MIAMI 6601496.1 84482/88966 

UNITED STATED BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FT. LAUDERDALE DIVISION 

www.flsb.uscourts.gov

In re: 

SEVEN STARS ON THE HUDSON CORP. 

 

Debtor, 

_______________________________________/

Case No.: 19-17544-RBR 

Chapter 11 

AGREED MOTION TO CONTINUE HEARING ON DEBTOR'S MOTION TO 

ASSUME UNEXPIRED LEASE OF NONRESIDENTIAL PROPERTY 

 

MDG Powerline Holdings LLC ("Landlord"), by and through undersigned counsel, files 

this Agreed Motion to Continue Debtor's Motion to Assume Unexpired Lease of Nonresidential 

Property Pursuant to Bankruptcy Code §§365(a)(d)(4) (the "Motion") pursuant to Local Rule 

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 Motion to Assume (as 

defined below) to December 10, 2019. 

1. Debtor filed its Motion to Assume Unexpired Lease of Nonresidential Property 

Pursuant to Bankruptcy Code §§365(a)(d)(4) [ECF No. 80] (the "Motion to Assume"), whereby 

it is seeking to assume its lease with Landlord. The Motion to Assume is set for hearing on 

November 13, 2019.

2. In addition, the Court currently has scheduled 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] 

(the "Stay Relief Motion"). The Stay Relief Motion is set for hearing on December 3, 2019. 

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3. Based on discussions between Debtor and Landlord, both parties agreed that the 

Stay Relief Motion should be heard prior to the hearing on the Motion to Assume. 

4. Accordingly, Debtor and Landlord request that the hearing on the Motion to 

Assume be rescheduled to December 10, 2019, which is a date on which another hearing in this 

case is already scheduled. 

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

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

6. WHEREFORE, Landlord 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: 

(a) continuing the hearing on the Motion to Assume until December 10, 2019; and (b) granting 

such further and other relief the Court deems just and proper. 

Dated: November 8, 2019 

 Respectfully submitted, 

 BILZIN SUMBERG BAENA 

PRICE & AXELROD LLP 

 Counsel for MDG Powerline Holdings LLC 

 1450 Brickell Avenue, 23rd Floor 

 Miami, Florida 33131 

 (305) 374-7580 

 

 By: /s/ Jay M. Sakalo 

 Jay M. Sakalo 

 Fla. Bar No. 156310 

 

 

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CERTIFICATE OF SERVICE 

I HEREBY CERTIFY that a true and correct copy of the foregoing was served via 

CM/ECF Notice of Electronic Filing to all Parties appearing in this case who are registered to 

receive electronic noticing in this case via CM/ECF on this 8th day of November, 2019. 

 By: /s/ Jay M. Sakalo 

 Jay M. Sakalo 

 

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EXHIBIT A 

UNITED STATED BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

FT. LAUDERDALE DIVISION 

www.flsb.uscourts.gov

In re: 

SEVEN STARS ON THE HUDSON CORP. 

 

Debtor, 

_______________________________________/

Case No.: 19-17544-RBR 

Chapter 11 

AGREED ORDER GRANTING AGREED MOTION 

TO CONTINUE HEARING ON DEBTOR'S MOTION TO 

ASSUME UNEXPIRED LEASE OF NONRESIDENTIAL PROPERTY 

On November 8, 2019, MDG Powerline Holdings LLC filed its Agreed Motion to 

Continue Debtor's Motion to Assume Unexpired Lease of Nonresidential Property Pursuant to 

Bankruptcy Code §§365(a)(d)(4) (the "Motion") pursuant to Local Rule 5071-1, 7090-1, and 

9013-1(c)(8) [ECF No. __]. The Court, having reviewed the Motion and the file, noting the 

agreement of the parties, and finding good cause to grant the relief requested in the Motion, it is 

– 

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ORDERED as follows: 

1. The Motion is granted.

2. The hearing on the Motion to Assume (as defined in the Motion) shall be 

continued to December 10, 2019 at 9:30 am, at the United States Bankruptcy Court, 299 E. 

Broward Blvd., Courtroom 308, Ft. Lauderdale, FL 33301.

### 

Submitted By:

Jay M. Sakalo 

Florida Bar No. 0156310 

BILZIN SUMBERG BAENA PRICE & AXELROD LLP 

1450 Brickell Avenue, Suite 2300 

Miami, Florida 33134 

Telephone: (305) 374-7580 

Facsimile: (305) 351-2253 

E-mail: jsakalo@bilzin.com 

Copies furnished to: 

Jay M. Sakalo, Esq. 

[Attorney Sakalo is hereby directed to serve a copy of this Order upon all parties in interest and 

to file a certificate of service of same.] 

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