Executive Summary

First Brands Group filed a chapter 11 plan for debtor Premier Marketing Group (PMG) that would establish a litigation trust for the benefit of certain creditors, while all other debtors under the First Brands umbrella would have their cases converted to a chapter 7 liquidation. The plan only covers PMG, but certain creditors of the First Brands Group debtors will be permitted to share in the recoveries realized by the litigation trust. After the effective date of the PMG plan, First Brands will convert the chapter 11 cases of all other debtors to chapter 7. The plan incorporates the terms of a settlement with the ad hoc group and unsecured creditors committee (UCC) that would transfer all estate claims of the First Brands debtors to the litigation trust, which will prosecute and monetize those claims for the benefit of First Brands’ creditors.