UNITED STATES BANKRUPTCY COURT 

SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

In re: Chapter 11 CINEMEX USA REAL ESTATE Case No. 20-14695-LMI 

HOLDINGS, INC., et al. 

 Jointly Administered 

 Debtors. 

____________________________________/ 

NOTICE OF APPEARANCE BY STICHTER, RIEDEL, BLAIN & POSTLER, 

P.A., FOR PROCTOR EQUIPMENT COMPANY AND REQUEST TO 

RECEIVE DOCUMENTS AND TO BE ADDED TO MAILING MATRIX 

PLEASE TAKE NOTICE THAT the undersigned law firm and counsel appear 

for Proctor Equipment Company (“Proctor”). Pursuant to Section 1109(b) of the 

Bankruptcy Code, Stichter, Riedel, Blain & Postler, P.A. (“SRB&P”), requests that all 

notices given or required to be given in this case, and all papers served or required to be 

served in this case, be given and served upon: 

 Scott A. Stichter 

 Stichter, Riedel, Blain & Postler, P.A. 

 110 East Madison Street, Suite 200 

 Tampa, Florida 33602 

 (813) 229-0144 – Phone 

 (813) 229-1811 – Fax 

 sstichter@srbp.com 

 

 PLEASE TAKE NOTICE that under Section 1109(b) of the Bankruptcy Code, 

this request includes not only the notices and papers referred to in the Bankruptcy Rules 

specified above, but also includes, without limitation, order and notices of any 

application, motion, petition, pleadings, request, complaint, demand, whether formal or 

informal, whether written or oral, and whether transmitted or conveyed by mail, courier 

service, hand delivery, telephone, facsimile, telegraph, telex, electronic mail, or otherwise 

Case 20-14695-LMI Doc 154 Filed 05/27/20 Page 1 of 3
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that: (1) affects or seeks to affect in any way any right or interest of any creditor or party 

in interest in this case, including the Debtor with respect to: (a) the debtor; (b) property 

of the estate or proceeds thereof in which the debtor may claim an interest; or (c) property 

or proceeds thereof in possession, custody, or control of others that the debtor may seek 

to use; or (2) requires or seeks to require any act, delivery of any property, payment, or 

other conduct by Proctor and/or SRBP. 

 PLEASE TAKE NOTICE that Proctor intends that neither this Notice of 

Appearance nor any later appearance, pleading, claim, or suit shall waive (1) Proctor’s 

claim of sovereign immunity; (2) Proctor’s right to have final orders in non-core matters 

entered only after de novo review by a district judge; (3) Proctor’s right to trial by jury in 

any proceeding so triable in this case or any case, controversy, or proceeding related to 

this case; (4) Proctor’s right to have the district court withdraw the reference in any 

matter subject to mandatory or discretionary withdrawal, or; (5) any other rights, claims, 

actions, defenses, setoffs, or recoupments to which Proctor is or may be entitled under 

agreements, in law or in equity, all of which rights, claims, actions, defenses, setoffs, and 

recoupments Proctor expressly reserves. 

 /s/ Scott A. Stichter 

Scott A. Stichter (FBN 0710679) 

Stichter, Riedel, Blain & Postler, P.A. 

110 East Madison Street, Suite 200 

Tampa, Florida 33602 

sstichter@srbp.com

(813) 229-0144 – Phone 

(813) 229-1811 – Fax 

Attorneys for Proctor Equipment Company

Case 20-14695-LMI Doc 154 Filed 05/27/20 Page 2 of 3
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CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Notice of 

Appearance has been furnished by the Court’s CM/ECF system or U.S. MAIL on this 

27th day of May, 2020 to: 

 Jeffrey P. Bast, Esquire 

 Bast Amron, LLP 

 One Southeast Third Avenue, Suite 1400 

 SunTrust International Center 

 Miami, Florida 33131 

 Office of the U.S. Trustee 

 

 All parties receiving electronic notice 

 /s/ Scott A. Stichter 

Scott A. Stichter 

14172.2358937 

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