09923-00001/13075643.3 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov

In re: Chapter 11 

 

CINEMEX HOLDINGS USA, 

INC.

 Case No. 20-14696-LMI 

 (Formerly Jointly Administered Under

Reorganized Debtor. Lead Case: Cinemex USA Real Estate 

Holdings, Inc., Case No. 20-14695-

LMI) 

___________________________/ 

OBJECTION TO CLAIM NO. 80 OF VCC, LLC 

(Objection to Claim Classification) 

IMPORTANT NOTICE TO CREDITOR: 

THIS IS AN OBJECTION TO YOUR CLAIM 

 This objection seeks either to disallow or reduce the amount or change 

the priority status of the claim filed by you or on your behalf. Please read this 

objection carefully to identify which claim is objected to and what disposition 

of your claim is recommended. 

 If you disagree with the objection or the recommended treatment, you 

must file a written response WITHIN 30 DAYS from the date of service of this 

objection, explaining why your claim should be allowed as presently filed, and 

you must serve a copy to the undersigned attorney OR YOUR CLAIM MAY 

BE DISPOSED OF IN ACCORDANCE WITH THE RECOMMENDATION 

IN THIS OBJECTION. 

 If your entire claim is objected to and this is a chapter 11 case, you will 

not have the right to vote to accept or reject any proposed plan of 

reorganization until the objection is resolved, unless you request an order 

pursuant to Bankruptcy Rule 3018(a) temporarily allowing your claim for 

voting purposes. 

 The written response must contain the case name, case number, and 

must be filed with the Clerk of the United States Bankruptcy Court, 301 N. 

Miami Avenue, Suite 150, Miami, Florida 33128. 

 Cinemex Holdings USA, Inc. (the “Reorganized Debtor” or “Cinemex Holdings,” and, 

together with CB Theater Experience LLC (“CB Theater”) and Cinemex USA Real Estate 

Holdings, Inc. (”Cinemex USA”), the “Reorganized Debtors” or “Debtors,” as applicable), 

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09923-00001/13075643.3 2 

through undersigned counsel and pursuant to section 502(b) of title 11, United States Code (the 

“Bankruptcy Code”), Rule 3007 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy 

Rules”), and Rule 3007-1 of the Local Bankruptcy Rules for the Southern District of Florida (the 

“Local Bankruptcy Rules”), hereby objects to Claim No. 80 filed by VCC, LLC in Case No. 20-

14695 in the amount of $4,956,411.79 and seeks to reclassify it from a secured to a general 

unsecured claim and to disallow it in its entirety, for the reasons set forth in the table below and 

discussed in further detail in the Objection: 

Claim 

No. 

Name of 

Property 

Amount of 

Claim 

Basis of 

Claim 

Basis for Objection Recommended 

Disposition 

80-2 Addison 

Property 

(see Claim 

80-1) 

$4,559,091.63 Contract 

work (see 

Claim 80-1) 

No collateral (rejected 

lease); already resolved 

pursuant to GUC Trust’s 

agreed motion with 

Addison Lessor (defined 

below), whose Claim No. 

39-1 in Case No. 20-

14699 included VCC, 

LLC’s claim. See Claim 

No. 39-1 in Case No. 20-

14699 at Part 2, at 4 

(including VCC, LLC’s 

asserted claim within 

Addison Lessor’s claim); 

ECF Nos. 207 and 211. 

Reclassify from 

secured to general 

unsecured; 

disallow as 

duplicative of 

Claim No. 39-1 in 

Case No. 20-

14699 submitted 

by Addison 

Lessor, which 

was resolved 

pursuant to the 

Agreed Order 

Resolving Claim 

No. 39-1 (ECF 

No. 207). See 

ECF No. 211. 

80-2 Wrigleyville 

Property 

(Addison 

Property) 

$75,281.00 Additional 

contract 

work 

No collateral (rejected 

lease); already resolved 

pursuant to GUC Trust’s 

agreed motion with 

Addison Lessor, whose 

Claim No. 39-1 in Case 

No. 20-14699 included 

VCC, LLC’s claim. See 

Claim No. 39-1 in Case 

No. 20-14699 at Part 2, at 

4 (including VCC, LLC’s 

asserted claim within 

Reclassify from 

secured to general 

unsecured; 

disallow as 

duplicative of 

Claim No. 39-1 in 

Case No. 20-

14699 submitted 

by Addison 

Lessor, which 

was resolved 

pursuant to the 

Agreed Order 

Case 20-14696-LMI Doc 341 Filed 12/13/21 Page 2 of 16
09923-00001/13075643.3 3 

Claim 

No. 

Name of 

Property 

Amount of 

Claim 

Basis of 

Claim 

Basis for Objection Recommended 

Disposition 

Addison Lessor’s claim); 

ECF Nos. 207 and 211. 

Resolving Claim 

No. 39-1 (ECF 

No. 207). See 

ECF No. 211. 

80-2 Halcyon 

Property 

$272,302.16 Matching 

Pro 

invoices 

Lack of substantiation; 

satisfaction (lease 

assumed with cure amount 

paid); satisfaction 

(assumed and cured 

underlying executory 

contract with Matching 

Pro). 

Reclassify from 

secured to general 

unsecured; 

disallow as 

satisfied. 

80-2 Brickell 

Property 

$49,737.00 Contract 

work 

Satisfaction (lease 

assumed with cure amount 

paid). 

Reclassify from 

secured to general 

unsecured; 

disallow as 

satisfied. 

I. RELIEF REQUESTED 

1. The Reorganized Debtor requests entry of an order, substantially in the form 

attached hereto as Exhibit A, pursuant to Bankruptcy Code section 502(b), Rule 3007 of the 

Bankruptcy Rules, and Rule 3007-1 of the Local Bankruptcy Rules, reclassifying from secured to 

general unsecured Claim No. 80 of VCC, LLC (the “Asserted Secured Claim”), without prejudice 

to any other objections to claim that could be brought against the Asserted Secured Claim. 

II. JURISDICTION AND VENUE 

2. The United States Bankruptcy Court for the Southern District of Florida (the 

“Bankruptcy Court”) has jurisdiction over this matter pursuant to 28 U.S.C. Sections 157 and 1334 

as well as the retention of jurisdiction provisions found in (i) the Court’s order confirming the 

Debtors’ plan of reorganization (Case No. 20-14695, ECF No. 936) (the “Confirmation Order”) 

and (ii) the confirmed plan of reorganization (Case No. 20-14695, ECF No. 779) (the “Plan”). 

This matter is a core proceeding within the meaning of 28 U.S.C. Section 157(b)(2). 

Case 20-14696-LMI Doc 341 Filed 12/13/21 Page 3 of 16
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3. Venue is proper pursuant to 28 U.S.C. Sections 1408 and 1409. 

4. The bases for the relief requested in this Objection are sections 105(a) and 502(b) 

of the Bankruptcy Code, Bankruptcy Rule 3007, and Local Bankruptcy Rule 3007-1. 

III. FACTUAL HISTORY 

A. The Bankruptcy 

5. On April 25, 2020, Cinemex USA and Cinemex Holdings filed for bankruptcy 

under chapter 11 of title 11 of the Bankruptcy Code in this Court. On April 26, 2020 (together 

with April 25, 2020, the “Petition Dates”), CB Theater also filed for bankruptcy under chapter 11 

in this Court. 

6. The bankruptcy cases were jointly administered under the lead case Cinemex USA 

Real Estate Holdings, Inc., Case No. 20-14695-LMI. 

7. The deadline to file proofs of claim was set as July 6, 2020. 

8. Cinemex is in the movie theater business and is based in Miami, Florida. At the 

time of the filing of this case, Cinemex operated 41 movie theaters in dozens of cities in 12 states, 

including Florida. The theaters operate under the brand name “CMX Cinemas.” 

1. On November 25, 2020, the Court entered the Confirmation Order. Case No. 20-

14695, ECF No. 936. Pursuant to the Confirmation Order (at Paragraph 132), the Reorganized 

Debtors1

 have the sole authority to bring objections to secured claims. 

2. On April 22, 2021, the Court entered the Final Decrees in the bankruptcy cases of 

CB Theater Experience LLC, Case No. 20-14699 (ECF No. 29) and Cinemex USA Real Estate 

Holdings, Inc., Case No. 20-14695 (ECF No. 1065) (collectively, the “Closed Cases”). 

1

 “Reorganized Debtors” is defined in the Plan as “the Debtors, as reorganized pursuant to and under the Plan or 

any successor thereto, by merger, consolidation, or otherwise, on or after the Effective Date.” 

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3. On April 27, 2021, the Court ordered that all outstanding matters should henceforth 

be docketed in the remaining open bankruptcy case, Cinemex Holdings USA, Inc., Case No. 20-

14696. See Case No. 20-14695, ECF No. 1071. 

4. On June 1, 2021, the Court entered an Order Extending Claims Objection Deadline 

for another one hundred eighty days through and including the later of: (a) December 13, 2021, or 

(b) one hundred eighty days following the date that a proof of Claim is filed or amended. See ECF 

No. 165. 

B. The Asserted Secured Claim 

9. On May 19, 2020, VCC, LLC filed with the Court a Notice of Filing and Perfection 

of Lien Pursuant to 11 U.S.C. §§ 362(b)(3) and 546(b), alleging a mechanic’s lien on 1025 W. 

Addison, Chicago, Illinois (the “Addison Property”). Case No. 20-14695, ECF No. 128. 

10. On July 7, 2020, VCC, LLC filed Proof of Claim No. 80 in Case No. 20-14695, 

alleging a secured claim against Debtors Cinemex USA and CB Theater in the amount of 

$4,559,091.63. The proof of claim stated that the $4,559,091.63 of the Asserted Secured Claim is 

secured by a mechanic’s lien relating to the Addison Property. According to the Proof of Claim, 

VCC, LLC completed the contracted work on the Addison Property on April 22, 2020. Although 

the Proof of Claim contains an attachment with the original contractor’s claim for mechanic’s lien, 

the Proof of Claim form itself did not assert that any part of the claim was secured. 

11. On August 19, 2020, VCC, LLC filed an Amended Proof of Claim No. 80 in Case 

No. 20-14695, alleging a secured claim against Debtors CB Theater and Cinemex Holdings in the 

amount of $4,956,411.79. The basis of perfection of the lien is listed on the Amended Proof of 

Claim as “Mechanic’s Lien.” The documents attached to the Amended Proof of Claim fall into 

three general categories: (1) invoices for $272,302.16 for services rendered by a third party, 

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09923-00001/13075643.3 6 

Matching Pro, at Cinemex Halcyon Village Center (“Halcyon Property”) and billed to VCC, LLC; 

(2) application and certificate of payment for $49,737.00 for contractor work at Cinemex Brickell 

City Center (“Brickell Property”), along with a Conditional Final Waiver of Lien conditioned upon 

receipt of the same amount; (3) application for additional payment of $75,281.00 for contractor 

work at CMX Cinema Wrigleyville (“Wrigleyville Property”), along with a Conditional Final 

Waiver of Lien conditioned up receipt of the same amount. The amounts detailed on the three 

attachments total $397,320.16. The unsubstantiated differential between the amount of the 

Asserted Secured Claim, $4,956,411.79, and the $397,320.16 listed on invoices in the Amended 

Proof of Claim, hence $4,559,091.63, appears to correspond to the amount substantiated in the 

original Proof of Claim, mechanic’s lien relating to the Addison Property. 

12. Also on August 19, 2020, VCC, LLC filed “out of an abundance of caution” a 

Motion for Order Granting Relief from the Automatic Stay to Enforce Mechanic's Lien (Case No. 

20-14695, ECF No. 493), and Declaration of Jessica Haddad in Support of Motion for Order 

Granting Relief from the Automatic Stay to Enforce Mechanic's Lien (Case No. 20-14695, ECF 

No. 494). The motion for relief from stay alleged a mechanics lien relating to the Addison Property 

for “no less than $4,634,372.63,” but it was filed after the underlying lease was rejected. See Case 

No. 20-14695, ECF No. 72. The motion for relief from stay remains pending. 

13. On May 18, 2021, the GUC Claims Trust filed its Third Omnibus Objection to 

Claims (Amended and Superseded Claims) (ECF No. 116), objecting to the original Proof of Claim 

filed by VCC, LLC (Claim 80-1 in Case No. 20-14695). The Amended Proof of Claim (Claim 

80-2 in Case No. 20-14695) was not affected by the objection of the GUC Claims Trust. 

14. On August 1, 2021, the Court entered an order sustaining the GUC Claims Trust’s 

objection. ECF No. 1076. Pursuant to the court order, Claim 80-1 in Case No. 20-14695 was 

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09923-00001/13075643.3 7 

stricken and disallowed in its entirety. The amended claim, Claim 80-2 in Case No. 20-14695 

(see Amended Proof of Claim) was not affected by the Court order. 

C. The Addison Property (The Wrigleyville Property) 

15. As set forth in the Stipulation Regarding Debtors’ Motion to Reject Lease with 

1025 W. Addison Street Apartments Owner, LLC between the Debtors and the owner of the 

Addison Property (Case No. 20-14695, ECF No. 228), 1025 W. Addison Street Apartments 

Owner, LLC (the “Addison Lessor”) is the owner of the Addison Property and was a lessor of the 

Addison Property pursuant to a lease dated July 3, 2014 (the “Addison Lease”). 

16. On April 30, 2020, the Debtors moved to reject the Addison Lease (Case No. 20-

14695, ECF No. 29). In their motion to reject, the Debtors identified the Addison Lease as the 

Wrigleyville Lease. 

17. On May 7, 2020, the Court entered an order granting the Debtors’ motion to reject 

the Addison Lease (Case No. 20-14695, ECF No. 72). 

18. Pursuant to the Confirmation Order (at Paragraph 144), the Debtors are deemed not 

to assume unexpired leases that were previously rejected. 

19. On November 19, 2019, the Debtors filed the Assumed Executory Contract and 

Unexpired Lease List (the “Assumption List”) as Exhibit B to the Plan Supplement for the Plan 

(Case No. 20-14695, ECF No. 885). The Assumption List does not include the Addison Lease. 

20. Furthermore, the Addison Lessor filed its own proof of claim that included the 

asserted lien of contractor VCC, LLC in the amount of $4,559,091.63 (Case No. in 20-14699, 

Claim 39-1, Part 2, at 4). 

21. On July 7, 2021, the GUC Trust and the Addison Lessor filed an agreed motion 

resolving Claim 39-1 in Case No. 20-14699. ECF No. 207. 

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22. The Court granted the agreed motion resolving Addison Lessor’s claim on July 

28, 2021. ECF No. 211. Pursuant to the court order, the entire Claim No. 39-1 filed by the 

Addison Lessor is allowed as a general unsecured claim in the reduced amount of $9,586,504.00, 

and is no longer subject to disallowance, modification and/or reduction. 

23. Consequently, VCC, LLC’s claim as it related to the Addison Property was 

resolved pursuant to the Agreed Order Granting GUC Claims Trust’s Agreed Motion Resolving 

Claim No. 39-1 Filed by 1025 W. Addison Street Apartments Owner, LLC (ECF No. 207). ECF 

No. 211. 

24. Additionally, the Asserted Secured Claim as it relates to the Addison Property does 

not attach to any property of the estate as the estate did not include the land within the Wrigleyville 

Property, and as such is not a secured claim under the Plan or the Bankruptcy Code. 

D. The Halcyon Property 

25. On November 25, 2020, the Court entered the Confirmation Order. Case No. 20-

14695, ECF No. 936. Pursuant to the Plan Supplement for the Plan, the Halcyon Property lease 

was assumed by CB Theater under Binding Term Sheet Pertaining to Existing Ground Lease with 

GT RP Halcyon, LLC with a cure amount of $54,500. Case No. 20-14695, ECF No. 885 at 70. 

26. Pursuant to the Confirmation Order, the Debtors provided sufficient cure payments 

predicate to the assumption of the Halcyon Property (the “Halcyon Lease”) as amended to provide 

for the Debtors to remove the mechanic’s liens on the Halcyon Property. 

27. Notwithstanding assumption or rejection, however, the Asserted Secured Claim as 

it relates to the Halcyon Property does not attach to property of the estate, and as such is not a 

secured claim under the Plan or the Bankruptcy Code. 

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09923-00001/13075643.3 9 

28. Furthermore, VCC, LLC does not substantiate its claim regarding the Halcyon 

Property other than by attaching invoices issued to it by a third-party contractor, Matching Pro. 

VCC, LLC does not clarify its contractual relationship, if any, with the Debtors in relation to the 

Halcyon Property, nor its contractual relationship, if any, with Matching Pro, and how it relates to 

the Debtors. As such, VCC, LLC’s $272,302.16 of the Asserted Secured Claim relating to the 

Halcyon Property is unsubstantiated. 

29. Additionally, CB Theater directly assumed the contract with the third-party 

contractor that issued invoices to VCC, LLC. VCC, LLC added such third-party invoices to its 

Proof of Claim with what appears to be a summary invoice issued by VCC, LLC to Cinemex 

Halcyon Village Center. The assumed contract with the third-party contractor, Matching Pro, for 

“Promotional GiveAways for new openings of PTC, Halcyon and Wheeling” is listed on the Plan 

Supplement with a cure amount of $0. Case No. 20-14695, ECF No. 885 at 71. As such, the 

underlying claim of Matching Pro that formed the basis of invoices issued to VCC, LLC for the 

services rendered at the Halcyon Property have been satisfied. Consequently, VCC, LLC’s 

$272,302.16 of the Asserted Secured Claim relating to the Halcyon Property has been satisfied. 

E. The Brickell Property 

30. On November 25, 2020, the Court entered the Confirmation Order. Case No. 20-

14695, ECF No. 936. Pursuant to the Plan Supplement for the Plan, the Brickell Property lease 

was assumed by CB Theater under Binding Term Sheet Amending Existing Commercial Lease 

with Brickell City Experience LLC with a cure amount of $161,654.00. Case No. 20-14695, ECF 

No. 885 at 19. 

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09923-00001/13075643.3 10 

31. Pursuant to the Confirmation Order, the Debtors provided sufficient cure payments 

predicate to the assumption of the lease for Brickell Property (the “Brickell Lease”) as amended 

to provide for the relevant lessor to remove the mechanic’s liens on the Brickell Property. 

32. Notwithstanding assumption or rejection, however, the Asserted Secured Claim as 

it relates to the Brickell Property does not attach to any property of the estate as the estate did not 

include the land within Brickell Property, and as such is not a secured claim under the Plan or the 

Bankruptcy Code. 

IV. OBJECTION 

33. Section 502(a) of the Bankruptcy Code provides that “[a] claim or interest, proof 

of which is filed under Section 501 of this title, is deemed allowed, unless a party in interest . . . 

objects.” 11 U.S.C. § 502(a). As set forth in Bankruptcy Rule 3001(f), a properly executed and 

filed proof of claim constitutes prima facie evidence of the validity and amount of the claim under 

Section 502(a) of the Bankruptcy Code. However, a claimant’s proof of claim is entitled to the 

presumption of prima facie validity only until the debtor effectively rebuts the presumption of 

validity. In re Santiago, 404 B.R. 564, 570 (Bankr. S.D. Fla. 2009). The burden of proof then 

shifts to the creditor. Id. 

34. By this Objection, the Reorganized Debtors seek to reclassify the Asserted Secured 

Claim from secured to general unsecured. For the Addison Lease, Illinois mechanics’ lien law 

specifies that the mechanic’s lien attaches to real property only: “Any [contractor] has a lien upon 

the whole of such lot or tract of land and upon adjoining or adjacent lots or tracts of land of such 

owner . . . for the amount due to him or her for the material, fixtures, apparatus, machinery, services 

or labor . . . .” Illinois Mechanics Lien Act, 770 ILCS 60/0.01, et seq. The Illinois law applicable 

here does not provide for any lien on the Debtors’ personal property, and the Addison Lease has 

Case 20-14696-LMI Doc 341 Filed 12/13/21 Page 10 of 16
09923-00001/13075643.3 11 

been rejected by a final order. “It is a fundamental principle of bankruptcy law that a creditor 

cannot hold a secured claim in the case unless its collateral is property of the estate.” In re Paul, 

534 B.R. 430, 434 (Bankr. M.D. Ga. 2015). See also In re Walker, No. 4:03-BK-17741E, 2003 

WL 22794522, at *2 (Bankr. E.D. Ark. Oct. 31, 2003), Magna Bank v. Gilsinn, 224 B.R. 710 

(Bankr. E.D. Mo. 1997); In re Gabor, 155 B.R. 391 (Bankr. N.D. W. Va. 1993); In re Elliot, 64 

B.R. 429 (Bankr. W.D. Mo. 1986). 

35. For the Halcyon Lease, even if there were collateral, any secured claim was 

satisfied and released pursuant to the Plan as the Brickell Lease was assumed and cured, with 

sufficient proceeds to pay VCC, LLC’s claim in full. Furthermore, VCC, LLC’s alleged claim 

related to the Halcyon Lease is insufficiently substantiated. However, the alleged underlying 

Halcyon Lease claim submitted by VCC, LLC was satisfied directly by the Debtors by virtue of 

assuming and curing the contract with the third-party contractor, Matching Pro, on whose invoices 

VCC, LLC relies in its alleged secured claim against the Debtors. The invoices submitted by VCC, 

LLC concern services provided by Matching Pro in relation to the same property as the assumed 

contract with Matching Pro. As set forth more fully below, this Objection is without prejudice to 

seeking reduction of the claim after reclassification to reflect this satisfaction. 

36. For the Brickell Lease, even if there were collateral, any secured claim was satisfied 

and released pursuant to the Plan as the Brickell Lease was assumed and cured, with sufficient 

proceeds to pay VCC, LLC’s claim in full. As set forth more fully below, this Objection is without 

prejudice to seeking reduction of the claim after reclassification to reflect this satisfaction. 

V. RESERVATION OF RIGHTS 

37. This Objection is limited to the grounds stated herein. Accordingly, it is without 

prejudice to the rights of the Reorganized Debtors, the GUC Trustee, or any other party in interest 

Case 20-14696-LMI Doc 341 Filed 12/13/21 Page 11 of 16
09923-00001/13075643.3 12 

to object to any claim on any grounds whatsoever, and the Reorganized Debtors expressly reserve 

all further substantive or procedural objections they may have. The Reorganized Debtors 

expressly reserve the right to further amend, modify, or supplement this Objection and to file 

additional substantive or non-substantive objections to the Claim. Should one or more grounds of 

objection set forth in this Objection be overruled, the Reorganized Debtors reserve the right to 

object to the Claim on any other applicable ground. The Reorganized Debtors also expressly 

reserve the right to raise further objections, including objections under Section 502(d) of the 

Bankruptcy Code. 

38. Nothing contained herein or any actions taken pursuant to such relief is intended or 

should be construed as (a) an admission as to the validity of any prepetition claim against a Debtor 

entity; (b) a waiver of any party’s right to dispute any prepetition claim on any grounds; (c) a 

promise or requirement to pay any prepetition claim; (d) an implication or admission that any 

particular claim is of a type specified or defined in this Objection or any order granting the relief 

requested by this Objection; (e) a request or authorization to assume any prepetition agreement, 

contract, or lease pursuant to Section 365 of the Bankruptcy Code; or (f) a waiver of the 

Reorganized Debtors’ rights under the Bankruptcy Code or any other applicable law. 

VI. NOTICE

39. The Reorganized Debtors will provide notice of this Objection to: (a) the Office of 

the United States Trustee for the Southern District of Florida; (b) the entity filing the Claim and 

its counsel, if any; and (c) any party that has requested notice pursuant to Bankruptcy Rule 2002. 

The Reorganized Debtors submit that, in light of the nature of the relief requested, no other or 

further notice need be given. 

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09923-00001/13075643.3 13 

VII. CONCLUSION 

 WHEREFORE, the Reorganized Debtors respectfully request entry of an Order 

substantially in the form attached hereto as Exhibit A, (a) sustaining the instant Objection; (b) 

reclassifying from secured to general unsecured Claim No. 80 of VCC, LLC filed in Case No. 20-

14695; and (c) granting any and further relief as the Court deems just and proper. 

 Respectfully submitted this 13th day of December, 2021. 

 QUINN EMANUEL URQUHART & 

 SULLIVAN, LLP 

 

 Patricia B. Tomasco (admitted pro hac vice) 

 Joanna Diane Caytas (admitted pro hac vice) 

 711 Louisiana Street, Suite 500 

 Houston, Texas 77002 

 Telephone: 713-221-7000 

 Facsimile: 713-221-7100 

 Email: pattytomasco@quinnemanuel.com

 Email: joannacaytas@quinnemanuel.com 

 

 By: /s/ Patricia B. Tomasco

 Patricia B. Tomasco (admitted pro hac 

 vice) 

 

 Juan P. Morillo (FBN 135933) 

 1300 I Street, NW, Suite 900 

 Washington, D.C. 20005 

 Telephone: 202-538-8000 

 Facsimile: 202-538-8100 

 Email: juanmorillo@quinnemanuel.com

 

 -and- 

 

Case 20-14696-LMI Doc 341 Filed 12/13/21 Page 13 of 16
09923-00001/13075643.3 14 

 

BAST AMRON LLP 

 Jeffrey P. Bast (FBN 996343) 

 Brett M. Amron (FBN 148342) 

Jaime B. Leggett (FBN 1016485) 

 One Southeast Third Avenue, Suite 1400 

 Sun Trust International Center

 Miami, Florida 33131 

 Telephone: 305-379-7904 

 Facsimile: 305-379-7905 

 Email: jbast@bastamron.com

 Email: bamron@bastamron.com 

Email: jleggett@bastamron.com 

 

COUNSEL FOR CINEMEX HOLDINGS 

USA, INC. 

Case 20-14696-LMI Doc 341 Filed 12/13/21 Page 14 of 16
09923-00001/13075599.1 

UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

www.flsb.uscourts.gov

In re: Chapter 11 

 

CINEMEX HOLDINGS USA, 

INC., 

 Case No. 20-14696-LMI 

 (Formerly Jointly Administered Under

Reorganized Debtor. Lead Case: Cinemex USA Real Estate 

Holdings, Inc., Case No. 20-14695-

LMI) 

___________________________ / 

ORDER GRANTING REORGANIZED DEBTOR’S OBJECTION TO 

CLAIM NO. 80 OF VCC, LLC 

 This matter having been considered without hearing upon the objection (ECF No. ___) 

(the “Objection”) of the Reorganized Debtor to Claim No. 80 of VCC, LLC in Case No. 20-14695, 

and the objector by submitting this form of order having represented that the Objection was served 

on the parties listed below, that the 30-day response time provided by Local Rule 3007-1(D) has 

expired, that no one listed below has filed, or served on the objector, a response to the Objection, 

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09923-00001/13075599.1 2 

and that the relief to be granted in this Order is the identical relief requested in the Objection, and 

this Court having considered the bases for the Objection to the Claim, it is 

 ORDERED that the Reorganized Debtor’s Objection to the following claim is sustained as 

set forth herein: 

1. Claim No. 80 of VCC, LLC filed in Case No. 20-14695 is reclassified from a 

secured to general unsecured claim in its entirety and disallowed in its entirety for the reasons set 

forth in the Objection; and 

2. The Clerk of the Court and the Reorganized Debtor’s claims agent are authorized 

and directed to update the claims register maintained in these chapter 11 cases to reflect the relief 

granted in this Order. 

# # # 

Submitted By: 

Patricia B. Tomasco 

Quinn Emanuel Urquhart & Sullivan, LLP 

711 Louisiana, Suite 500 

Houston, Texas 77002 

Telephone: 713-221-7100 

Email: pattytomasco@quinnemanuel.com 

Copies to: 

Attorney Patty Tomasco, who shall serve a copy of this order on all interested parties and file a 

certificate of service reflecting same.

Case 20-14696-LMI Doc 341 Filed 12/13/21 Page 16 of 16