First Brands Group, LLC and WEM US Co. — Entry #3993: Proposed Order RE: (Filed By Michael Bueno ).(Related document(s):[3079] Motion for Relief From Stay) (Pollan, Jennifer)

Case 25-90399 Document 3993 Filed in TXSB on 10/26/26 Page 1 of 5


                             IN THE UNITED STATES BANKRUPTCY COURT
                               FOR THE SOUTHERN DISTRICT OF TEXAS
                                        HOUSTON DIVISION

    In re:                                                 §
                                                           §       Chapter 11
    FIRST BRANDS GROUP, LLC, et al.                        §
                                                           §       Case No. 25-90399 (CML)
              Debtors.   1
                                                           §       (Jointly Administered)


    AGREED ORDER GRANTING MICHAEL BUENO’S MOTION FOR RELIEF FROM
           THE AUTOMATIC STAY PURSUANT TO 11 U.S.C. § 362(d)(1)
                        [Relates to Docket No. 3079]

             This matter came before the Court upon consideration of Michael Bueno’s Motion for

Relief from the Automatic Stay Pursuant to 11 U.S.C. § 362(d)(1) (the “Motion”) 2 (ECF No. 3079)

filed by Michael Bueno (the “Movant”), pursuant to which the Movant seeks relief from the

automatic stay to proceed with the State Court Action, as more fully described in the Motion. The

Court having considered the Movant’s request and opposition thereto, if any; and it appearing that

due and proper notice of the Motion has been provided under the circumstances; and it further

appearing that that the Movant and Eva S. Engelhart, the chapter 7 trustee (the “Trustee”) of the

jointly administered bankruptcy estates of First Brands Group, LLC, First Brands Group Holdings,

LLC’s direct and indirect subsidiaries, and Viceroy Private Capital, LLC (collectively, the “FBG

Debtors” and together with the Movant, the “Parties”) to the Motion have reached an agreement;

and the Court finds that the Motion should be granted in the manner set forth below. It is hereby:

             1. ORDERED that as to Debtor Cardone Industries, Inc. (“Cardone”):


1
  A complete list of the “Debtors” in these chapter 7 cases may be obtained on the website of the Debtors’ claims and
noticing agent at https://restructuring.ra.kroll.com/firstbrands. The Debtors’ service address for these chapter 7 cases
is Eva Engelhart, Chapter 7 Trustee c/o Porter Hedges LLP, Joshua W. Wolfshohl, 1000 Main St., 36th Floor, Houston,
Texas 77002.
2
    Capitalized terms used but not defined in this Order shall have the meanings ascribed to them in the Motion.


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                 a. The stay found in section 362(a) of the Bankruptcy Code is hereby modified

                       solely to authorize Movant to prosecute to final judgment the State Court Action

                       against Cardone to establish liability, determine damages, pursue recovery from

                       applicable insurance policy proceeds, subject to the applicable insurance policy

                       limits, and against non-debtors, and for no other purpose;

                 b. Other than as set forth in the immediately preceding subparagraph, the stay

                       remains in full force and effect for all other purposes and continues to prohibit

                       execution, garnishment, collection, attachment, or enforcement of any such

                       judgment, if any, awarded to Movant, against Cardone, any FBG Debtor’s

                       estate, or their non-insurance assets;

                 c. By signature of Movant’s counsel below, Movant waives his right to file or

                       assert any proof of claim (or other claim) in any of the bankruptcy cases of any

                       of the FBG Debtors, and any such proof of claim (whether already filed or filed

                       in the future, including Claim No. 2433) or scheduled claim is hereby

                       disallowed in its entirety;

                 d. Nothing in this Order shall be construed as Movant having waived his right(s),

                       if any, to look to applicable insurance proceeds or to otherwise look to any non-

                       debtor to be made whole, which rights, to the extent they exist, are hereby

                       strictly preserved;

                 e. With respect to any and all parties in interest, nothing in this Order shall be

                       construed as any admission of liability whatsoever or any waiver of any defense

                       whatsoever, and all rights and defenses of the FBG Debtors and their estates are

                       hereby expressly preserved; and


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        2. ORDERED that nothing in this stipulation and agreed order constitutes a

            determination of liability, damages, insurance coverage, policy limits, policy defenses,

            or the allowance or disallowance of any claim in the bankruptcy case.

        3. ORDERED that the 14-day stay found in Bankruptcy Rule 4001(a)(4) is waived.

        4. ORDERED that this Court shall retain exclusive jurisdiction with respect to all matters

            arising from or related to the implementation, enforcement, or interpretation of this

            Order.

SIGNED ___________________, 2026.


                                              THE HONORABLE CHRISTOPHER M. LOPEZ
                                              UNITED STATES BANKRUPTCY JUDGE


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STIPULATED AND AGREED TO BY:

 HUSCH BLACKWELL LLP                     PORTER HEDGES, LLP

  /s/ Jennifer K. Pollan                 /s/ Joshua W. Wolfshohl
 Lynn Hamilton Butler (SBN 03527350)     Joshua W. Wolfshohl (SBN 24038592
 Lynn.Butler@huschblackwell.com          jwolfshohl@porterhedges.com
 Jennifer Pollan (SBN 24150828)          Eric M. English (TX Bar No. 24062714)
 Jennifer.pollan@huschblackwell.com      eenglish@porterhedges.com
 111 Congress Ave., Suite 1400           M. Shane Johnson (TX Bar No. 24083263)
 Austin, Texas 78701                     sjohnson@porterhedges.com
 Tel: (512) 472-5456                     Grecia V. Sarda (TX Bar No. 24132092)
 Fax: (512) 479-1101                     gsarda@porterhedges.com
                                         1000 Main, 36th Floor
                                         Houston, TX 77002
                                         Tel: 713-226-6000
                                         Fax: 713-228-1331


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                                 CERTIFICATE OF SERVICE

        I hereby certify that on October 26, 2026, a true and correct copy of the foregoing document

was served via this Court’s ECF notification system to all parties registered to receive notification,

which includes Cardone.

                                               /s/ Jennifer K. Pollan
                                               Jennifer K. Pollan


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