary Proceeding, nor admitting any 

defenses interposed by the Defendants thereto. The Debtor will continue to pay rent 

and otherwise perform under the Lease unless and until this Court may otherwise direct. 

WHEREFORE, for the foregoing reasons, it is respectfully prayed that this Court enter 

an Order approving the Debtor’s assumption of the Lease, and for such and further relief as this 

Court may deem just and proper under the circumstances. 

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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on October 3, 2019, I electronically filed the foregoing 

document with the Clerk of the Court using CM/ECF, and that the foregoing document is being 

served this day on all counsel of record or pro se parties identified on the attached service list 

either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other 

authorized manner for those counsel or parties to are not authorized to receive electronically 

Notices of Electronic Filing. 

/s/_Sonya S. Slott, Esq._

Sonya S. Slott, Esq. 

FLBN 603910

The Salkin Law Firm

PO Box 15580 

Plantation, FL 33318

954-423-4469

sonya@msbankrupt.com

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