By: David “G” Kreluer
Hip-Hop Business • Legal, financial, and strategic intelligence for music industry professionals.

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A motion filed April 10, 2026, in federal bankruptcy court is asking a judge to impose financial penalties for every future violation of a non-disparagement clause that was embedded in a confirmed Chapter 11 plan — a legal posture that entertainment attorneys across the country need to read carefully, because the structural problem it exposes is not unique to this case. A sanctions hearing before Judge Scott M. Grossman in the United States Bankruptcy Court for the Southern District of Florida has been scheduled for May 6, 2026, at 2:30 p.m. The case is In re: Latasha Transrina Kebe, No. 23-14082.

What the Record Shows

In 2019, Belcalis Marlenis Almanzar, known professionally as Cardi B, filed a defamation lawsuit in federal court in Georgia against Latasha Transrina Kebe, the creator of the YouTube channel UnWineWithTashaK. In 2022, a federal jury in Georgia ruled for Almanzar and ordered Kebe to pay approximately $3.9 million in damages. Kebe subsequently filed for Chapter 11 bankruptcy protection, case number 23-14082, in the Southern District of Florida.

As part of Kebe’s confirmed Chapter 11 plan, the parties entered into a non-disparagement agreement. Under the terms of that agreement, Kebe agreed not to make derogatory public statements about Almanzar, Almanzar’s estranged husband Kiari Cephus (Offset), or others in Almanzar’s family and immediate circle. The agreement named Offset specifically during negotiation. In exchange, Almanzar agreed to defer collection of the full $3.9 million judgment, with Kebe’s Chapter 11 plan requiring repayment of $1.2 million over the first five years. The plan provides a 30.1 percent recovery to general unsecured creditors.

The 46-page sanctions motion, filed by Almanzar’s counsel at Meland Budwick PA, documents at least 25 alleged violations of the non-disparagement clause since the plan was confirmed in March 2026. The violations include 16 posts published on X between April 6 and April 10, the majority of which referenced a shooting involving Offset outside the Seminole Hard Rock Hotel and Casino in Hollywood, Florida, on April 7. The motion also alleges Kebe violated the agreement during podcast appearances and a TikTok livestream in which she publicly thanked another artist for donating approximately $3,000 to a GoFundMe Kebe launched in early March 2026 with a goal of raising $3.5 million. The motion argues the GoFundMe itself — framed as a campaign against Almanzar’s collection efforts — constitutes an ongoing violation.

The motion requests: a contempt finding; an immediate injunction prohibiting any direct or coded disparagement of Almanzar or her family across all platforms; attorney’s fees incurred in monitoring and enforcing the agreement since March 2025; and a financial penalty attached to each future violation at the moment it is published, not after it is deleted. The hearing has been designated non-evidentiary and allotted ten minutes on the court’s calendar.

What This Actually Means

The mainstream legal coverage has treated this as a celebrity dispute that keeps generating copy. It is that, but it is also a live demonstration of a structural defect in how non-disparagement agreements are drafted when a judgment debtor goes into bankruptcy — and that defect has direct implications for every entertainment attorney who has ever settled a defamation, harassment, or breach of contract dispute using a non-disparagement clause.

The core problem is that a non-disparagement clause in a confirmed bankruptcy plan is a different instrument than a non-disparagement clause in a private settlement agreement, and they do not carry the same enforcement tools. In a private settlement, a violation typically triggers breach of contract remedies: damages, specific performance, or termination of the settlement terms. The injured party can sue for breach and seek to accelerate the full underlying judgment. In a bankruptcy plan, the non-disparagement clause is embedded in a court-confirmed document, which makes violations a potential contempt of court matter — but contempt proceedings in bankruptcy are slow, procedurally demanding, and most federal bankruptcy judges approach them conservatively. The debtor also has fewer assets by definition (she is in Chapter 11), which limits the practical value of a monetary sanction unless it is structured with teeth upfront.

Almanzar’s counsel has identified the correct remedy but may be running into the court’s scheduling posture. A ten-minute, non-evidentiary hearing is not the calendar slot a court uses when it believes a full contempt finding is warranted. It suggests Judge Grossman may be approaching this as a threshold issue — whether the motion even establishes a prima facie case for sanctions — before committing to full evidentiary proceedings. Entertainment attorneys advising clients in similar disputes need to understand that the court’s first protective reflex in a Chapter 11 context is to preserve the plan, not to punish violations of it.

The per-violation penalty ask is the most consequential part of this motion, and it deserves careful attention. Almanzar’s team is asking the court to attach a financial penalty at the moment of publication rather than at the conclusion of a contempt proceeding. That structure — an automatic, pre-liquidated penalty triggered by a defined act — is the only enforcement mechanism that actually changes the economic incentive for a content creator whose revenue model depends on posting frequency. The existing arrangement, as the motion describes it, creates no real deterrence: post, generate views and revenue, delete when caught, repeat. If Judge Grossman grants a per-violation penalty structure, it transforms the non-disparagement clause from a reactive enforcement tool into a prospective one.

The Legal or Financial Mechanics

The enforcement difficulty here has its roots in how bankruptcy law restructures prepetition obligations. When a non-disparagement clause is incorporated into a confirmed Chapter 11 plan, it becomes an obligation of the reorganized debtor under the terms of the plan. Violations of plan provisions can be addressed through a motion for contempt under 11 U.S.C. § 105(a), which grants bankruptcy courts broad equitable power to carry out the plan. That is the vehicle Almanzar is using.

The problem is that § 105(a) contempt requires the moving party to establish that the alleged violator had actual knowledge of the specific provision she was bound to follow, that the acts were clearly prohibited by the plan’s terms, and that the acts were not ambiguous interpretations of those terms. Kebe’s defense will likely argue that her social media posts about Offset — a public figure involved in a newsworthy shooting incident — were public commentary protected by the First Amendment, not targeted harassment within the scope of the plan’s non-disparagement clause. Whether “coded” language that her audience can identify as referring to Almanzar but which does not name her falls within or outside the clause’s scope is precisely the kind of ambiguity courts are reluctant to resolve through contempt rather than clarifying the plan terms.

Almanzar’s 30.1 percent recovery means Kebe’s plan pays back roughly $1.17 million of the full judgment in structured payments, leaving approximately $2.73 million effectively uncollected unless the plan fails. The economic pressure on Almanzar to enforce the non-disparagement clause is therefore significant: if Kebe’s bankruptcy plan is dismissed for cause — which a contempt finding could support — Almanzar regains the right to pursue collection on the full $3.9 million judgment. That is the leverage the sanctions motion is designed to invoke without explicitly asking for plan dismissal yet.

Entertainment attorneys who have placed non-disparagement clauses inside bankruptcy plans as a condition of settlement need to revisit those instruments immediately. If the clause does not include: (1) a definition of “coded” or indirect disparagement, (2) a pre-liquidated damages figure per violation to be approved by the court at confirmation, and (3) an automatic cure period after which the full judgment accelerates, the clause is structurally unenforceable in practice even if it is technically part of a confirmed plan.

What Independent Operators Need to Know

Audit every non-disparagement clause in every settlement you have finalized in the last three years. If any of those settlements was reached with a counterparty who has since filed for bankruptcy, or who could plausibly file, the non-disparagement clause has likely lost its primary enforcement mechanism. The damages are restructured, the automatic acceleration is gone, and you are left with bankruptcy court contempt proceedings as your only remedy.

If you are drafting a settlement that includes a non-disparagement clause, and the counterparty is in financial distress, should you be putting the clause inside a bankruptcy plan? Structuring the non-disparagement obligation as a separate contract with its own breach and acceleration provisions, and obtaining a security interest or consent judgment that survives the bankruptcy independently of the plan seems like the better option.

For managers and label operators who regularly deal with bloggers, social media personalities, and content creators in defamation or harassment contexts: the Kebe-Almanzar case is teaching you that a million-dollar judgment plus a court-confirmed settlement is not sufficient deterrence for a content creator whose business model runs on the controversy you represent. Build in per-violation penalties from the first agreement. If the other side won’t accept them, that tells you what their compliance intentions are before you sign.

Bottom Line

Entertainment Attorneys: A non-disparagement clause in a confirmed bankruptcy plan without a pre-liquidated per-violation penalty is functionally aspirational. If you cannot attach automatic monetary consequences at the moment of violation — not after a contempt hearing — you have given your client a document, not a deterrent. Review existing instruments and redraft before the next dispute arises. The Kebe case is the model of what happens when the clause has no teeth.

Music Managers: If you have settled a dispute with a media personality, blogger, or ex-associate who is now in financial distress, find out whether they have filed or are likely to file for bankruptcy protection. Your non-disparagement agreement may have just become a 30-cents-on-the-dollar instrument without any meaningful enforcement mechanism. Your attorney needs to assess that exposure today, not when the first violation hits.

Independent Label Operators: The 25-violation pattern documented in this motion — post, generate revenue, delete, repeat — is a business model. Content creators who traffic in artist controversy operate on the assumption that enforcement is slow and expensive. They are correct unless you structure your agreements to impose costs at the moment of publication. The motion’s request for per-violation automatic penalties is the only legal architecture that actually changes that calculus, and you should be demanding it in every future non-disparagement agreement regardless of whether bankruptcy is on the horizon.