Court filing

Greenberg Traurig First Interim Fee Application — In re KServicing

Record facts

Court	U.S. Bankruptcy Court for the District of Delaware
Filed	2023-02-14

U.S. Bankruptcy Court for the District of Delaware · No. 22-10951 · Doc. 533 · 2023-02-14 · Docket on CourtListener

Summary

The first interim fee application of Greenberg Traurig, LLP, special counsel to the Board of Directors of Kabbage, Inc. d/b/a KServicing, filed February 14, 2023 as Doc 533 in the jointly administered chapter 11 cases of Kabbage, Inc. d/b/a KServicing, Case No. 22-10951 (CTG), in the U.S. Bankruptcy Court for the District of Delaware. It seeks allowance of $223,096.50 in compensation and $411.25 in expenses, an aggregate of $223,507.75, for the period October 3, 2022 through December 31, 2022 under 11 U.S.C. §§ 330 and 331. The application reports 228.3 hours billed by 7 professionals and a blended attorney rate of $1,230.03. Fees by category are $104,857.50 for board and corporate governance, $57,153.00 for court hearings, $43,670.00 for employment and fee applications and $17,416.00 for case administration. The 17-page filing lists an objection deadline of March 6, 2023.

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

IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE

------------------------------------------------------------ x

In re
:
Chapter 11
:

KABBAGE, INC. d/b/a KSERVICING, et al., :
Case No. 22-10951 (CTG)
:

:
(Jointly Administered)
Debtors.1
:
:

:
Obj. Deadline: March 6, 2023 at 4:00 p.m. (ET)
------------------------------------------------------------ x
Hearing: March 22, 2023 at 10:00 a.m. (ET)

SUMMARY OF FIRST INTERIM FEE APPLICATION OF GREENBERG
TRAURIG, LLP, SPECIAL COUNSEL TO THE BOARD OF DIRECTORS OF
KABBAGE, INC. D/B/A KSERVICING FOR ALLOWANCE OF COMPENSATION
FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES
FOR THE PERIOD FROM OCTOBER 3, 2022 THROUGH DECEMBER 31, 2022

Name of Applicant:
Greenberg Traurig, LLP
Authorized to Provide Professional Services to:
Special Counsel to the Board of Directors of
Kabbage, Inc. d/b/a KServicing
Date of Retention:
November 2, 2022
(nunc pro tunc to October 3, 2022)
Period for Which Compensation and
Reimbursement sought
October 3, 2022 through December 31, 2022
(First Interim Period)
Total compensation sought this period
$223,096.50
Total expense reimbursement sought this period:
$411.25
Total compensation allowed by interim order to
date:
N/A
Total expenses allowed by interim order to date:
N/A
Total allowed compensation paid to date:
$98,616.40
Total allowed expenses paid to date:
$411.25
Blended rate in this application for all attorneys:
$1,230.03

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 533 Filed 02/14/23 Page 1 of 17

Blended rate in this application for all
timekeepers:
$977.21
Compensation sought in this application already
paid pursuant to a monthly compensation order
but not yet allowed:
$98,616.40
Expenses sought in this application already paid
pursuant to a monthly compensation order but not
yet allowed:
$411.25
Number of professionals included in this
application:
7
If applicable, number of professionals in this
application not included in staffing plan approved
by client:
N/A
If applicable, difference between fees budgeted
and compensation sought for this period:
$65,118.50 less than budgeted
Number of professionals billing fewer than 15
hours to the case during this period:
4
Are any rates higher than those approved and
disclosed at retention? If yes, calculate and
disclose the total compensation sought in this
application using the rates originally disclosed in
the retention application.
No
This is a(n): Monthly

X Interim

Final Application
This Application does not include any hours incurred in connection with preparation of this
Application.

Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 2 of 17

SUMMARY OF MONTHLY FEE APPLICATIONS
FOR THE FIRST INTERIM PERIOD

APPLICATION
FEES
REQUESTED
EXPENSES
REQUESTED
FEES
APPROVED
EXPENSES
APPROVED
TOTAL
OWED
First Monthly
10/3/22–10/31/22
D.I. 326, Filed
12/2/22

CNO: D.I. 377,
Filed 12/27/22
$84,604.00
$411.25
$67,683.20
$411.25
$16,920.80
Second Monthly
11/1/22–11/30/22
D.I. 392, Filed
12/29/22

CNO: D.I. 476,
Filed 1/20/23
$38,666.50
$0.00
$30,933.20
$0.00
$7,733.30
Third Monthly
12/1/22–12/31/22
D.I. 494, Filed
1/30/23

CNO: Deadline to
object to Third
Monthly Fee
Application is
2/20/23 at 4:00
pm ET
$99,826.00
$0.00
$0.00*
$0.00*
$0.00*
TOTALS:
$223,096.50
$411.25
$98,616.40
$411.25
$24,654.10

Summary of Any Objections to Monthly Fee Application: None.

Compensation Sought in this Application Not Yet Paid: $124,480.10

* Deadline to Object to Third Monthly Fee Application is 2/20/23 at 4:00 pm ET

Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 3 of 17

Compensation By Individual

Name of Professional
Position; Date of Bar
Admission; Area of
Expertise
Hourly
Billing Rate
Total
Billed
Hours
Total Compensation
Tony W. Clark
Senior Counsel; Member of
Pennsylvania Bar since 1979;
Member of Delaware Bar
since 1982. Area of expertise:
Restructuring and Bankruptcy
$1,565.00
12.1
$18,936.50
Brian E. Greer
Shareholder; Member of New
York Bar since 1999. Area of
expertise: Restructuring and
Bankruptcy
$1,125.00
8.4
$9,450.00
David B. Kurzweil
Shareholder; Member of
Georgia Bar since 1987;
Member of New York Bar
since 2012. Area of expertise:
Restructuring and Bankruptcy
$1,540.00
65.4
$100,716.00
Dennis A. Meloro
Shareholder; Member of
Delaware Bar since 2003.
Area of expertise: Bankruptcy
and Restructuring
$1,255.00
3.4
$4,267.00
Matthew A. Petrie
Associate; Member of Florida
Bar since 2007; Member of
Georgia Bar since 2020. Area
of expertise: Restructuring and
Bankruptcy
$870.00
64.3
$55,941.00
Eric J. Howe
Shareholder; Member of the
Illinois Bar since 2007;
Member of Minnesota Bar
since 2013. Area of expertise:
Bankruptcy.
$1,050.00
2.1
$2,205.00
Sandy Bratton
Paralegal; 27 years of
experience.
$435.00
72.6
$31,581.00
Total:
228.3
$223,096.50
Blended Rate:

$1,230.03

Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 4 of 17

COMPENSATION BY PROJECT CATEGORY
Task
Code
Project Category
Total
Hours
Total
Fees
KS001
Case Administration
22.8
$17,416.00
KS003
Employment and Fee Applications
57.3
$43,670.00
KS005
Board and Corporate Governance
97.4
$104,857.50
KS007
Court Hearings
50.8
$57,153.00
Total:
228.3
$223,096.50

EXPENSE SUMMARY

Expense Category

Service Provider
(if applicable)

Total Expenses
Service Company Charges
CT Corporation
$328.24
Information and Research
Lexis/Nexis
$83.01
Total Disbursements:
$411.25

Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 5 of 17

IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE

------------------------------------------------------------ x

In re
:
Chapter 11
:

KABBAGE, INC. d/b/a KSERVICING, et al., :
Case No. 22-10951 (CTG)
:

:
(Jointly Administered)
Debtors.1
:
:

:
Obj. Deadline: March 6, 2023 at 4:00 p.m. (ET)
------------------------------------------------------------ x
Hearing: March 22, 2023 at 10:00 a.m. (ET)

FIRST INTERIM FEE APPLICATION OF GREENBERG
TRAURIG, LLP, SPECIAL COUNSEL TO THE BOARD OF DIRECTORS OF
KABBAGE, INC. D/B/A KSERVICING FOR ALLOWANCE OF COMPENSATION
FOR SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES
FOR THE PERIOD FROM OCTOBER 3, 2022 THROUGH DECEMBER 31, 2022

Greenberg Traurig, LLP (“Greenberg Traurig”), special counsel to the Board of Directors
of Kabbage, Inc. d/b/a KServicing (the “Board”), hereby submits its first interim application (the
“Application”) for compensation and reimbursement of expenses for the period from October 3,
2022 through and including December 31, 2022 (the “Application Period”) pursuant to 11 U.S.C.
§§ 330 and 331 (the “Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure
(the “Bankruptcy Rules”), Rule 2016-2 of the Local Rules of Practice and Procedure of the United
States Bankruptcy Court for the District of Delaware (the “Local Rules”), and this Court’s Order
Establishing Procedures for Interim Compensation and Reimbursement of Expenses of
Professionals [Docket No. 136] (the “Interim Compensation Order”).

By this Application, Greenberg Traurig seeks an interim allowance of compensation in the
amount of $223,096.50 and reimbursement of actual expenses in the amount of $411.25 for an
aggregate total of $223,507.75 in accordance with the Interim Compensation Order. In support of
the Application, Greenberg Traurig respectfully represents as follows:
BACKGROUND
1.
On October 3, 2022, each of the Debtors filed a voluntary petition for relief under
chapter 11 of the Bankruptcy Code (the “Petition Date”).
2.
The Debtors continue to operate their businesses and manage their properties 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.
3.
The Debtors’ cases are being jointly administered for procedural purposes only,
pursuant to an order the Court entered on October 4, 2022 [Docket No. 42].
4.
On October 21, 2022, the Court entered the Interim Compensation Order.
5.
On October 14, 2022, the Debtors filed the Application of Debtors for Authority to
Employ and Retain Greenberg Traurig, LLP as Special Counsel to the Board of Directors of
Kabbage, Inc. d/b/a KServicing Effective as of the Petition Date [Docket No. 107]. On
November 2, 2022, the Court entered the Order Authorizing Debtors to Employ and Retain
Greenberg Traurig, LLP as Special Counsel to the Board of Directors of Kabbage, Inc. d/b/a
KServicing Effective as of the Petition Date [Docket No. 197].
6.
On December 2, 2022, Greenberg Traurig filed the First Monthly Application of
Greenberg Traurig, LLP, as Special Counsel to the Board of Directors of Kabbage, Inc. d/b/a
KServicing, for Allowance of Compensation for Services Rendered and Reimbursement of
Expenses for the Period From October 3, 2022 Through October 31, 2022 [Docket No. 326] (the
Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 7 of 17

“First Monthly Fee Application”). On December 27, 2022, the Debtors filed a certificate of no
objection to the First Monthly Fee Application [Docket No. 377].
7.
On December 29, 2022, Greenberg Traurig filed the Second Monthly Application
of Greenberg Traurig, LLP, as Special Counsel to the Board of Directors of Kabbage, Inc. d/b/a
KServicing, for Allowance of Compensation for Services Rendered and Reimbursement of
Expenses for the Period From November 1, 2022 Through November 30, 2022 [Docket No. 392]
(the “Second Monthly Fee Application”). On January 20, 2023, the Debtors filed a certificate of
no objection to the Second Monthly Fee Application [Docket No. 476].
8.
On January 30, 2023, Greenberg Traurig filed the Third Monthly Application of
Greenberg Traurig, LLP, as Special Counsel to the Board of Directors of Kabbage, Inc. d/b/a
KServicing, for Allowance of Compensation for Services Rendered and Reimbursement of
Expenses for the Period From December 1, 2022 Through December 31, 2022 [Docket No. 494]
(the “Third Monthly Fee Application”). The deadline to object to the Third Monthly Fee
Application is February 20, 2023 at 4:00 p.m. ET.
9.
Greenberg Traurig responds to the following questions raised in the U.S. Trustee
Program’s Guidelines for Reviewing Applications for Compensation and Reimbursement of
Expenses Filed Under 11 U.S.C. § 330 for Attorneys in Larger Chapter 11 Cases (the “U.S.
Trustee Guidelines”):

Question

Yes

No
Additional
Explanation or
Clarification
Did Greenberg Traurig agree to any variations from,
or alternatives to, Greenberg Traurig’s standard or
customary billing rates, fees or terms for services
pertaining to this engagement that were provided
during the application period? If so, please explain.

X
N/A
Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 8 of 17

Question

Yes

No
Additional
Explanation or
Clarification
If the fees sought in the Interim Fee Application as
compared to the fees budgeted for the time period
covered by the Interim Fee Application are higher by
10% or more, did Greenberg Traurig discuss the
reasons for the variation with the client?

X
N/A
Have any of the professionals included in the Interim
Fee Application varied their hourly rate based on
geographic location of the bankruptcy case?

X
N/A
Does the Interim Fee Application include time for
fees related to reviewing or revising time records or
preparing, reviewing or revising invoices?

X
N/A
Does the Interim Fee Application include time for
fees for reviewing time records to redact any
privileged or other confidential information? If so,
please quantify hours and fees.

X
N/A
Does the Interim Fee Application include any rate
increases since retention in these cases?

X
N/A

COMPENSATION PAID AND ITS SOURCE
10.
No agreement or understanding exists between GT and any third person for the
sharing of compensation, except as allowed by Section 504(b) and Bankruptcy Rule 2016 with
respect to sharing of compensation between and among partners at GT. All services for which
compensation is requested hereunder were rendered at the request of and solely on behalf of the
Board and not on behalf of any other entity.
SUMMARY OF SERVICES RENDERED
11.
This Application is the first interim fee application filed by Greenberg Traurig in
these chapter 11 cases. In connection with the professional services described below, by this
Application, Greenberg Traurig seeks compensation in the amount of $223,507.75 for the
Application Period.
12.
The majority of services rendered by Greenberg Traurig during the Application
Period as special counsel to the Board are summarized below. Moreover, each of the following are
Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 9 of 17

set forth in the invoices attached as Exhibits A to the First, Second, and Third Monthly Fee
Applications, which include: (i) a description of the Professional performing the services; (ii) the
date the services were performed; (iii) a detailed description of the nature of the services and the
related time expended; and (iv) a summary of the fees and hours of each Professional listed by
project category (which applicable categories are set forth below). Summarily, Greenberg Traurig
rendered the following services during the Application Period as special counsel to the Board:
a) Case Administration (KS001)
Fees: $17,416.00
Hours: 22.80
This category includes services relating to the general administration of these cases,
including without limitation, reviewing case background, case status, and maintaining a calendar
of important dates.
b) Employment and Fee Applications (KS003)
Fees: $43,670.00
Hours: 57.30

This category includes services relating to drafting, reviewing, revising, finalizing and
filing Greenberg Traurig’s retention application and addressing questions and comments from the
United States Trustee regarding Greenberg Traurig’s retention application. This category also
includes services relating to drafting, reviewing, revising and finalizing Greenberg Traurig’s first,
second and third monthly fee applications.
c) Board and Corporate Governance (KS005)
Fees: $104,857.50
Hours: 97.4

This category includes services relating to reviewing materials and presentations prepared
for the Board, attending meetings of the Board, reviewing minutes of meetings of the Board, and
monitoring case pleadings and important deadlines for the Board.
Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 10 of 17

d) Court Hearings (KS007)
Fees: $57,153.00
Hours: 50.8

This category includes services relating to preparing for and attending hearings.
SUMMARY OF EXPENSES
13.
During the Application Period, Greenberg Traurig incurred or disbursed actual and
necessary costs and expenses related to these cases in the aggregate amount of $411.25. Greenberg
Traurig seeks reimbursement of actual expenses in the amount of $411.25. The expenses incurred
include service company charges and research charges. A detailed description of the necessary
costs and expenses incurred by Greenberg Traurig is attached as Exhibit B to the First Monthly
Fee Application.
14.
Pursuant to Local Rule 2016-2, Greenberg Traurig represents as follows with
regard to its charges for actual and necessary costs and expenses incurred during the Application
Period, if any:
a.
Copy Charges were $0.10 per page ($0.80 for color copies), which charges are
reasonable and customary in the legal industry and represents the costs of copy material,
acquisition, maintenance, storage, and operation of copy machines, together with a margin
for recovery of related expenditures. In addition, Greenberg Traurig often utilizes outside
copier services for high volume projects, and this Application seeks the recovery of those
costs, if applicable;
b.
Incoming facsimiles are not billed;
c.
Out-going facsimiles are billed at the rate of $0.25 per page. The cost represents
operator time, maintaining several dedicated facsimile telephone lines, supplies and
equipment, and includes a margin for recovery of related expenditures;
d.
Toll telephone charges are not billed; and
Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 11 of 17

e.
Computer assisted legal research charges are billed at actual costs.
VALUATION OF SERVICES
15.
Greenberg Traurig expended a total of 228.30 hours in connection with this matter
during the Application Period. The nature of the work performed by the Professionals is detailed
in Exhibit A of the First, Second, and Third Monthly Fee Applications. The hourly rates contained
therein are Greenberg Traurig’s normal hourly rates for work of this character.
16.
In accordance with the factors enumerated in Section 330 of the Bankruptcy Code,
the amounts requested herein for compensation and expense reimbursement are fair and reasonable
given (a) the complexity of these cases, (b) the time expended by the attorneys and
paraprofessionals at Greenberg Traurig, (c) the nature and extent of the services rendered, (d) the
value of such services, and (e) the costs of comparable services other than in a case under this title.
17.
Greenberg Traurig hereby certifies that (i) it has reviewed the requirements of Local
Rule 2016-2 and (ii) this Application complies with such rule.
18.
Greenberg Traurig has provided a copy of this Application to the Notice Parties (as
defined in the Interim Compensation Order).
[Remainder of page intentionally left blank.]

Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 12 of 17

CONCLUSION
WHEREFORE, Greenberg Traurig respectfully requests that (a) it be allowed
compensation in the amount of $223,096.50 for professional services rendered and reimbursement
of expenses in the amount of $411.25 for the Application Period; (b) the Court authorize the
Debtors to pay Greenberg any unpaid portion for the Application Period on an interim basis; and
(c) the Court grant such other and further relief deemed appropriate under the circumstances.
Dated: February 14, 2023

Respectfully submitted,

Wilmington, Delaware

GREENBERG TRAURIG, LLP

/s/ Dennis A. Meloro

Anthony W. Clark (DE Bar No. 2051)
Dennis A. Meloro (DE Bar No. 4435)
222 Delaware Avenue, Suite 1600
Wilmington, Delaware 19801
Telephone: (302) 661-7000
Email: Anthony.clark@gtlaw.com
melorod@gtlaw.com

- and -

David B. Kurzweil (admitted pro hac vice)
Matthew A. Petrie (admitted pro hac vice)
3333 Piedmont Road, NE, Suite 2500
Atlanta, Georgia 30305
Telephone: (678) 553-2259
Email: kurzweild@gtlaw.com

petriem@gtlaw.com

Special Counsel to the Board of Directors of
Kabbage, Inc. d/b/a KServicing

Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 13 of 17

EXHIBITS A – C
PLEASE TAKE NOTICE that in compliance with the U.S. Trustee Program’s Guidelines
for Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11
U.S.C. § 330 for Attorneys in Larger Chapter 11 Cases (the “U.S. Trustee Guidelines”), attached
hereto as Exhibit A is a copy of the budget and staffing plan agreed to between the above-
captioned debtors and debtors in possession and Greenberg Traurig, LLP (“Greenberg Traurig”)
for the period of October 3, 2022 through and including December 31, 2022 (the “First Interim
Period”). A chart comparing the total hours spent and the hours budgeted for each task code for
the First Interim Period is attached hereto as Exhibit B.
PLEASE TAKE FURTHER NOTICE that attached hereto as Exhibit C are Greenberg
Traurig’s customary and comparable compensation disclosures.
Dated: February 14, 2023

Respectfully submitted,

Wilmington, Delaware

GREENBERG TRAURIG, LLP

/s/ Dennis A. Meloro

- and -

David B. Kurzweil (admitted pro hac vice)
Matthew A. Petrie (admitted pro hac vice)
3333 Piedmont Road, NE, Suite 2500
Atlanta, Georgia 30305
Telephone: (678) 553-2259
Email: kurzweild@gtlaw.com

petriem@gtlaw.com

Special Counsel to the Board of Directors of
Kabbage, Inc. d/b/a KServicing
Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 14 of 17

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)
:

:
(Jointly Administered)
Debtors.1
:
:

:
Obj. Deadline: March 6, 2023 at 4:00 p.m. (ET)
------------------------------------------------------------ x
Hearing: March 22, 2023 at 10:00 a.m. (ET)

CERTIFICATION OF DENNIS A. MELORO IN SUPPORT OF
FIRST INTERIM FEE APPLICATION OF GREENBERG TRAURIG, LLP
I, David Kurzweil, hereby declare, pursuant to 28 U.S.C. § 1746, under penalty of perjury
as follows:
1.
I am a Shareholder at Greenberg Traurig, LLP (“Greenberg Traurig”), which
maintains offices for the practice of law at 222 Delaware Avenue, Suite 1600, Wilmington,
Delaware 19801. I am an attorney-at-law, duly admitted and in good standing to practice in the
State of Delaware.
2.
I make this certification regarding the First Interim Fee Application of Greenberg
Traurig, LLP, as Special Counsel to the Board of Directors of Kabbage, Inc. d/b/a KServicing for
Allowance of Compensation for Services Rendered and Reimbursement of Expenses for the Period
from October 3, 2022 through December 31, 2022 (the “Interim Fee Application”) to certify to

certain matters addressed in the Order Establishing Procedures for Interim Compensation and
Reimbursement of Expenses of Professionals [Docket No. 136] (the “Interim Compensation
Order”).
3.
Specifically, I have reviewed the Interim Fee Application, including each monthly
fee application relating to the period from October 3, 2022 through and including December 31,
2022 (the “Interim Fee Period”), and I hereby certify that such applications comply with the
Interim Compensation Order and the applicable provisions of the Bankruptcy Code, the Federal
Rules of Bankruptcy Procedure and the Local Rules for the United States Bankruptcy Court for
the District of Delaware. In addition, I hereby certify that, in accordance with the Interim
Compensation Order, and in connection with preparing the Interim Fee Application, Greenberg
Traurig has made a reasonable effort to comply with the U.S. Trustee Program’s Guidelines for
Reviewing Applications for Compensation and Reimbursement of Expenses Filed Under 11 U.S.C.
§ 330 for Attorneys in Larger Chapter 11 Cases (the “U.S. Trustee Guidelines”). To that end,
Greenberg Traurig specifically responds to certain questions identified in the U.S. Trustee
Guidelines as follows:
 Question 1: Did Greenberg Traurig agree to any variations from, or alternatives to,
Greenberg Traurig’s standard or customary billing rates, fees or terms for services
pertaining to this engagement that were provided during the application period? If so,
please explain.

 Answer: No.
 Question 2: If the fees sought in the Interim Fee Application as compared to the fees
budgeted for the time period covered by the Interim Fee Application are higher by 10% or
more, did Greenberg Traurig discuss the reasons for the variation with the client?

 Answer: Not Applicable.
Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 16 of 17

 Question 3: Have any of the professionals included in the Interim Fee Application varied
their hourly rate based on geographic location of the bankruptcy case?

 Answer: No.
 Question 4: Does the Interim Fee Application include time for fees related to reviewing or
revising time records or preparing, reviewing or revising invoices?

 Answer: No.
 Question 5: Does the Interim Fee Application include time for fees for reviewing time
records to redact any privileged or other confidential information? If so, please quantify
hours and fees.

 Answer: No.
 Question 6: Does the Interim Fee Application include any rate increases since retention in
these cases?

 Answer: No.
I declare under penalty of perjury that the foregoing is true and correct to the best of my
information, knowledge, and belief.
Dated: February 14, 2023

Respectfully submitted,

GREENBERG TRAURIG, LLP

/s/ Dennis A. Meloro

Dennis A. Meloro (DE Bar No. 4435)
222 Delaware Avenue, Suite 1600
Wilmington, Delaware 19801
Telephone: (302) 661-7000
Email: melorod@gtlaw.com

Special Counsel to the Board of Directors of
Kabbage, Inc. d/b/a KServicing
Case 22-10951-CTG Doc 533 Filed 02/14/23 Page 17 of 17

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Greenberg Traurig First Interim Fee Application — In re KServicing

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