Notice of blacklines — amended chapter 11 plan and disclosure statement — In re KServicing

Record facts

U.S. Bankruptcy Court for the District of Delaware · No. 22-10951 · Doc. 397 · 2022-12-30 · Docket on CourtListener

Summary

A notice of blacklines of the amended joint chapter 11 plan of liquidation and the amended disclosure statement in In re Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), filed December 30, 2022 as Doc 397 in the United States Bankruptcy Court for the District of Delaware. The notice states that the debtors filed the plan on October 4, 2022 and the disclosure statement on October 5, 2022, and that on December 30, 2022 they filed revised versions of both. It states that blackline comparisons of the revised documents against the earlier versions are attached as Exhibit 1 and Exhibit 2. The notice adds that the debtors reserve the right to amend, modify or supplement the revised documents and will file further revised copies if they do, and that the revised documents are subject to ongoing negotiations between the debtors and their stakeholders.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

RLF1 28271248v.1 
UNITED STATES BANKRUPTCY COURT 
DISTRICT OF DELAWARE 
------------------------------------------------------------ x 
 
 
: 
Chapter 11 
In re 
: 
 
 
: 
Case No. 22-10951 (CTG) 
KABBAGE, INC. d/b/a KSERVICING, et al., : 
 
 
: 
(Jointly Administered)  
 
 
Debtors.1 
: 
 
 
: 
 
 
: 
Re: Docket Nos. 14, 63, 395 & 396 
------------------------------------------------------------ x 
 
NOTICE OF BLACKLINES OF (I) AMENDED JOINT CHAPTER 11 PLAN 
OF LIQUIDATION KABBAGE, INC. (d/b/a KSERVICING) AND ITS  
AFFILIATED DEBTORS AND (II) AMENDED DISCLOSURE STATEMENT  
FOR THE AMENDED JOINT CHAPTER 11 PLAN OF LIQUIDATION  
KABBAGE, INC. (d/b/a KSERVICING) AND ITS AFFILIATED DEBTORS 
 
PLEASE TAKE NOTICE THAT on October 4, 2022, Kabbage, Inc. d/b/a 
KServicing and its debtor affiliates, as debtors and debtors in possession in the above-captioned 
chapter 11 cases (collectively, the “Debtors”), filed the Joint Chapter 11 Plan of Liquidation 
Kabbage, Inc. (d/b/a KServicing) and its Affiliated Debtors [Docket No. 14] (the “Plan”) with the 
United States Bankruptcy Court for the District of Delaware (the “Court”). 
PLEASE TAKE FURTHER NOTICE THAT on October 5, 2022, the Debtors filed 
the Disclosure Statement for the Joint Chapter 11 Plan of Liquidation Kabbage, Inc. (d/b/a 
KServicing) and its Affiliated Debtors [Docket No. 63] (the “Disclosure Statement”) with the 
Court. 
 
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. 
Case 22-10951-CTG    Doc 397    Filed 12/30/22    Page 1 of 3

 
2 
 
RLF1 28271248v.1 
PLEASE TAKE FURTHER NOTICE THAT on December 30, 2022, the Debtors 
filed a revised version of the Plan [Docket No. 395] (the “Revised Plan”) and a revised version of 
the Disclosure Statement [Docket No. 396] (the “Revised Disclosure Statement”). 
PLEASE TAKE FURTHER NOTICE THAT for the convenience of the Court and 
all parties in interest, a blackline comparison of the Revised Plan marked against the Plan is 
attached hereto as Exhibit 1, and a blackline comparison of the Revised Disclosure Statement 
marked against the Disclosure Statement is attached hereto as Exhibit 2. 
PLEASE TAKE FURTHER NOTICE THAT the Debtors reserve the right to 
amend, modify, or supplement the Revised Plan and the Revised Disclosure Statement.  To the 
extent that the Debtors make further revisions to the Revised Plan or the Revised Disclosure 
Statement, the Debtors will file further revised copies of such documents with the Court.   
PLEASE TAKE FURTHER NOTICE THAT the Revised Plan and Revised 
Disclosure Statement are subject to ongoing negotiations between the Debtors and their 
stakeholders. 
 
[Remainder of page intentionally left blank] 
Case 22-10951-CTG    Doc 397    Filed 12/30/22    Page 2 of 3

 
3 
 
RLF1 28271248v.1 
Dated: December 30, 2022 
Wilmington, Delaware 
 
/s/ Matthew P. Milana 
RICHARDS, LAYTON & FINGER, P.A. 
Daniel J. DeFranceschi, Esq. (No. 2732) 
Amanda R. Steele, Esq. (No. 5530) 
Zachary I. Shapiro, Esq. (No. 5103) 
Matthew P. Milana, Esq. (No. 6681) 
One Rodney Square 
920 North King Street 
Wilmington, Delaware 19801 
Telephone: (302) 651-7700 
E-mail: defranceschi@rlf.com 
       steele@rlf.com 
       shapiro@rlf.com 
       milana@rlf.com 
 
-and- 
 
WEIL, GOTSHAL & MANGES LLP 
Ray C. Schrock, P.C. (admitted pro hac vice) 
Candace M. Arthur, Esq. (admitted pro hac vice) 
Natasha S. Hwangpo, Esq. (admitted pro hac vice) 
Chase A. Bentley, Esq. (admitted pro hac vice) 
767 Fifth Avenue 
New York, New York 10153 
Telephone:  
(212) 310-8000 
E-mail:  
ray.schrock@weil.com 
 
 
candace.arthur@weil.com 
 
 
natasha.hwangpo@weil.com 
 
 
chase.bentley@weil.com 
 
Attorneys for Debtors and Debtors in Possession 
Case 22-10951-CTG    Doc 397    Filed 12/30/22    Page 3 of 3

File and source

File

gov.uscourts.deb.188293.397.0.pdf

Size

175,434 bytes

SHA-256

88a612ec20b2411f74d97b3e985e2edb6144fbfa43f7c72452f2973d76553fc4

Our copy

gov.uscourts.deb.188293.397.0.pdf

Original

archive.org