Supplemental Declaration of Deborah Rieger-Paganis (AlixPartners) — In re KServicing (Bankr. D. Del.)

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U.S. Bankruptcy Court for the District of Delaware · No. 22-10951 · Doc. 124 · 2022-10-20 · Docket on CourtListener

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UNITED STATES BANKRUPTCY COURT 
DISTRICT OF DELAWARE 
------------------------------------------------------------ x 
 
In re 
: 
Chapter 11 
 
: 
 
KABBAGE, INC. d/b/a KSERVICING, et al., : 
Case No. 22-10951 (CTG) 
 
: 
 
 
: 
 
 
 
Debtors.1 
: 
(Jointly Administered)  
------------------------------------------------------------ x 
Re: Docket No. 16 
 
SUPPLEMENTAL DECLARATION OF  
DEBORAH RIEGER-PAGANIS OF ALIXPARTNERS, LLP  
 
Pursuant to 28 U.S.C. § 1746, I, Deborah Rieger-Paganis, state under penalty of perjury, 
that: 
1. 
I am a Managing Director of AlixPartners, LLP (“AlixPartners”), which 
has a place of business at 909 Third Avenue, Floor 30, New York, New York 10022.   
2. 
Except as otherwise noted, I have personal knowledge of the matters set 
forth herein and, if called as a witness, would testify competently thereto. 
3. 
I submit this supplemental declaration in the cases of the above-captioned 
debtors (collectively, the “Debtors”) to supplement the disclosures set forth in my original 
declaration dated October 4, 2022 [Docket No. 16] (the “Original Declaration”).   
4. 
Unless otherwise noted, references to AP2 below collectively refer to 
AlixPartners, AlixPartners Holdings, LLP, the parent company of AlixPartners, and each of their 
respective subsidiaries.  AlixPartners hereby discloses the following: 
 
1  
The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification 
number, as applicable are: Kabbage, Inc. d/b/a KServicing (3937); Kabbage Canada Holdings, LLC (N/A); 
Kabbage Asset Securitization LLC (N/A); Kabbage Asset Funding 2017-A LLC (4803); Kabbage Asset Funding 
2019-A LLC (8973); and Kabbage Diameter, LLC (N/A).  Kabbage is a trademark of American Express used 
under license; Kabbage, Inc. d/b/a KServicing is not affiliated with American Express. The Debtors’ mailing and 
service address is 925B Peachtree Street NE, Suite 383, Atlanta, GA 30309.  
2  
Capitalized terms used herein shall have meanings ascribed to them in the Original Declaration. 
Case 22-10951-CTG    Doc 124    Filed 10/20/22    Page 1 of 2

 
 
2 
 
 The Original Declaration states: “UnitedHealthcare, UnitedHealthcare Dental 
and UnitedHealthcare of California, and affiliates (“United”) are benefits 
providers to the Debtors.  An AP board member is on the Board of Trustees of 
United.”  Further investigation has revealed that the aforementioned AP board 
member is a member of the Board of Directors of UnitedHealth Group, Inc.. 
 As set forth in the Original Declaration, AP follows a practice to solicit from its 
Institutional Investors their connections to the Investor Search Parties.  In 
response, the Institutional Investors have disclosed the following regarding 
their respective connections to the Investor Search Parties: 
o Investcorp — no investment in the Investor Search Parties. 
o CDPQ — debt investment in Credit Suisse Group AG, Macquarie 
Group Ltd., and US Bancorp, in each case representing less than one 
percent (1%) of total assets under management; no investment in any 
other Investor Search Parties. 
o PSP — investment in Credit Suisse, Macquarie Group, and SoftBank, 
in each case representing less than one percent (1%) of total assets under 
management; no investment in any other Investor Search Parties. 
5. 
AlixPartners does not believe that the supplemental disclosures above 
impact its disinterestedness.  AlixPartners continues to reserve the right to supplement its 
disclosures in the event that AlixPartners learns of any additional connections that require 
disclosure.  If any new, material, relevant facts or relationships are discovered or arise, 
AlixPartners will promptly file a supplemental declaration pursuant to Bankruptcy Rule 2014(a). 
I declare under penalty of perjury pursuant to 28 U.S.C. §1746 that the foregoing is true 
and correct. 
 
Dated: October 20, 2022                                       AlixPartners, LLP 
            New York, NY 
 
 /s/ Deborah Rieger-Paganis 
 
Deborah Rieger-Paganis 
Managing Director 
 
Case 22-10951-CTG    Doc 124    Filed 10/20/22    Page 2 of 2

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