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DM_US 166174184-1.102966.0048

IN THE UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

FT. LAUDERDALE DIVISION

)

In re: ) Chapter 11

)

SEVEN STARS ON THE HUDSON CORP., ) Case No. 19-17544 

)

Debtor. )

)

AGREED MOTION TO CONTINUE HEARING ON ROCKIN’ JUMP, LLC’S MOTION 

FOR AN ORDER GRANTING RELIEF FROM THE AUTOMATIC STAY PURSUANT 

TO 11 U.S.C. § 362(d)(1) AND MOTION TO AMEND RELIEF GRANTED IN THE 

ORDER GRANTING APPLICATION FOR ADMINISTRATIVE EXPENSES

Rockin’ Jump, LLC (“Franchisor”), by and through undersigned counsel, hereby files this 

Agreed Motion to Continue Hearing on Rockin’ Jump, LLC’s Motion for an Order Granting Relief 

from the Automatic Stay Pursuant to 11 U.S.C. § 362(d)(1) [ECF No. 39] (“Stay Relief Motion”)

and Motion to Amend the Amount of Relief Granted in the Order Granting the Application for 

Administrative Expenses [ECF No. 61] (“Motion to Amend” and together with the Stay Relief 

Motion, the “Motions”) pursuant to Local Rules 5071-1, 7090-1, and 9013-1(c)(8), seeking entry 

of an order substantially in the form of the proposed order attached hereto as Exhibit A, continuing 

the hearing on the Motions. 

1. On August 5, 2019, Franchisor filed its Stay Relief Motion. 

2. On August 30, 2019, Franchisor filed its Motion to Amend. 

3. The Stay Relief Motion is currently set for an evidentiary hearing on March 3, 2020 

at 1:30 pm. 

4. Franchisor and Debtor have been engaged in meaningful, good-faith settlement 

negotiations to resolve the Stay Relief Motion, the treatment of Franchisor’s administrative and 

pre-petition claims and the treatment of the franchise related contracts. 

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DM_US 166174184-1.102966.0048

5. Franchisor and Debtor have reached an agreement with respect to the Motions, and 

have executed a term sheet, but require additional time to finalize the documentation and file a 

motion for approval of the settlement pursuant to Fed. R. Bankr. P. 9019.

6. Franchisor and Debtor anticipate that a motion for approval of their settlement will 

be filed by March 6, 2020.

7. Franchisor and Debtor request that in the interest of preserving judicial resources, 

as well as the estate’s and the parties’ resources, the hearing on the Motions to be rescheduled to 

April 21, 2020 at 1:30 pm.

8. A proposed order granting this Motion is attached hereto as Exhibit A. The 

proposed order is also being uploaded to the Court pursuant to Local Rule 5005-1. 

WHEREFORE, Franchisor respectfully requests that the Court grant this Motion and 

enter an order, substantially in the form of the proposed order attached hereto as Exhibit A, 

continuing the hearing on the Motions until April 21, 2020 at 1:30 pm, and granting any other and 

further relief as the Court deems just and proper. 

Dated: March 2, 2020 Respectfully submitted,

/s/ Joseph M. Wasserkrug 

MCDERMOTT WILL & EMERY LLP

Joseph M. Wasserkrug

333 SE 2nd Avenue, Suite 4500

Miami, FL 33131-2184

Telephone: (305) 347-6501

Facsimile: (305) 938-2184

jwasserkrug@mwe.com

Florida Bar No. 112274

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DM_US 166174184-1.102966.0048

Brandon Q. White

444 W. Lake Street, Suite 4000

Chicago, IL 60606-0029

Telephone: (312) 372-2000

Facsimile: (312) 277-7504

bqwhite@mwe.com

Illinois Bar No. 6310472

Pro hac vice 

Nathan F. Coco

Two Allen Center

1200 Smith Street, Suite 1600

Houston, TX 77002-4403

Telephone: (713) 653-1700

Facsimile: (713) 583-60143

ncoco@mwe.com

Texas Bar No. 24091122

Pro hac vice

Attorneys for Rockin’ Jump, LLC

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on March 2, 2020, a true and correct copy of the foregoing was 

served by transmission of Notices of Electronic Filing generated by CM/ECF to those parties 

registered to receive electronic notice of filing in this case. 

/s/ Joseph M. Wasserkrug

Joseph M. Wasserkrug

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