126617820.1 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov 

In Re: 

 Case No. 20-14696-LMI 

CINEMEX USA REAL ESTATE HOLDINGS, 

INC., CINEMEX HOLDINGS USA, INC., Chapter 11 

and CB THEATER EXPERIENCE LLC, 

 (Jointly Administered) 

Debtors. 

____________________________________/ 

MN THEATERS 2006 LLC’S RESPONSE TO GUC CLAIMS TRUST’S 

FOURTH OMNIBUS OBJECTION TO CLAIMS AND RESERVATION OF RIGHTS 

 MN Theaters 2006 LLC (“MN Theaters”), by and through its undersigned counsel, files 

this response to the GUC Claims Trust’s Fourth Omnibus Objection to Claims [ECF 182] (the 

“Claims Objection”).1 

1. MN Theaters filed its proof of claim (together with all attachments thereto, the 

“Claim”)2 against Debtor CB Theater Experience LLC (together with the other debtors in the 

above-captioned chapter 11 cases, the “Debtors”) on July 2, 2020. On June 28, 2021, the GUC 

Claims Trust filed the Claims Objection, seeking the disallowance of the Claim, among others, 

due to the assumption of the underlying leases (the “Leases”) described in the Claim and the 

payment by the Purchaser (as defined by the Plan) of the related cure amounts. MN Theaters 

acknowledges that the Leases have been assumed and cured and does not object to the 

disallowance of the Claim. 

2. MN Theaters remains engaged in litigation in the United States District Court for 

the Southern District of New York (Case No. 1:20-cv-05860-PKC) (the “District Court Case”) 

 

1

 Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to such terms in the 

Claims Objection. 

2

 Exhibit A to the Claims Objection incorrectly references the Claim of MN Theaters as Claim No. 28-1. The Claim 

is actually Claim No. 35-1. 

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with an affiliate of the Debtors, Grupo Cinemex S.A. de C.V. (“Grupo Cinemex”). Accordingly, 

MN Theaters submits this response out of an abundance of caution for the sole purpose of 

reserving any and all of its rights and remedies against Grupo Cinemex, the Purchaser, the 

Reorganized Debtors (as defined in the Plan), and any and all of their respective successors and 

assigns, including, without limitation, any and all rights and remedies relating to or arising out of 

the District Court Case and the Leases. 

Dated: July 27, 2021 Respectfully submitted, 

By: /s/ David L. Gay 

David L. Gay 

Florida Bar No. 839221 

Carlton Fields, P.A. 

2 MiamiCentral 

700 NW 1st Avenue, Suite 1200 

Miami, Florida 33136-4118 

Telephone: 305-530-0050 

Facsimile: 305-530-0055 

E-mail: dgay@carltonfields.com 

 

Counsel to MN Theaters 2006 LLC 

 

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CERTIFICATE OF SERVICE 

 I certify that, on July 27, 2021, a true and correct copy of the foregoing MN Theaters 

2006 LLC’s Response to GUC Claims Trust’s Fourth Omnibus Objection to Claims and 

Reservation of Rights was served via ECF on all parties who receive service in these jointly 

administered Bankruptcy case via electronic case filings. 

 /s/ David L. Gay 

 David L. Gay 

 

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