EXHIBIT 12

Case 19-17544-RBR Doc 37-12 Filed 07/19/19 Page 1 of 6
THINKEEN LEGAL, P.A.

1951 NW 7TH AVE #600, 

MIAMI, FL 33136

WWW.THINKEENLEGAL.COM

Christian Pérez Font

T +1 954 873 0923

CPerezFont@thinkeenlegal.com

June 4th, 2019

Kristina E. Wilson, Esq.

Simply Legal

1395 Brickell Avenue, Suite 900

Miami, FL 33131

Re: NOTICE TO CEASE AND DESIST

Continued violations of the Lease Agreement between MDG Powerline Holdings, LLC and 

Seven Stars on the Hudson Corp dated November 23, 2015 (the “Lease”).

Dear Ms. Wilson:

This firm along with the Law Office of Kathleen A. Daly, P.A., represents Seven Stars on the Hudson 

Corp, d/b/a Rockin’ Jump Fort Lauderdale (“RJ”). We are writing to you in your capacity as the legal 

representative of both MDG Powerline Holdings, LLC (“Landlord”) and XBK Management, LLC, 

d/b/a Xtreme Action Park (“Xtreme”). This letter is being served as notice of your clients’ continuing 

and wrongful interference with RJ’s business operations (as more fully described below) which has 

significantly impaired its quiet enjoyment of the leased premises. We hereby demand that your 

clients cease and desist from all such wrongful activities immediately. 

1.- Signage

Section 15 of the Basic Provisions of the Lease, as amended, reads as follows: 

“SIGNAGE: Tenant will be permitted to install the maximum amount of signage 

allowable by local code on both the east and west façade of the building as well 

as signage in the interior of the Premises near the front of the building, 

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subject to Landlord approval, which shall not be unreasonably withheld. 

Tenant shall also have rights to the pro-rata portion of or dedicated panel on 

any existing or future pylon or monument, signage for the Project.”

(emphasis added). 

In prior correspondence it has been pointed out that, Landlord, in clear violation of the terms of the 

Lease, has either directed or allowed the removal of our client’s existing and previously approved 

internal signage (specially the one near the sole access point in the park which was removed in April 

2018 and which had been in place since 2016), thus negatively impacting our client’s ability to 

conduct business and its right to quietly enjoy the leased premises for their intended purpose. This 

violation continues unabated as of this date and our client has been unable to put adequate signage 

within the premises despite many notices and attempts to come to a reasonable understanding with 

Landlord and/or Xtreme.

Landlord working in conjunction with Xtreme continues to refuse to and/or fairly represent/display

our client’s facilities (including its name) in the facility maps that are held available for guests visiting

the park, and also refuse to provide adequate screen time to our client in the TV monitors located 

within the facilities, again, in clear violation of the terms of the Lease. 

Our client has also indicated that Landlord in conjunction with Xtreme has removed all references to 

our client from the marquee located in Powerline Road all of which, aside from also being a clear 

violation of the terms of the Lease, has contributed to the deterioration of our client’s business as 

many passing clients can no longer see that our client’s facilities are located within the premises. In 

this respect, please note while our client is not featured in said marquee, Landlord and its agent 

Xtreme have allowed other business entities which are not within the leased premises to be 

represented/advertised therein which not only shows bias against our client but also a willful disregard 

for the terms of the Lease.

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2.- Front Desk Space

Under the terms of the Lease, Landlord was required to allow our client to have a registration area 

and perform registration activities therein in the event that such area was ever expanded. In prior 

correspondence (June 1st, 2018) you have indicated that our client would be granted a space in the 

registration area. However, our client informs that, as of this date, an appropriate space has not yet 

been provided and our client only has a small fraction of space at the corner of Xtreme’s front desk 

without adequate partition or signage. Our client has not been allowed to place its own signage and 

is neither represented on the TVs in the back wall of the front desk. 

Our client has repeatedly sought to work with Xtreme to find a mutually acceptable solution to the 

front desk situation but to no avail. In fact, in an effort to accommodate Xtreme’s customers and to 

avoid congestion, RJ agreed to use a side entrance (used as an emergency exit-evacuation route) if 

Xtreme was hosting large visiting groups. However, this accommodation on the part of RJ was used 

against it when the Landlord repainted the side entrance hallway which had the RJ green color and 

replaced it with graphics unrelated to RJ’s brand-- all of which, coupled with all the issues in the 

building’s front entrance and lack of proper signage, makes it virtually impossible for customers to 

find the entrance to our client’s facilities and which in turn has detrimentally impacted RJ’s business 

operations. 

3.- Marketing Campaigns

Under the terms of Section 14.05(c)(i) of the Lease our client is responsible for contributing to joint 

marketing campaigns and is therefore entitled to be properly represented in the park’s marketing 

campaigns. However, in retaliation for our client’s past claims, Landlord and/or Xtreme have

eliminated all references and traces of our client from the park’s website (our client had been 

represented in the website since November 2016) again in violation of the Lease, all of which has

negatively impacted our client’s business. 

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4.- Other breaches and intentional misconduct

As you were previously notified, our client continues to be negatively impacted by Xtreme’s 

significant delays in the delivery of food to our client’s customers many of which have been delayed 

for more than 30 minutes after ordering. This pattern of delays coupled with contractual restrictions 

on our client’s ability to allow food into the leased premises continues to negatively affect RJ’s good 

reputation and ability to conduct business. 

Moreover, in the past RJ has notified the Landlord that it was making modifications to common areas 

without affording RJ reasonable accommodations. For example, the placement of a ropes course and 

barricades in front of RJ’s facilities unnecessarily hindered visibility and access to RJ’s facilities for 

a period of 4-6 weeks which in turn adversely impacted its ability to draw customers. Also, as 

communicated in prior correspondence, the Landlord and/or in conjunction with Xtreme, have in the 

past prevented RJ’s guests (as well as other guests visiting the park) from entering RJ’s facilities 

during several lockout events, all of which also resulted in decreased revenues and negative financial 

consequences for our client. 

Finally, and as you were previously advised, Landlord has, without RJ’s consent, installed security 

cameras within the leased premises which have unfettered view of all of the leased premises. While 

RJ does not object to security cameras being conspicuously placed in the property’s common areas 

and exits, it strongly objects to the current placement of the cameras which encroaches upon the rights 

of RJ’s customers and their reasonable expectation of privacy as well as RJ’s privacy interests.

Formal notice is given to Landlord and to Xtreme to immediately and finally cease and desist from 

the above-described malicious conduct. Landlord is hereby also directed to remediate all contractual 

breaches described above within thirty (30) days as required under Section 17.03 of the Lease. Should 

the conduct not stop or the breaches not be remedied our client shall have no option but to take 

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appropriate legal action to protect against the further and continued impairment of its business 

interests and to enforce its property rights.

Very truly yours,

Thinkeen Legal, P.A.

By: ___________________________

Christian Perez Font, Esq.

.cc Seven Stars on the Hudson Corp.

d/b/a Rockin’ Jump Fort Lauderdale

2108 NE 63rd Street

Fort Lauderdale, FL 33308

Att: Jens Berding

.cc Kathleen Daly, Esq.

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