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The motion argues that the vehicles are depreciating assets and reports of vandalism, damage, theft, or missing vehicles increase risk. It also cites pending requests to cancel non-paid insurance policies and the trustee’s alleged delay in securing insurance and liquidation steps. The filing requires a written, detailed response by the stated deadline to avoid admission of allegations.",{"@graph":69,"@context":123},[70,84,106],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":40,"@type":76,"position":81},"https://docshare.wps.com/document/research-report/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/tricolor-holdings-llc-tbk-bank-ssbs-motion-for-i-relief-from-the-automatic-stay-and-ii-adequate-protection/267926/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/tricolor-holdings-llc-tbk-bank-ssbs-motion-for-i-relief-from-the-automatic-stay-and-ii-adequate-protection/267926.png","ImageObject",300,407,{"name":92,"@type":93},"Connor ","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-11-02","2026-09-14",true,{"@type":102,"interactionType":103,"userInteractionCount":105},"InteractionCounter",{"@type":104},"ViewAction",12,{"@type":107,"mainEntity":108},"FAQPage",[109,115,119],{"name":110,"@type":111,"acceptedAnswer":112},"What relief does TBK Bank, SSB request from the bankruptcy court?","Question",{"text":113,"@type":114},"TBK Bank requests an order granting relief from the automatic stay and directing adequate protection for its collateral interests in designated vehicles.","Answer",{"name":116,"@type":111,"acceptedAnswer":117},"Why does TBK Bank argue that adequate protection is necessary?",{"text":118,"@type":114},"TBK Bank contends the vehicles are depreciating and subject to risks such as vandalism, damage, theft, or being unaccounted for, and that insurance coverage has not been evidenced.",{"name":120,"@type":111,"acceptedAnswer":121},"What is the required response procedure and deadline stated in the motion?",{"text":122,"@type":114},"The debtor entities must file a written response with the bankruptcy clerk by the stated deadline before close of business on October 29, 2025, and the motion warns that failure to respond may result in allegations being deemed admitted and relief entered by default.","https://schema.org",{"og:url":83,"og:type":125,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":127,"canonical":83},"index,follow",{"doc_id":129,"site_id":62},267926,1789426562,{"code":4,"msg":5,"data":132},{"doc_id":129,"user_id":133,"nickname":92,"user_avatar":134,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":135,"file_id":136,"file_url":137,"file_type":138,"file_size":139,"view_count":105,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":41,"language":140,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":141,"faqs":142,"seo_title":143,"seo_description":67,"update_tm":130,"read_time":144,"preview_page_count":4},687207022233,"https://ap-avatar.wpscdn.com/davatar_155a257f0dc6eb9ab79c44ca47cae57d","Case 25-33487-mvl7 Doc 202 Filed 10/15/25 Entered Document Page 1 of 30  \nDesc Main  \nDate Filed: 10/15/2025  \nVINSON & ELKINS LLP  \nBradley R. Foxman (TX 24065243) Matthew W. Moran (TX 24002642) Sara E. Zoglman (TX 24121600) 2001 Ross Avenue, Suite 3900 Dallas, Texas 75201  \nTel: 214-220-7700  \nFax: 214-220-7716  \nEmail: [bfoxman@velaw.com](bfoxman@velaw.com)  \n[mmoran@velaw.com](mmoran@velaw.com)[szoglman@velaw.com](szoglman@velaw.com)  \nVINSON & ELKINS LLP  \nPaul E. Heath (TX 09355050)  \n845 Texas Avenue, Suite 4700 Houston, Texas 77002  \nTel: 713-758-2222  \nFax: 713-758-2346  \nEmail: [pheath@velaw.com](pheath@velaw.com)  \nCounsel to TBK Bank, SSB  \nIN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION  \nIn re  \nTRICOLOR HOLDINGS, LLC, et al.,  \nDebtors.1  \n§§  \n§§  \n§§  \n§  \nChapter 7  \nCase No. 25-33487 (MVL)  \nJointly Administered  \nTBK BANK, SSB’S MOTION FOR (I) RELIEF FROM  THE AUTOMATIC STAY AND (II) ADEQUATE PROTECTION   \nPURSUANT TO LOCAL BANKRUPTCY RULE 4001-1(b), A RESPONSE IS REQUIRED TO THIS MOTION, OR THE ALLEGATIONS IN THE MOTION MAY BE DEEMED ADMITTED, AND AN ORDER GRANTING THE RELIEF SOUGHT MAY BE ENTERED BY DEFAULT.  \nANY RESPONSE SHALL BE IN WRITING AND FILED WITH THE CLERK OF THE UNITED STATES BANKRUPTCY COURT AT 1100 COMMERCE STREET, ROOM 1254, DALLAS, TEXAS 75242, BEFORE CLOSE OF BUSINESS ON OCTOBER 29, 2025, WHICH IS AT LEAST 14 DAYS FROM THE DATE OF SERVICE HEREOF. A COPY  \n1 The Debtors and their bankruptcy case numbers are: Tricolor Holdings, LLC (25-33487), TAG Intermediate Holding Company, LLC (25-33495), Tricolor Auto Group, LLC (25-33496), Tricolor Auto Acceptance, LLC (25-33497), Tricolor Insurance Agency, LLC (25-33512), Tricolor Home Loans LLC (25-33511), Tricolor Real Estate Services (25-33514), TAG California Holding Company, LLC (25-33493), Flexi Compras Autos, LLC (25-33490), TAG California Intermediate Holding Company, LLC (25-33494), Tricolor California Auto Group, LLC (25-33502), Tricolor California Auto Acceptance, LLC (25-33501), Risk Analytics LLC (25-33491), Tricolor Tax, LLC (25-33515), Tricolor Financial, LLC (25-33510), Tricolor Auto Receivables LLC (25-33498), TAG Asset Funding, LLC (25-33492), Apoyo Financial, LLC (25-33489) .  \n¨2¤UBw9*/ *w«  \n2533487251015000000000010  \nCase 25-33487-mvl7 Doc 202 Filed 10/15/25 Entered 10/15/25 19:17:22 Desc Main  \nDocument Page 2 of 30  \nSHALL BE SERVED UPON COUNSEL FOR THE MOVING PARTY AND ANY TRUSTEE OR EXAMINER APPOINTED IN THE CASE. ANY RESPONSE SHALL INCLUDE A DETAILED AND COMPREHENSIVE STATEMENT AS TO HOW THEMOVANT CAN BE “ADEQUATELY PROTECTED” IF THE STAY IS TO BE CONTINUED.  \nTBK Bank, SSB (“TBK Bank” or the “Agent”) files this motion (the “Motion”) seeking entry of an order, substantially in the form attached hereto as Exhibit 1, (a) granting relief from the automatic stay pursuant to section 362 of title 11 of the United States Code (the “Bankruptcy Code”) and permitting TBK Bank to exercise rights and remedies in connection with certain of the Debtors’ vehicles identified below, and (b) directing the Trustee to immediately provide TBK Bank with adequate protection of its interests in its collateral identified below pursuant to sections 361 and 363 of the Bankruptcy Code. In support of this Motion, TBK Bank respectfully states as follows:  \nPRELIMINARY STATEMENT2  \n1. As this Court is well aware, the primary assets in the Debtors’ estates, and TBKBank’s Collateral, are the Vehicles—which are depreciating assets that lose value as time passes. TBK Bank has recently learned about new, additional threats to the Vehicles. At multiple of the Subject Debtors’ locations, there are reports of Vehicles being vandalized, damaged, missing or otherwise unaccounted for. Further, there is a motion pending before this Court to retroactively cancel, for non-payment, the only insurance policies that TBK Bank has seen evidence of with respect to the Vehicles.3 TBK Bank has requested that the Trustee safeguard the ","cbCainAnZohI3rBa","https://ap.wps.com/l/cbCainAnZohI3rBa","pdf",631654,"English","# Preliminary Statement\n# Motion Background and Relief Requested\n## Adequate Protection and Collateral Interests\n## Insurance Coverage and Vehicle Risks\n# Relief Sought and Response Deadline","[{\"question\":\"What relief does TBK Bank, SSB request from the bankruptcy court?\",\"answer\":\"TBK Bank requests an order granting relief from the automatic stay and directing adequate protection for its collateral interests in designated vehicles.\"},{\"question\":\"Why does TBK Bank argue that adequate protection is necessary?\",\"answer\":\"TBK Bank contends the vehicles are depreciating and subject to risks such as vandalism, damage, theft, or being unaccounted for, and that insurance coverage has not been evidenced.\"},{\"question\":\"What is the required response procedure and deadline stated in the motion?\",\"answer\":\"The debtor entities must file a written response with the bankruptcy clerk by the stated deadline before close of business on October 29, 2025, and the motion warns that failure to respond may result in allegations being deemed admitted and relief entered by default.\"}]","TRICOLOR HOLDINGS, LLC - TBK BANK, SSB’S MOTION FOR (I) RELIEF FROM THE AUTOMATIC STAY AND (II) ADEQUATE PROTECTION | PDF",76]