MIAMI 6721840.3 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-SMG 

Chapter 11 

AGREED MOTION TO CONTINUE 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) until April 29, 2020 at 1:30 p.m., without prejudice to seeking to advance the 

hearing on the Motion. 

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 was originally set for 

hearing on November 13, 2019, was continued until February 4, 2020 and continued again to 

March 4, 2020 by agreement between Landlord and Debtor [ECF Nos. 90, 107 and 128].

2. Subsequently, Debtor and Rockin' Jump LLC filed an agreed motion to 

reschedule 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") requesting that it be 

set for hearing on April 21, 2020 [ECF No. 139]. 

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

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

4. Accordingly, as a result of the request to continue the Stay Relief Motion to April 

21, 2020, Debtor and Landlord request that the hearing on the Motion to Assume be rescheduled 

to April 29, 2020 at 1:30 p.m., without prejudice to seeking to advance the hearing date if the 

Stay Relief Motion is resolved prior to April 21, 2020. 

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 April 29, 2020, without prejudice to 

seeking to advance the hearing date if the Stay Relief Motion is resolved prior to April 21, 2020; 

and (b) granting such further and other relief the Court deems just and proper. 

Dated: March 3, 2020 

 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 3rd day of March 2020. 

 By: /s/ Jay M. Sakalo 

 Jay M. Sakalo 

 

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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-SMG 

Chapter 11 

[PROPOSED] AGREED ORDER GRANTING AGREED 

MOTION TO CONTINUE DEBTOR'S MOTION TO 

ASSUME UNEXPIRED LEASE OF NONRESIDENTIAL PROPERTY 

On March 3, 2020, 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 – 

ORDERED as follows: 

1. The Motion is granted.

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

continued to April 29, 2020 at 1:30 p.m. at the United States Bankruptcy Court, 299 E. Broward 

Blvd., Courtroom 308, Ft. Lauderdale, FL 33301, without prejudice to seeking to advance the 

hearing date if the Stay Relief Motion is resolved prior to April 21, 2020.

### 

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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