Third Monthly Fee Statement of Weil, Gotshal & Manges LLP — In re KServicing (Bankr. D. Del.)

Record facts

U.S. Bankruptcy Court for the District of Delaware · No. 22-10951 · Doc. 510 · 2023-02-01 · Docket on CourtListener

Full text

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 
Obj. Deadline: February 21, 2023 at 4:00 p.m. 
(ET) 
SUMMARY OF THIRD MONTHLY FEE STATEMENT OF WEIL, GOTSHAL & 
MANGES LLP FOR PAYMENT OF COMPENSATION AND REIMBURSEMENT OF  
EXPENSES FOR PERIOD DECEMBER 1, 2022 THROUGH DECEMBER 31, 2022 
 
Name of Applicant: 
Authorized to Provide Professional Services to: 
Date of Retention: 
Period for which compensation and 
reimbursement are sought: 
Amount of compensation sought as actual, 
reasonable, and necessary: 
Amount of expense reimbursement sought as 
actual, reasonable, and necessary: 
 
Weil, Gotshal & Manges LLP 
Debtors and Debtors in Possession 
 
October 21, 2022 effective as of October 3, 2022 
December 1, 2022 through December 31, 2022 
 
 
$1,269,040.40 (80% of $1,586,300.50) 
$6,583.58 
This is a(n):  X   monthly ___ interim ___ final application
                                                 
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. 
WEIL 98992131V.5 
Case 22-10951-CTG    Doc 510    Filed 02/01/23    Page 1 of 15

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COMPENSATION BY PROFESSIONAL 
DECEMBER 1, 2022 THROUGH DECEMBER 31, 2022 
 
The attorneys who rendered professional services in these chapter 11 cases from December 1, 2022 
through December 31, 2022 (the “Fee Period”) are: 
NAME OF 
PROFESSIONAL 
POSITION 
DEPARTMENT 
YEAR 
ADMITTED1 
HOURLY 
BILLING 
RATE 
TOTAL 
BILLED 
HOURS  
TOTAL 
COMPENSATION 
Goldring, Stuart J. 
Partner 
Tax 
1984 
$1,950.00 
9.90 
$19,305.00 
Slack, Richard W. 
Partner 
Litigation 
1987 
$1,495.00 
36.50 
$54,567.50 
Tsekerides, Theodore 
E. 
Partner 
Litigation 
1994 
$1,395.00 
79.20 
$110,484.00 
Schrock, Ray C. 
Partner 
Restructuring 
1998 
$1,950.00 
4.30 
$8,385.00 
Westerman, Gavin 
Partner 
Corporate 
2004 
$1,525.00 
2.10 
$3,202.50 
Arthur, Candace 
Partner 
Restructuring 
2010 
$1,495.00 
64.20 
$95,979.00 
Hwangpo, Natasha 
Partner 
Restructuring 
2014 
$1,395.00 
195.90 
$273,280.50 
Margolis, Steven M. 
Counsel 
Tax 
1990 
$1,300.00 
4.40 
$5,720.00 
Bonk, Cameron Mae 
Counsel 
Litigation 
2016 
$1,250.00 
191.60 
$239,500.00 
Friedman, Julie T. 
Associate 
Restructuring 
2003 
$695.00 
17.20 
$11,954.00 
Hill, David F. 
Associate 
Litigation 
2017 
$1,200.00 
4.60 
$5,520.00 
Ruocco, Elizabeth A. 
Associate 
Restructuring 
2017 
$1,165.00 
116.30 
$135,489.50 
Bentley, Chase A. 
Associate 
Restructuring 
2018 
$1,200.00 
118.80 
$142,560.00 
Diplas, Alexandros 
Associate 
Litigation 
2018 
$1,165.00 
28.70 
$33,435.50 
Ritholtz, Benjamin 
Associate 
Litigation 
2019 
$1,130.00 
9.80 
$11,074.00 
Parker-Thompson, 
Destiney 
Associate 
Restructuring 
2020 
$840.00 
70.10 
$58,884.00 
McMillan, Jillian A. 
Associate 
Restructuring 
2021 
$1,075.00 
116.90 
$125,667.50 
Ham, Hyunjae 
Associate 
Restructuring 
2021 
$980.00 
22.00 
$21,560.00 
Ollestad, Jordan 
Alexandra 
Associate 
Litigation 
2022 
$980.00 
70.80 
$69,384.00 
Blankman, Alexandra 
Associate 
Litigation 
2022 
$840.00 
7.80 
$6,552.00 
Cazes, Catherine 
Associate 
Litigation 
2022 
$840.00 
50.60 
$42,504.00 
Suarez, Ashley 
Associate 
Restructuring 
2022 
$840.00 
40.30 
$33,852.00 
Castillo, Lauren 
Associate 
Restructuring 
* 
$690.00 
90.70 
$62,583.00 
Total for Attorneys 
 
 
 
 
1,352.70 
$1,571,443.00 
 
                                                 
1 * – Not Yet Admitted to Practice 
Case 22-10951-CTG    Doc 510    Filed 02/01/23    Page 2 of 15

 
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The paraprofessionals and other non-legal staff who rendered professional services during the Fee Period 
are: 
NAME OF 
PARAPROFESSIONAL AND 
OTHER NON-LEGAL 
STAFF 
POSITION 
DEPARTMENT 
HOURLY 
BILLING 
RATE 
TOTAL 
BILLED 
HOURS  
TOTAL 
COMPENSATION 
Haiken, Lauren C. 
Litigation Support 
LSS 
$435.00 
4.50 
$1,957.50 
Jewett, Laura 
Litigation Support 
LSS 
$415.00 
4.00 
$1,660.00 
Dang, Thai 
Litigation Support 
LSS 
$400.00 
3.30 
$1,320.00 
Nudelman, Peter 
Litigation Support 
LSS 
$400.00 
20.60 
$8,240.00 
Peene, Travis J. 
Paralegal 
Restructuring 
$290.00 
2.00 
$580.00 
Mason, Kyle 
Paralegal 
Restructuring 
$275.00 
4.00 
$1,100.00 
Total: 
 
 
 
38.40 
$14,857.50 
The total fees for the Fee Period are: 
PROFESSIONALS 
BLENDED RATE 
TOTAL 
BILLED 
HOURS  
TOTAL COMPENSATION 
Partners and Counsel 
$1,378.04 
588.10 
$810,423.50 
Associates 
$995.32 
764.60 
$761,019.50 
Paraprofessionals and Other Non-Legal Staff 
$386.91 
38.40 
$14,857.50 
Blended Attorney Rate 
$1,161.71 
 
 
Total: 
 
1,391.10 
$1,586,300.50 
 
 
Case 22-10951-CTG    Doc 510    Filed 02/01/23    Page 3 of 15

 
 
4 
COMPENSATION BY PROJECT CATEGORY 
DECEMBER 1, 2022 THROUGH DECEMBER 31, 2022 
 
 
 
TASK 
CODE 
 
 
PROJECT CATEGORY 
 
TOTAL BILLED 
HOURS 
 
TOTAL 
COMPENSATION 
001 
Administrative Expense Claims 
15.60 
$12,413.00 
003 
AmEx Transaction Investigation 
64.90 
$53,858.00 
006 
Bar Date and Claims Matters 
65.30 
$61,798.00 
007 
Borrower Matters 
0.30 
$418.50 
008 
Case Administration (WIP List & Case Calendar) 
11.60 
$11,507.00 
009 
Chapter 11 Plan/Plan Confirmation/Implementation 
118.00 
$148,246.00 
010 
Corporate Governance/Securities 
110.40 
$129,061.50 
011 
Customer (incl. Partner Banks)/Vendor/Supplier Matters 
13.80 
$17,344.00 
012 
Cash Management 
4.60 
$5,919.00 
013 
Disclosure Statement/Solicitation/Voting 
172.30 
$196,583.50 
014 
Employee Matters 
7.70 
$9,604.50 
015 
Exclusivity 
22.70 
$19,294.00 
016 
Executory Contracts/Leases/Real Prop/Other 365 Matters 
16.70 
$15,708.50 
017 
General Case Strategy (incl Team and Client Calls) 
98.50 
$112,460.00 
018 
Government Investigation Matters (excl. Settlements) 
3.50 
$4,372.00 
019 
Hearings and Court Matters 
0.60 
$726.00 
021 
Non-bankruptcy Litigation (incl. CUBI Dispute) 
536.70 
$640,999.00 
024 
Regulatory Matters 
1.90 
$2,650.50 
025 
Retention/Billing/Fee Applications: OCP 
9.10 
$9,233.00 
026 
Retention/Fee Applications: Non-Weil Professionals 
11.70 
$12,082.50 
027 
Retention/Fee Applications: Weil 
35.50 
$29,034.50 
028 
Secured Creditors Issues/Meetings/Comms (excl. Settlements) 
5.20 
$6,952.50 
029 
Settlements (including 9019 matters) 
29.90 
$38,705.00 
030 
Schedules/Statement of Financial Affairs 
1.30 
$987.00 
031 
Tax Matters 
12.30 
$19,182.00 
032 
Unsecured Creditors Issues/Meetings/Comms/UCC (excl. stlmnts) 
1.60 
$1,920.00 
033 
US Trustee/MORs/2015.3 Reports 
2.40 
$2,791.50 
035 
Servicing Transfer 
17.00 
$22,449.50 
TOTAL 
 
1,391.100 
$1,586,300.50 
Case 22-10951-CTG    Doc 510    Filed 02/01/23    Page 4 of 15

 
 
5 
 
 
EXPENSE SUMMARY 
DECEMBER 1, 2022 THROUGH DECEMBER 31, 2022 
 
EXPENSE CATEGORY 
 
AMOUNT 
Computerized Research 
$4,910.48 
Duplicating 
$637.30 
Meals 
$20.00 
Transportation 
$572.85 
Travel 
$442.95 
TOTAL 
$6,583.58 
 
 
 
Case 22-10951-CTG    Doc 510    Filed 02/01/23    Page 5 of 15

 
 
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 
Obj. Deadline: February 21, 2023 at 4:00 p.m. (ET) 
THIRD MONTHLY FEE STATEMENT OF 
WEIL, GOTSHAL & MANGES LLP FOR PAYMENT OF 
COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR 
PERIOD DECEMBER 1, 2022 THROUGH DECEMBER 31, 2022 
 
Weil, Gotshal & Manges LLP (“Weil” or the “Firm”), attorneys for 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”), hereby files its third monthly fee 
statement (this “Fee Statement”) for payment of compensation for professional services rendered 
to the Debtors and for reimbursement of actual and necessary expenses incurred in connection 
therewith for the period commencing December 1, 2022 through and including December 31, 2022 
(the “Fee Period”), pursuant to sections 105(a), 330, and 331 of title 11 of the United States Code 
(the “Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure 
(the “Bankruptcy Rules”), Rule 2016-2 of the Local Rules of Bankruptcy Practice and Procedure 
of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”), and the 
Court’s Order Establishing Procedures for Interim Compensation and Reimbursement of 
                                                 
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 510    Filed 02/01/23    Page 6 of 15

 
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Expenses of Professionals [Docket No. 136] (the “Interim Compensation Order”).  In support 
of this Fee Statement, Weil respectfully represents as follows: 
Background 
1. 
On October 3, 2022 (the “Petition Date”), the Debtors each commenced 
with this Court a voluntary case under chapter 11 of the Bankruptcy Code (the “Chapter 11 
Cases”).  The Debtors are authorized to continue to operate their business as debtors in possession 
pursuant to sections 1107(a) and 1108 of the Bankruptcy Code.  No trustee, examiner, or statutory 
committee of creditors has been appointed in these Chapter 11 Cases. 
2. 
Pursuant to Bankruptcy Rule 1015(b), the Chapter 11 Cases are being 
jointly administered under the above captioned case. 
3. 
Additional information regarding the Debtors’ business, capital structure, 
and the circumstances leading to the commencement of these Chapter 11 Cases is set forth in the 
Declaration of Deborah Rieger-Paganis in Support of Debtors’ Chapter 11 Petitions and First 
Day Relief [Docket No. 13].2 
4. 
This Court authorized Weil’s retention as attorneys for the Debtors pursuant 
to the Order Authorizing Retention and Employment of Weil, Gotshal & Manges LLP As Attorneys 
For Debtors Effective as of Petition Date [Docket No. 137] (the “Retention Order”), entered on 
October 21, 2022.    
Jurisdiction 
5. 
The Court has jurisdiction to consider this matter pursuant to 
28 U.S.C. §§ 157 and 1334, and the Amended Standing Order of Reference from the United States 
District Court for the District of Delaware, dated February 29, 2012.  This is a core proceeding 
                                                 
2  Capitalized terms used but not defined herein shall have the respective meanings ascribed to such terms in the Joint 
Chapter 11 Plan of Liquidation [Docket No. 14] (as may be amended, modified, or supplemented, the “Plan”). 
Case 22-10951-CTG    Doc 510    Filed 02/01/23    Page 7 of 15

 
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pursuant to 28 U.S.C. § 157(b).  Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 
and 1409.   
6. 
Pursuant to Local Rule 9013-1(f), the Debtors consent to the entry of a final 
order by the Court in connection with this Fee Statement to the extent that it is later determined 
that the Court, absent consent of the parties, cannot enter final orders or judgments consistent with 
Article III of the United States Constitution.   
Summary of Professional Compensation 
and Reimbursement of Expense Requested 
7. 
By this Fee Statement, Weil requests allowance and payment of 
$1,269,040.40 (80% of $1,586,300.50) as compensation for professional services rendered to the 
Debtors during the Fee Period and allowance and payment of $6,583.58 as reimbursement for 
actual and necessary expenses incurred by Weil during the Fee Period.  All services for which 
compensation is requested by Weil were performed for or on behalf of the Debtors. 
8. 
During the Fee Period, Weil received no payment and no promises of 
payment from any source for services rendered or to be rendered in any capacity whatsoever in 
connection with the matters covered by this Fee Statement.  There is no agreement or 
understanding between Weil and any other person, other than members of Weil, for the sharing of 
compensation to be received for services rendered in these Chapter 11 Cases. 
9. 
The fees charged by Weil in these Chapter 11 Cases are billed in accordance 
with its existing billing rates and procedures in effect during the Fee Period, and in accordance 
with the Retention Order. 
10. 
Weil maintains computerized records of the time spent by all Weil 
attorneys, paraprofessionals, and other non-legal staff in connection with the Firm’s representation 
of the Debtors.  Annexed hereto as Exhibit A are copies of Weil’s itemized time records for 
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professionals, paraprofessionals, and other non-legal staff performing services for the Debtors 
during the Fee Period.  Weil’s time records comply with the requirements set forth in Local 
Rule 2016-2 and the Guidelines for Reviewing Applications for Compensation and Reimbursement 
of Expenses Filed Under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases 
(the “Guidelines”), including the use of itemized time entries and separate matter numbers for 
different project types, as hereinafter described in greater detail. 
Summary of Services 
11. 
The following is a summary of the significant professional services 
rendered by Weil during the Fee Period.  This summary is organized in accordance with the 
internal system of task codes set up by Weil at the outset of these Chapter 11 Cases.3  If a task code 
does not appear below, then Weil did not bill significant time for that task code during the Fee 
Period, but may bill time for that task code in the future.  Certain services performed may overlap 
between, or appropriately be allocated to, more than one task code. 
a. 
AmEx Transaction Investigation (Task Code 003)  
 
 
Fees:  $53,858.00; Total Hours:  64.90 
 Reviewed and analyzed documents and correspondence related 
to the sale of substantially all of the Debtors’ assets to American 
Express (“AmEx”) in October 2020 (the “AmEx Transaction”); 
 Analyzed potential claims and causes of action against certain 
parties to the AmEx Transaction; 
 Drafted and reviewed AmEx Transaction investigation report; 
 Researched legal issues in connection with the AmEx 
Transaction investigation report; 
 Reviewed AmEx production materials; and 
                                                 
3  Exhibit A annexed hereto provides a more detailed description of the services provided during the Fee Period, and 
reference should be made thereto for a complete recitation of such services. 
Case 22-10951-CTG    Doc 510    Filed 02/01/23    Page 9 of 15

 
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 Conferred with Weil team, various counsel, and client regarding 
the investigation. 
b. 
Bar Date and Claims Matters (Task Code 006)  
 
 
Fees:  $61,798.00; Total Hours:  65.30 
 Reviewed and summarized proofs of claim; 
 Drafted, reviewed, and revised claims objection summary chart; 
 Researched issues related to debtors’ right to setoff claims; and 
 Corresponded with Debtors and Debtors’ advisors regarding the 
above. 
c. 
Chapter 11 Plan/Plan Confirmation/Implementation (Task Code 009)  
 
 
Fees:  $148,246.00; Total Hours:  118.00 
 Responded to Plan-related questions and comments from the 
client, the Debtors’ advisors, the U.S. Trustee, the Reserve Bank, 
and other stakeholders; 
 Analyzed third party servicer regulatory requirements; 
 Participated on calls with Debtors’ advisors, the U.S. Trustee, 
and counsel to various creditors regarding the Plan; and 
 Drafted, reviewed, revised, and finalized the Amended Joint 
Chapter 11 Plan of Liquidation of Kabbage, Inc. (d/b/a 
KServicing) and Its Affiliated Debtors [Docket No. 395]. 
d. 
Corporate Governance / Securities (Task Code 010)  
 
 
Fees:  $129,061.50; Total Hours:  110.40 
 Prepared board materials and presentations for Board meetings 
regarding the chapter 11 cases;  
 Attended the Debtors’ Board meetings regarding the chapter 11 cases 
and prepared minutes thereof; and 
 Coordinated with Board counsel to among other things, to avoid 
duplication of services. 
e. 
Disclosure Statement / Solicitation / Voting (Task Code 013)  
 
 
Fees:  $196,583.50; Total Hours:  172.30 
 Reviewed and revised liquidation analysis and discussed with 
Debtors’ advisors; 
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 Reviewed and responded to the client, the Debtors’ advisors, the 
U.S. Trustee, the Reserve Bank, the Department of Justice, and 
other stakeholders’ comments to amended Disclosure Statement; 
 Drafted, reviewed, revised, and finalized the Amended 
Disclosure Statement for the Amended Joint Chapter 11 Plan of 
Liquidation of Kabbage, Inc. (d/b/a KServicing) and Its Affiliated 
Debtors [Docket No. 396]; 
 Reviewed and revised draft motion to approve Plan solicitation, 
voting, and related procedures in accordance with the U.S. 
Trustee’s comments; and 
 Drafted, reviewed, and revised balloting and solicitation 
procedures and discussed with claims agent. 
f. 
General Case Strategy (incl. Team and Client Calls) (Task Code 017)  
 
 
Fees:  $112,460.00; Total Hours:  98.50 
 Communicated with the Debtors, members of the various Weil 
teams, and other advisors regarding case strategy, pending and 
upcoming matters, filings, key dates, and deadlines; and 
 Participated on regular update calls with the Debtors and their 
other advisors regarding chapter 11 cases process, strategy, 
priority workstreams, and timeline. 
g. 
Non-Bankruptcy Litigation (incl. CUBI Dispute) (Task Code 021)  
 
 
Fees:  $640,999.00; Total Hours:  536.70 
 Drafted, reviewed, revised, and finalized Debtors’ Motion for an 
Order Authorizing the Debtors to File Under Seal Certain 
Exhibits to the Declarations in Support of Motion to Enforce 
[Docket No. 351] (the “Motion to Enforce”) and objections 
thereto; 
 Corresponded with CUBI regarding the CUBI Dispute; 
 Corresponded with Debtors’ advisors and participated in Weil 
internal meetings regarding the CUBI Dispute; 
 Prepared, researched, and reviewed materials for the CUBI 
Dispute; 
 Researched priority and adequate protection issues; 
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 Reviewed class action complaint and letter from class action 
claimants, and corresponded with opposing counsel; and 
 Corresponded with Debtors’ advisors regarding various pending 
litigations. 
h. 
Retention / Fee Applications:  Weil (Task Code 027)  
 
 
Fees:  $29,034.50; Total Hours:  35.50 
 Reviewed monthly invoices for compliance with U.S. Trustee 
guidelines; and 
 Drafted, reviewed, revised, and finalized Second Monthly Fee 
Statement of Weil, Gotshal & Manges LLP for Payment of 
Compensation and Reimbursement of Expenses for Period 
November 1, 2022 Through November 30, 2022 [Docket No. 
389]. 
12. 
The foregoing professional services performed by Weil were necessary and 
appropriate to the administration of these Chapter 11 Cases and were in the best interests of the 
Debtors’ estates and their stakeholders.  Compensation for the foregoing services as requested is 
commensurate with the complexity, importance, and nature of the problems, issues, and tasks 
involved.  The professional services were performed skillfully and efficiently. 
Actual and Necessary Disbursements 
13. 
Weil requests allowance of actual and necessary expenses incurred during 
the Fee Period in the aggregate amount of $6,583.58.  Annexed hereto as Exhibit B is a list of 
Weil’s itemized actual and necessary expenses.  Weil’s disbursement policies pass through all out-
of-pocket expenses at actual cost or an estimated actual cost when the actual cost is difficult to 
determine.  For example, with respect to duplication charges, Weil charges $0.10 per black and 
white page and $0.50 per color page because the actual cost is difficult to determine.  Similarly, as 
it relates to computerized research, Weil believes that it does not make a profit on that service as 
a whole, although the cost of any particular search is difficult to ascertain.  Other reimbursable 
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expenses (whether the service is performed by Weil in-house or through a third-party vendor) 
include, but are not limited to, overtime meals, deliveries, travel, and local transportation. 
Reservation of Rights 
14. 
To the extent time or disbursement charges for services rendered or 
disbursements incurred relate to the Fee Period but were not processed prior to the preparation of 
this Fee Statement, or Weil has for any other reason not sought compensation or reimbursement 
of expenses herein with respect to any services rendered or expenses incurred during the Fee 
Period, Weil reserves the right to request additional compensation for such services and 
reimbursement of such expenses in a future fee statement. 
Notice 
15. 
Notice of this Fee Statement will be provided in accordance with the Interim 
Compensation Order on the Fee Notice Parties (as defined in the Interim Compensation Order).  
No further notice is required.  
Case 22-10951-CTG    Doc 510    Filed 02/01/23    Page 13 of 15

 
 
 
 
WHEREFORE Weil respectfully requests (a)  interim allowance of compensation 
for professional services rendered to the Debtors during the Fee Period in the amount of 
$1,586,300.50 for actual and necessary costs, and for expenses incurred by Weil during the Fee 
Period in the amount of $6,583.58; (b)  that, in accordance with the Interim Compensation Order, 
the Debtors pay Weil a total of $1,275,623.98 consisting of $1,269,040.40 (representing 80% of 
the total amount of fees allowed) and $6,583.58 (representing 100% of the expenses allowed), if 
no objections are timely filed and Weil files a certificate of no objection with the Court in 
accordance with the Interim Compensation Order; (c)  that the interim allowance of such 
compensation for professional services rendered and reimbursement of actual and necessary 
expenses incurred be without prejudice to Weil’s right to seek such further compensation for the 
full value of services performed and expenses incurred; and (d)  that the Court grant Weil such 
other and further relief as is just. 
Dated:  February 1, 2023 
 
New York, New York 
 
/s/  Candace M. Arthur 
WEIL, GOTSHAL & MANGES LLP 
Ray C. Schrock, P.C. (admitted pro hac vice) 
Candace M. Arthur (admitted pro hac vice) 
Natasha S. Hwangpo (admitted pro hac vice) 
Chase A. Bentley (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 510    Filed 02/01/23    Page 14 of 15

 
 
 
 
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 
 
 
DECLARATION OF CANDACE M. ARTHUR 
 
I, Candace M. Arthur, hereby declare the following under penalty of perjury: 
1. 
I am a member with the applicant firm, Weil, Gotshal & Manges LLP 
(“Weil” or the “Firm”), and have been admitted to appear before this Court, by order dated 
October 4, 2022 [Docket No. 29]. 
2. 
I have personally performed many of the legal services rendered by Weil as 
counsel to the Debtors and am thoroughly familiar with the other work performed on behalf of the 
Debtors by the lawyers, paraprofessionals, and other non-legal staff in the Firm. 
3. 
I have reviewed the foregoing Fee Statement, and the facts set forth therein 
are true and correct to the best of my knowledge, information and belief.  Moreover, I have 
reviewed Local Rule 2016-2 and submit that the Fee Statement complies with such rule. 
Dated: February 1, 2023 
New York, New York 
 
/s/  Candace M. Arthur 
Candace M. Arthur 
 
                                                 
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 510    Filed 02/01/23    Page 15 of 15

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