Fourth Monthly Fee Statement (Weil, Gotshal & Manges LLP) — In re KServicing

Record facts

U.S. Bankruptcy Court for the District of Delaware · No. 22-10951 · Doc. 600 · 2023-03-03 · Docket on CourtListener

Summary

The fourth monthly fee statement of Weil, Gotshal & Manges LLP, counsel to the debtors in In re Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), filed March 3, 2023 as Doc 600 in the U.S. Bankruptcy Court for the District of Delaware. It covers January 1, 2023 through January 31, 2023 and requests $1,573,224.40 (80% of $1,966,530.50) in fees plus $14,835.24 in expenses. Summary tables break the 1,560.10 billed hours down by professional, by project category and by expense type, with the largest categories being disclosure statement work and non-bankruptcy litigation. A narrative describes services under task codes including asset sales of legacy loans, claims matters, the amended plan and corporate governance. The 15-page filing sets an objection deadline of March 23, 2023 and closes with a declaration by a Weil member.

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

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: March 23, 2023 at 4:00 p.m. (ET)
SUMMARY OF FOURTH MONTHLY FEE STATEMENT OF WEIL, GOTSHAL & 
MANGES LLP FOR PAYMENT OF COMPENSATION AND REIMBURSEMENT OF 
EXPENSES FOR PERIOD JANUARY 1, 2023 THROUGH JANAURY 31, 2023
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
January 1, 2023 through January 31, 2023
$1,573,224.40 (80% of $1,966,530.50)
$14,835.24
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 99023273V.6
Case 22-10951-CTG    Doc 600    Filed 03/03/23    Page 1 of 15

2
COMPENSATION BY PROFESSIONAL
JANUARY 1, 2023 THROUGH JANUARY 31, 2023
The attorneys who rendered professional services in these chapter 11 cases from January 1, 2023 
through January 31, 2023 (the “Fee Period”) are:
NAME OF 
PROFESSIONAL
POSITION
DEPARTMENT
YEAR 
ADMITTED1
HOURLY 
BILLING 
RATE2
TOTAL 
BILLED 
HOURS 
TOTAL 
COMPENSATION
Goldring, Stuart J.
Partner
Tax
1984
$2,095.00
16.50
$34,567.50
Slack, Richard W.
Partner
Litigation
1987
$1,695.00
46.50
$78,817.50
Slack, Richard W.
Partner
Litigation
1987
$847.50†
1.70
$1,440.75
Tsekerides, Theodore 
E.
Partner
Litigation
1994
$1,395.00
65.30
$104,153.50
Schrock, Ray C.
Partner
Restructuring
1998
$2,095.00
4.50
$9,427.50
Westerman, Gavin
Partner
Corporate
2004
$1,725.00
14.40
$24,840.00
Arthur, Candace
Partner
Restructuring
2010
$1,695.00
157.90
$267,640.50
Arthur, Candace
Partner
Restructuring
2010
$847.50†
3.00
$2,542.50
Hwangpo, Natasha
Partner
Restructuring
2014
$1,575.00
186.90
$294,367.50
Magill, Amanda 
Graham
Partner
Tax
2015
$1,575.00
2.40
$3,780.00
Bonk, Cameron Mae
Counsel
Litigation
2016
$1,375.00
93.20
$128,150.00
Bonk, Cameron Mae
Counsel
Litigation
2016
$687.50†
2.10
$1,443.75
Guthrie, Hayden
Counsel
Corporate
2017
$1,400.00
9.10
$12,740.00
Friedman, Julie T.
Associate
Restructuring
2003
$775.00
12.10
$9,377.50
Ruocco, Elizabeth A.
Associate
Restructuring
2017
$1,275.00
144.60
$184,365.00
Ruocco, Elizabeth A.
Associate
Restructuring
2017
$637.50†
4.00
$2,550.00
Bentley, Chase A.
Associate
Restructuring
2018
$1,345.00
128.60
$172,967.00
Diplas, Alexandros
Associate
Litigation
2018
$1,275.00
15.50
$19,762.50
Kleiner, Adena
Associate
Corporate
2020
$1,170.00
62.70
$73,359.00
Parker-Thompson, 
Destiney
Associate
Restructuring
2020
$910.00
69.00
$62,790.00
McMillan, Jillian A.
Associate
Restructuring
2021
$1,170.00
52.70
$61,659.00
McMillan, Jillian A.
Associate
Restructuring
2021
$585.00†
4.80
$2,808.00
Cummings, Kyle
Associate
Litigation
2021
$1,065.00
8.30
$8,839.50
Ham, Hyunjae
Associate
Restructuring
2021
$1,065.00
102.70
$109,375.50
1 * – Not Yet Admitted to Practice
2 † – Non-working travel is billed at 50% of regular hourly rates.
Case 22-10951-CTG    Doc 600    Filed 03/03/23    Page 2 of 15

3
Ollestad, Jordan 
Alexandra
Associate
Litigation
2022
$1,065.00
93.70
$99,790.50
Ollestad, Jordan 
Alexandra
Associate
Litigation
2022
$532.50†
3.00
$1,597.50
Cazes, Catherine
Associate
Litigation
2022
$910.00
9.50
$8,645.00
Shah, Bastian
Associate
Tax
2022
$910.00
27.00
$24,570.00
Shah, Bastian
Associate
Tax
2022
$840.00
14.60
$12,264.00
Suarez, Ashley
Associate
Restructuring
2022
$910.00
11.40
$10,374.00
Bertens, Erin
Associate
Corporate
*
$750.00
13.80
$10,350.00
Castillo, Lauren
Associate
Restructuring
*
$750.00
158.40
$118,800.00
Total for Attorneys
1,539.90
$1,958,155.00
The paraprofessionals who rendered professional services during the Fee Period are:
NAME OF 
PARAPROFESSIONAL
POSITION
DEPARTMENT
HOURLY 
BILLING 
RATE
TOTAL 
BILLED 
HOURS 
TOTAL 
COMPENSATION
Wong, Sandra
Paralegal
Litigation
$495.00
3.60
$1,782.00
Gilchrist, Roy W.
Paralegal
Litigation
$475.00
5.70
$2,707.50
Chan, Herbert
Paralegal
Litigation
$440.00
3.90
$1,716.00
Mason, Kyle
Paralegal
Restructuring
$310.00
3.20
$992.00
Okada, Tyler
Paralegal
Restructuring
$310.00
3.80
$1,178.00
Total:
20.20
$8,375.50
The total fees for the Fee Period are:
PROFESSIONALS
BLENDED RATE
TOTAL 
BILLED 
HOURS 
TOTAL COMPENSATION
Partners and Counsel
$1,597.20
603.50
$963,911.00
Associates
$1,061.77
936.40
$994,244.00
Paraprofessionals
$414.63
20.20
$8,375.50
Blended Attorney Rate
$1,271.36
Total:
1,560.10
$1,966,530.50
Case 22-10951-CTG    Doc 600    Filed 03/03/23    Page 3 of 15

4
COMPENSATION BY PROJECT CATEGORY
JANUARY 1, 2023 THROUGH JANUARY 31, 2023
TASK 
CODE
PROJECT CATEGORY
TOTAL BILLED 
HOURS
TOTAL 
COMPENSATION
001
Administrative Expense Claims
10.70
$11,108.00
003
AmEx Transaction Investigation
19.80
$23,381.50
004
Asset Disposition/363 Asset Sales
74.00
$87,768.50
006
Bar Date and Claims Matters
80.90
$72,848.50
008
Case Administration (WIP List & Case Calendar)
12.30
$11,509.00
009
Chapter 11 Plan/Plan Confirmation/Implementation
208.20
$275,985.50
010
Corporate Governance/Securities
90.30
$104,564.00
011
Customer (incl. Partner Banks)/Vendor/Supplier Matters
15.20
$22,802.00
012
Cash Management
1.70
$2,317.50
013
Disclosure Statement/Solicitation/Voting
401.00
$497,560.00
014
Employee Matters
3.70
$4,036.50
015
Exclusivity
19.50
$19,681.50
016
Executory Contracts/Leases/Real Prop/Other 365 Matters
5.90
$7,663.00
017
General Case Strategy (incl Team and Client Calls)
85.50
$107,166.00
019
Hearings and Court Matters
17.90
$23,269.50
021
Non-bankruptcy Litigation (incl. CUBI Dispute)
339.90
$480,786.50
022
Non-working Travel
18.60
$12,382.50
024
Regulatory Matters
10.60
$17,212.00
025
Retention/Billing/Fee Applications: OCP
8.30
$9,183.00
026
Retention/Fee Applications: Non-Weil Professionals
8.70
$8,839.50
027
Retention/Fee Applications: Weil
19.60
$17,354.50
028
Secured Creditors Issues/Meetings/Comms (excl. Settlements)
5.40
$7,989.00
031
Tax Matters
20.30
$23,300.00
033
US Trustee/MORs/2015.3 Reports
1.80
$2,445.00
035
Servicing Transfer
80.30
$115,377.50
TOTAL
1,560.10
$1,966,530.50
Case 22-10951-CTG    Doc 600    Filed 03/03/23    Page 4 of 15

5
EXPENSE SUMMARY
JANUARY 1, 2023 THROUGH JANUARY 31, 2023
EXPENSE CATEGORY
AMOUNT
Air Courier/Express Mail/Outside Messenger Service
$110.86
Computerized Research
$6,422.06
Duplicating
$1,102.30
Meals
$180.00
Transportation
$1,302.78
Travel
$5,717.24
TOTAL
$14,835.24
Case 22-10951-CTG    Doc 600    Filed 03/03/23    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: March 23, 2023 at 4:00 p.m. (ET)
FOURTH MONTHLY FEE STATEMENT OF
WEIL, GOTSHAL & MANGES LLP FOR PAYMENT OF
COMPENSATION AND REIMBURSEMENT OF EXPENSES FOR
PERIOD JANUARY 1, 2023 THROUGH JANUARY 31, 2023
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 fourth 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 January 1, 2023 through and including January 31, 2023 
(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 600    Filed 03/03/23    Page 6 of 15

2
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 600    Filed 03/03/23    Page 7 of 15

3
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 
$1,573,224.40 (80% of $1,966,530.50) as compensation for professional services rendered to the 
Debtors during the Fee Period and allowance and payment of $14,835.24 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 
Case 22-10951-CTG    Doc 600    Filed 03/03/23    Page 8 of 15

4
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.
Asset Disposition/363 Asset Sales (Task Code 004)
Fees:  $87,768.50; Total Hours:  74.00

Reviewed and analyzed documents related to the sale of the 
Debtors’ legacy loans;

Drafted, reviewed, and revised legacy loans purchase agreement; 

Researched legal issues in connection with precedent asset sale 
motions and plans with sale processes; and

Conferred with Weil team and Debtors’ advisors related to the 
sale of the Debtors’ legacy loans.
b.
Bar Date and Claims Matters (Task Code 006) 
Fees:  $72,848.50; Total Hours:  80.90

Reviewed and summarized proofs of claim;
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 600    Filed 03/03/23    Page 9 of 15

5

Drafted, reviewed, and revised claims objection summary chart;

Drafted, reviewed, and revised omnibus objection for 
reclassification purposes;

Researched issues related to omnibus claims objections; and

Corresponded with Debtors and Debtors’ advisors regarding the 
above.
c.
Chapter 11 Plan/Plan Confirmation/Implementation (Task Code 009) 
Fees:  $275,985.50; Total Hours:  208.20

Participated on calls with Debtors’ advisors, the U.S. Trustee, 
and counsel to various creditors regarding the Plan and the Plan 
Supplement; 

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. 466]; 

Responded to Plan-related questions and comments from the 
Debtors, the Debtors’ advisors, the U.S. Trustee, the Reserve 
Bank, and other stakeholders;

Analyzed third party servicer regulatory requirements;

Drafted, reviewed and revised Plan Supplement documents.
d.
Corporate Governance / Securities (Task Code 010) 
Fees:  $104,564.00; Total Hours:  90.30

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:  $497,560.00; Total Hours:  401.00

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 
Case 22-10951-CTG    Doc 600    Filed 03/03/23    Page 10 of 15

6
Debtors [Docket Nos. 454 and 467] (the “Disclosure 
Statement”);

Drafted, reviewed, revised, and finalized the Order (I) Approving 
the Disclosure Statement of the Debtors, (II) Establishing 
Solicitation, Voting and Related Procedures, (III) Scheduling 
Confirmation Hearing, (IV) Establishing Notice and Objection 
Procedures for Confirmation of Plan, (V) Approving Special 
Electronic Noticing Procedures, (VI) Approving Debtors’ 
Proposed Cure Procedures for Unexpired Leases and Executory 
Contracts, and (VII) Granting Related Relief [Docket No. 470];

Drafted, reviewed, revised, and finalized the Debtors’ Omnibus 
Reply to Objections to Motion of Debtors for Entry of Order (I) 
Approving the Disclosure Statement of the Debtors, (II) 
Establishing Solicitation, Voting, and Related Procedures, (III) 
Scheduling Confirmation Hearing, (IV) Establishing Notice and 
Objection Procedures for Confirmation of Plan, (V) Approving 
Special Electronic Noticing Procedures, (VI) Approving 
Debtors’ Proposed Cure Procedures for Unexpired Leases and 
Executory Contracts, and (VII) Granting Related Relief [Docket 
No. 449] (the “Disclosure Statement Reply”);

Reviewed and revised liquidation analysis and discussed with 
Debtors’ advisors;

Reviewed and responded to the Debtors, the Debtors’ advisors, 
the U.S. Trustee, the Reserve Bank, the Department of Justice, 
and other stakeholders’ comments and objections to Disclosure 
Statement;

Researched and conferred with Weil team, various counsel, and 
Debtors regarding the Disclosure Statement Reply; and

Reviewed and revised ballots for solicitation of the Plan.
f.
General Case Strategy (incl. Team and Client Calls) (Task Code 017) 
Fees:  $107,166.00; Total Hours:  85.50

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.
Case 22-10951-CTG    Doc 600    Filed 03/03/23    Page 11 of 15

7
g.
Non-Bankruptcy Litigation (incl. CUBI Dispute) (Task Code 021) 
Fees:  $480,786.50; Total Hours:  339.90

Drafted, reviewed, and revised reply related to 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;

Drafted, reviewed, and revised the CUBI stipulation, the 
proposed order related to the CUBI Dispute, and the letter to 
CUBI regarding data information requests; 

Corresponded with the Debtors and the Debtors’ advisors 
regarding various pending litigations and disputes.
h.
Servicing Transfer (Task Code 035)
Fees:  $115,377.50; Total Hours:  80.30

Participated on calls with Weil team, the Debtors, and various 
parties regarding the loan servicing transition plan; 

Reviewed and analyzed documents and correspondence related 
to the transitioning of the Debtors’ loan servicing obligations;

Discussed and conferred with Weil team, the Debtors, CUBI, 
CRB, AmEx regarding servicing documents in AmEx’s control 
and/or possession;

Drafted, reviewed, and revised loan servicing transition plan; 
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 $14,835.24.  Annexed hereto as Exhibit B is a list of 
Case 22-10951-CTG    Doc 600    Filed 03/03/23    Page 12 of 15

8
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 
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.  
[Remainder of Page Intentionally Left Blank]
Case 22-10951-CTG    Doc 600    Filed 03/03/23    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 
$1,966,530.50 for actual and necessary costs, and for expenses incurred by Weil during the Fee 
Period in the amount of $14,835.24; (b)  that, in accordance with the Interim Compensation Order, 
the Debtors pay Weil a total of $1,588,059.64 consisting of $1,573,224.40 (representing 80% of 
the total amount of fees allowed) and $14,835.24 (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:  March 3, 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 600    Filed 03/03/23    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:
March 3, 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 600    Filed 03/03/23    Page 15 of 15

File and source

File

gov.uscourts.deb.188293.600.0.pdf

Size

371,584 bytes

SHA-256

3026de4222cd9144e667865111a29a83dd26cb19381ff0008731ee19ebe72d8f

Our copy

gov.uscourts.deb.188293.600.0.pdf

Original

archive.org