Case 22-90168 Document 1724 Filed in TXSB on 05/23/23 Page 1 of 8

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION

)
In re: ) Chapter 11
)
CINEWORLD GROUP PLC, et al., 1 ) Case No. 22-90168 (MI)
)
Debtors. ) (Jointly Administered)
) (Emergency Relief Requested)

DEBTORS’ EMERGENCY MOTION FOR ENTRY

OF AN ORDER (I) RESETTING THE COMBINED HEARING DATE
AND (II) EXTENDING CERTAIN DEADLINES RELATED THERETO

Emergency relief has been requested. Relief is requested not later than May 26, 2023.
If you object to the relief requested or you believe that emergency consideration is not
warranted, you must appear at the hearing if one is set, or file a written response
prior to the date that relief is requested in the preceding sentence. Otherwise, the
Court (as defined herein) may treat the pleading as unopposed and grant the relief
requested.

The above-captioned debtors and debtors in possession (collectively, the “Debtors”) state

the following in support of this motion (this “Motion”): 2

Relief Requested

1. The Debtors seek entry of an order, substantially in the form attached hereto

(the “Order”), (a) resetting the Combined Hearing Date and (b) extending certain deadlines related

thereto as follows:

1
A complete list of each of the Debtors in these chapter 11 cases may be obtained on the website of the Debtors’
claims and noticing agent at https://cases.ra.kroll.com/cineworld. The location of Debtor Cineworld Group plc’s
principal place of business and the Debtors’ service address in these chapter 11 cases is: 8th Floor Vantage
London, Great West Road, Brentford, England, TW8 9AG, United Kingdom.
2
Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in (a) the Declaration
of Israel Greidinger, Deputy Chief Executive Officer of Cineworld Group plc, in Support of the Debtors’ Chapter
11 Petitions and First Day Motions [Docket No. 19] (the “Greidinger First Day Declaration”) and (b) the
Declaration of James A. Mesterharm, Chief Restructuring Officer of Cineworld Group plc, in Support of the
Debtors’ Chapter 11 Petitions and First Day Motions [Docket No. 80] (together with the Greidinger First Day
Declaration, the “First Day Declarations”), or the Disclosure Statement Motion (as defined herein), as applicable.
 Case 22-90168 Document 1724 Filed in TXSB on 05/23/23 Page 2 of 8

Event Current Deadline/Time New Deadline/Time

(Prevailing Central Time) (Prevailing Central Time)
Plan Supplement Filing May 26, 2023 June 6, 2023
Deadline
Deadline to File Voting June 11, 2023, at June 15, 2023, at 12:00 p.m.
Report 12:00 p.m.
Combined Hearing Date June 12, 2023, at 8:00 a.m. June 28, 2023

2. The relief requested herein—which will allow the Debtors to continue working with

all parties in interest to finalize the Plan and the definitive documents contemplated therein—is

supported by the Ad Hoc Group (which includes therein all of the Debtors’ DIP Lenders), the U.S.

Trustee (as defined herein), and the Committee (as defined herein). The Debtors are not aware of

any objections to this Motion.

Jurisdiction and Venue

3. The United States Bankruptcy Court for the Southern District of Texas

(the “Court”) has jurisdiction over this matter pursuant to 28 U.S.C. § 1334. This is a core

proceeding pursuant to 28 U.S.C. § 157(b). The Debtors confirm their consent to the entry of a

final order by the Court.

4. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

5. The bases for the relief requested herein are section 105 of title 11 of the United

States Code (the “Bankruptcy Code”), rule 9006 of the Federal Rules of Bankruptcy Procedure

(the “Bankruptcy Rules”), and rules 2002-1 and 9013-1 of the Bankruptcy Local Rules for the

Southern District of Texas (the “Bankruptcy Local Rules”).

Preliminary Statement

6. On September 7, 2023 (the “Petition Date”), each Debtor filed a voluntary petition

for relief under chapter 11 of the Bankruptcy Code. A detailed description of the Debtors, their

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businesses, and the facts and circumstances supporting the Debtors’ chapter 11 cases are set forth

in greater detail in the First Day Declarations.

7. On the Petition Date, the Court entered an order authorizing the joint administration

and procedural consolidation of these chapter 11 cases pursuant to Bankruptcy Rule 1015(b) and

Bankruptcy Local Rule 1015-1 [Docket No. 32]. The Debtors are operating their businesses and

managing their properties as debtors in possession pursuant to sections 1107(a) and 1108 of the

Bankruptcy Code. On September 23, 2022, the Office of the United States Trustee for the Southern

District of Texas (the “U.S. Trustee”) appointed an official committee of unsecured creditors

[Docket No. 419] (the “Committee”). No request for the appointment of a trustee or examiner has

been made in these chapter 11 cases.

8. On April 10, 2023, the Debtors filed the Debtors’ Emergency Motion for Entry of

an Order (I) Conditionally Approving the Adequacy of the Disclosure Statement, (II) Approving

the Solicitation Procedures with Respect to Confirmation of the Debtors’ Proposed Chapter 11

Plan, (III) Approving the Forms of Ballots and Notices in Connection Therewith, (IV) Approving

the Rights Offering Procedures and Related Materials, (V) Scheduling Certain Dates with Respect

Thereto, and (VI) Granting Related Relief [Docket No. 1512] (the “Disclosure Statement

Motion”).

9. On April 25, 2023, the Court entered the Order (I) Conditionally Approving the

Adequacy of the Disclosure Statement, (II) Approving the Solicitation Procedures with Respect to

Confirmation of the Debtors’ Proposed Chapter 11 Plan, (III) Approving the Forms of Ballots and

Notices in Connection Therewith, (IV) Approving the Rights Offering Procedures and Related

Materials, (V) Scheduling Certain Dates with Respect Thereto, and (VI) Granting Related Relief

[Docket No. 1596] (the “Disclosure Statement Order”).

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10. The Disclosure Statement Order establishes (a) May 26, 2023 as the deadline to file

the Plan Supplement, (b) June 11, 2023, at 12:00 p.m. (prevailing Central Time), as the deadline

to file the Voting Report, and (c) June 12, 2023, at 8:00 a.m. (prevailing Central Time), as the

Combined Hearing to consider final approval of the Second Amended Disclosure Statement

Relating to the Second Amended Joint Chapter 11 Plan of Reorganization of Cineworld Group plc

and Its Debtor Subsidiaries [Docket No. 1610] and confirmation of the Second Amended Joint

Chapter 11 Plan of Reorganization of Cineworld Group plc and Its Debtor Subsidiaries [Docket

No. 1603].

Basis for Relief

11. Section 105(a) of the Bankruptcy Code authorizes a court to “issue any order,

process, or judgment that is necessary or appropriate to carry out the provisions of this title.”

11 U.S.C. § 105(a). Bankruptcy Rule 9006(b) authorizes courts to extend deadlines that were

scheduled by a previous court order, and states, in pertinent part, that:

when an act is required or allowed to be done at or within a specified period by

these rules or by a notice given thereunder or by order of court, the court for cause
shown may at any time in its discretion . . . with or without motion or notice order
the period enlarged if the request therefor is made before the expiration of the period
originally prescribed or as extended by a previous order[.]

Bankruptcy Rule 9006(b).

12. The Court has ample authority to modify the dates as requested herein.

The Disclosure Statement Order provides that the dates established therein are “subject to

modification as necessary by the Debtors, in consultation with the Required Consenting Creditors,

the Required Equity Capital Raising Parties, and the Committee.” Disclosure Statement Order,

¶ 5. The Combined Hearing Notice, as approved by the Court through the Disclosure Statement

Order, provides that the Combined Hearing “may be continued from time to time by the Court or

4
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the Debtors without further notice other than by such adjournment being announced in open court

or by a notice of adjournment filed with the Court and served on all parties entitled to notice.”

Combined Hearing Notice at p. 1 (emphasis added). As mentioned above, the Debtors’ key

stakeholders support the relief requested herein, and no parties’ rights are being prejudiced by the

relief requested herein.

13. Accordingly, the Debtors request that the Court grant the relief requested herein.

Emergency Consideration

14. The Debtors request emergency consideration of this Motion in accordance with

Bankruptcy Local Rule 9013-1. This Motion solely requests procedural relief, which is ultimately

for the benefit of the Debtors, their estates, and all parties in interest. Moreover, emergency relief

is appropriate in light of the current deadline to file the Plan Supplement on May 26, 2023.

Accordingly, the Debtors request that the Court approve the relief requested in this Motion on an

emergency basis.

Notice

15. The Debtors will provide notice of this Motion to the following parties and/or their

respective counsel, including: (a) the U.S. Trustee; (b) the holders of the 30 largest unsecured

claims against the Debtors (on a consolidated basis); (c) counsel to the Committee; (d) the agent

under the Prepetition Priming Facility, and counsel thereto; (e) the agent under the Prepetition

Legacy Term Facilities, and counsel thereto; (f) the agent under the Revolving Credit Facility, and

counsel thereto; (g) counsel to the ad hoc group of Prepetition Revolving Lenders; (h) counsel to

the Ad Hoc Group; (i) the agent under the Settlement Facility, and counsel thereto; (j) counsel to

lenders under the Settlement Facility; (k) the trustee under the Convertible Bonds, and counsel

thereto; (l) counsel to the ad hoc group of holders of Convertible Bonds; (m) the agent under the

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DIP Facility and counsel thereto; (n) the Office of the United States Attorney for the Southern

District of Texas; (o) the state attorneys general for states in which the Debtors conduct business;

(p) the Internal Revenue Service; (q) the Securities and Exchange Commission; (r) the

Environmental Protection Agency; (s) other governmental agencies having a regulatory or

statutory interest in these cases; and (t) any party that has requested notice pursuant to Bankruptcy

Rule 2002. In light of the nature of the relief requested, no other or further notice need be given.

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WHEREFORE, the Debtors request that the Court enter the Order granting the relief

requested herein and such other relief as the Court deems appropriate under the circumstances.

Houston, Texas
Dated: May 23, 2023

/s/ Rebecca Chaikin

JACKSON WALKER LLP KIRKLAND & ELLIS LLP
Matthew D. Cavenaugh (TX Bar No. 24062656) KIRKLAND & ELLIS INTERNATIONAL LLP
Rebecca Blake Chaikin (TX Bar No. 24133055) Joshua A. Sussberg, P.C. (admitted pro hac vice)
Veronica A. Polnick (TX Bar No. 24079148) Ciara Foster (admitted pro hac vice)
Vienna Anaya (TX Bar No. 24091225) 601 Lexington Avenue
1401 McKinney Street, Suite 1900 New York, New York 10022
Houston, TX 77010 Telephone: (212) 446-4800
Telephone: (713) 752-4200 Facsimile: (212) 446-4900
Facsimile: (713) 752-4221 Email: [email protected]
[email protected] [email protected]
[email protected]
[email protected] Co-Counsel to the Debtors
and Debtors in Possession
Co-Counsel to the Debtors
and Debtors in Possession
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Certificate of Accuracy

I certify that the foregoing statements are true and accurate to the best of my knowledge.
This statement is being made pursuant to Bankruptcy Local Rule 9013-1(i).

/s/ Rebecca Chaikin

Rebecca Blake Chaikin

Certificate of Service

I certify that, on May 23, 2023, I caused a copy of the foregoing document to be served by
the Electronic Case Filing System for the United States Bankruptcy Court for the Southern District
of Texas.

/s/ Rebecca Chaikin

Rebecca Blake Chaikin
 Case 22-90168 Document 1724-1 Filed in TXSB on 05/23/23 Page 1 of 3

IN THE UNITED STATES BANKRUPTCY COURT

FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION

) Chapter 11
In re: )
) Case No. 22-90168 (MI)
CINEWORLD GROUP PLC, et al., 1 )
) (Jointly Administered)
Debtors. )
) Re: Docket No. _____

ORDER (I) RESETTING THE COMBINED HEARING DATE

AND (II) EXTENDING CERTAIN DEADLINES RELATED THERETO

Upon the motion (the “Motion”) 2 of the above-captioned debtors and debtors in possession

(collectively, the “Debtors”) for entry of an order (this “Order”) (a) resetting the Combined

Hearing Date and (b) extending certain deadlines with respect thereto, all as more fully set forth

in the Motion; and this Court having jurisdiction over this matter pursuant to 28 U.S.C. § 1334;

and this Court having found that this is a core proceeding pursuant to 28 U.S.C. § 157(b); and this

Court having found that it may enter a final order consistent with Article III of the United States

Constitution; and this Court having found that venue of this proceeding and the Motion in this

district is proper pursuant to 28 U.S.C. §§ 1408 and 1409; and this Court having found that the

relief requested in the Motion is in the best interests of the Debtors’ estates, their creditors, and

other parties in interest; and this Court having found that the Debtors’ notice of the Motion and

opportunity for a hearing on the Motion were appropriate and no other notice need be provided;

and this Court having reviewed the Motion and having heard the statements in support of the relief

1
A complete list of each of the Debtors in these chapter 11 cases may be obtained on the website of the Debtors’
claims and noticing agent at https://cases.ra.kroll.com/cineworld. The location of Debtor Cineworld Group plc’s
principal place of business and the Debtors’ service address in these chapter 11 cases is: 8th Floor Vantage
London, Great West Road, Brentford, England, TW8 9AG, United Kingdom.
2
Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in the Motion.
 Case 22-90168 Document 1724-1 Filed in TXSB on 05/23/23 Page 2 of 3

requested therein at a hearing before this Court (the “Hearing”), if any; and this Court having

determined that the legal and factual bases set forth in the Motion and at the Hearing, if any,

establish just cause for the relief granted herein; and upon all of the proceedings had before this

Court; and after due deliberation and sufficient cause appearing therefor, it is HEREBY

ORDERED THAT:

1. Cause exists to extend certain deadlines set forth in the Disclosure Statement Order.

The following dates are hereby established:

Event Previous Deadline/Time New Deadline/Time

(Prevailing Central Time) (Prevailing Central Time)
Plan Supplement Filing May 26, 2023 June 6, 2023
Deadline
Deadline to File Voting June 11, 2023, at June 15, 2023, at
Report 12:00 p.m. 12:00 p.m.
Combined Hearing Date June 12, 2023, at 8:00 a.m. June 28, 2023, at ________

2. Except as modified by this Order, the Disclosure Statement Order, including the

deadlines set forth therein, remains in full force and effect in all respects.

3. Notice of the Motion as provided therein shall be deemed good and sufficient notice

of such Motion, and the requirements of Bankruptcy Rule 6004(a) and the Bankruptcy Local Rules

are satisfied by such notice.

4. The Debtors are authorized to take all actions necessary to effectuate the relief

granted in this Order in accordance with the Motion.

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5. This Court retains exclusive jurisdiction with respect to all matters arising from or

related to the implementation, interpretation, and enforcement of this Order.

Dated: _______, 2023

MARVIN ISGUR
UNITED STATES BANKRUPTCY JUDGE