EXHIBIT 1

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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

BROWARD DIVISION

In re:

SEVEN STARS ON THE HUDSON

CORPORATION, d/b/a ROCKIN’ JUMP Case No19-17544 - SMG

Chapter 11

Debtor,

____________________________________/

SEVEN STARS ON THE HUDSON Adversary Proceeding

CORPORATION, d/b/a ROCKIN’ JUMP, No. 19-01230

 Plaintiff

v.

Proposed Temporary 

MDG POWERLINE HOLDINGS, LLC Restraining Order

AND XBK MANAGEMENT LLC,

d/b/a XTREME ACTION PARK,

Defendants.

___________________________________

TEMPORARY RESTRAINING ORDER

Upon the Motion for a Temporary Restraining Order filed by the Debtor, 

Seven Stars on the Hudson Corporation, d/b/a Rockin’ Jump, and upon this Court’s 

review and consideration of: (1) the Emergency Motion For Temporary 

Restraining Order And Preliminary Injunction, (2) the Declaration of Kathleen A. 

Daly, dated December 17, 2019, (3) the Declaration of Jens Berding, dated 

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December 16, 2019, and (4) the exhibits annexed to the Motion and Declarations 

(collectively, the “Motion”); and this Court having jurisdiction to consider the 

Motion and the relief requested therein pursuant to 28 U.S.C. §§ 157 and 1334 and 

11 U.S.C. 105(a); and consideration of the Motion and the relief requested therein 

being a core proceeding pursuant to 28 U.S.C. § 157(b)(2)(A), (B) and (M); and 

venue being proper before this Court pursuant to 28 U.S.C. § 1409; and appropriate, 

sufficient and timely notice of the filing of the Motion and request for a temporary 

restraining order having been given pursuant to Bankruptcy Rule 7065; and it 

appearing that the relief requested in the Motion is necessary and beneficial to the 

Debtor and to the public; and upon due deliberation and sufficient cause appearing 

therefor:

IT IS HEREBY FOUND AND DETERMINED THAT: 

1) The Debtor has demonstrated that the relief requested in the Motion is 

urgently needed. Unless a temporary restraining order is issued, there is a material 

risk that the Debtor’s business will be harmed by sudden closures of the Park where 

its business is housed, in order for Xtreme to host private or semi-private events

solely for its guests.

2) Such acts could: (i) interfere with the jurisdictional mandate of this 

Court under Chapter 11 of the Bankruptcy Code; and (ii) interfere with and cause 

harm to the Debtor’s reorganization effort, including the payment of its creditors. 

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Accordingly, there is a material risk that the Debtor, its creditors and other parties in 

interest may suffer immediate and irreparable injury for which they will have no 

adequate remedy at law, and it is therefore necessary that the Court enter this order.

3) The interest of the public will be served by this Court’s entry of this 

order.

4) The relief requested in the Motion is in the best interest of the Debtor, 

its creditors and other parties in interest.

5) The balancing of the interests weighs decidedly in favor of granting the 

within order.

BASED ON THE FOREGOING FINDINGS OF FACT AND AFTER DUE 

DELIBERATION AND SUFFICIENT CAUSE APPEARING THEREFORE, 

IT IS HEREBY ORDERED THAT:

6) The Motion is granted as set forth herein.

7) To the extent unresolved objections to the preliminary injunction 

requested in the Motion exist, all parties in interest must appear before the Honorable 

Scott M. Grossman, United States Bankruptcy Judge for the Southern District of 

Florida for a hearing (the “Hearing”) at _______ on _____________________ at the 

Untied States Bankruptcy Court for the Southern District of Florida, Room ____, 

299 E. Broward Blvd., Ft. Lauderdale, FL, or as soon thereafter as counsel may be 

heard to show why a preliminary injunction should not be granted as follows:

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a. Prohibiting defendant XBK Management LLC d/b/a Xtreme Action 

Park (“Xtreme”) from shutting down its facility without notifying 

the Debtor at least 14 days in advance of such closure;

b. Directing Xtreme (and its affiliated entities) in all advertising and 

public announcements, including any notices posted online, on 

social media, and other forms of signage in and around the physical 

location of Xtreme Action Park to advise that any private event shall 

not effect the Debtor and that the Debtor’s park will remain open to 

the public during such event; and

c. Permitting the Debtor to review and approve Xtreme’s advertising 

of any proposed closing at least ten (10) days in advance to ensure 

that the wording sufficiently alerts the public that the Debtor’s park 

remains open during any semi-private or private event.

d. Permitting the Debtor to review the contract between Xtreme and its 

client to confirm whether the client is contracting for a private event 

that does not permit any other guests to enter the facility, or whether 

the client is contracting for a semi-private event where guests of 

Debtor are allowed to freely enter Xtreme action park. Regardless 

of whether the event is a private or semi-private event, , the common 

areas shall be freely accessible to the Debtor’s guests. 

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e. Directing that any such private or semi-private event arranged by 

Xtreme or any other person or entity acting on its behalf, shall not 

cause any disruption in food services for Debtor’s guests while in 

the facility, unless an alternate arrangement is agreed to by Debtor 

in writing. 

8) Pursuant to Rule 65(b) of the Federal Rules of Civil Procedure, made 

applicable to this Chapter 11 Case by Bankruptcy Rule 7065, no notice to 

any person is required prior to the entry and issuance of this order.

9) Pursuant to Bankruptcy Rule 7065, the security provisions of Rule 65© of 

the Federal Rules of Civil Procedure are waived.

10) This order is without prejudice to the right of the Debtor to seek 

additional relief under applicable provisions of the Bankruptcy Code.

11) This order and the Motion shall be promptly served on the defendants 

and all other parties who have filed notices of appearance pursuant to 

Bankruptcy Rule 2002.

12) Service in accordance with this order shall be deemed good and 

sufficient service and adequate notice for all purposes.

13) Any party in interest wishing to submit a response or objection to the 

relief requested in the Motion must do so in writing and such response shall 

conform to the Bankruptcy Rules and Local Bankruptcy Rules for the 

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Southern District of Florida and shall be served so as to be actually 

received by not later than ___________________ by the following parties:

a. Counsel for the Debtor in the Adversary Proceeding;

b. Counsel for the Debtor in the Main Case;

c. The United States Trustee; and

d. All other parties who have filed notices of appearance.

14) This Court may enter an order granting the preliminary injunction 

requested in the Motion without hearing if no unresolved objections exist.

15) The terms of this order shall be immediately effective and enforceable 

upon its entry.

16) The Debtor is hereby authorized and empowered to take any action or 

perform any act necessary to implement and effectuate the terms of the 

order.

17) This Court shall retain exclusive jurisdiction with respect to the 

enforcement, amendment or modification of this order, and any requests 

for additional relief, and any request by an entity for relief from the 

provisions of this order.

Dated: December _, 2019

_____________________________ 

United States Bankruptcy Judge

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