Court filing

Monthly Fee Application (Richards Layton & Finger — January 2023) — In re KServicing

Record facts

Court	U.S. Bankruptcy Court for the District of Delaware
Filed	2023-03-07

U.S. Bankruptcy Court for the District of Delaware · No. 22-10951 · Doc. 621 · 2023-03-07 · Docket on CourtListener

Summary

The Fourth Monthly Application of Richards, Layton & Finger, P.A., co-counsel to the debtors, filed March 8, 2023 as Doc 621 in the jointly administered Chapter 11 cases of Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), in the U.S. Bankruptcy Court for the District of Delaware. It seeks allowance of $323,673.50 in fees, 80% of which is $258,938.80, plus $10,333.27 in expenses, for a total of $334,006.77 for January 1, 2023 through January 31, 2023. Summary tables break down 404.4 hours by professional and by project category, with the largest category, Plan of Re-Organization/Disclosure Statement, at $145,538.00. It lists prior monthly applications, itemizes expenses including business meals and overtime, and sets an objection deadline of March 28, 2023. Amanda R. Steele signs a Local Rule 2016-2 certification.

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 28686156v.1
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 28, 2023 at 4:00 p.m. (ET)
------------------------------------------------------------ x

Name of Applicant:

Richards, Layton & Finger, P.A.

Authorized to Provide Professional Services to:
the above-captioned debtors and

debtors in possession

Date of Retention:

October 28, 2022, nunc pro tunc

to October 3, 2022

Period for which compensation
and reimbursement are sought:

January 1, 2023 to January 31, 2023

Amount of Compensation sought as actual,
reasonable, and necessary:

$258,938.80 (80% of $323,673.50)

Amount of Expense Reimbursement sought
as actual, reasonable, and necessary:

$10,333.27

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.
Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 1 of 19

RLF1 28686156v.1
Prior Applications Filed:

Date
Period
Docket No.
Fees
Expenses
12/2/22
10/3/22 – 10/31/22
327
$344,163.50
$2,605.35
1/4/23
11/1/22 – 11/30/22
407
$288,304.50
$9,556.64
2/1/23
12/1/22 – 12/31/22
511
$202,611.50
$1,594.74

Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 2 of 19

RLF1 28686156v.1
COMPENSATION BY PROFESSIONAL
JANUARY 1, 2023 THROUGH JANUARY 31, 2023

Name of Professional
Individual
Position, year assumed
position, prior relevant
experience, year of
obtaining relevant
license to practice
Hourly
Billing Rate
(including
changes)
Total
Hours
Billed
Total
Compensation
Daniel J. DeFranceschi
Joined firm as associate
in 1990. Director in
2000. Member of DE
Bar since 1989.
$1,300
7.0
$9,100.00
Amanda R. Steele
Joined firm as associate
in 2010. Director in
2018. Member of DE
Bar since 2010.
$995
77.3
$76,913.50
Zachary I. Shapiro
Joined firm as associate
in 2007. Director in
2019. Member of DE
Bar since 2008.
$995
132.5
$131,837.50
$850
0.2
$170.00
Cory D. Kandestin
Joined firm as associate
in 2007. Counsel in
2015. Member of DE
Bar since 2007.
$875
1.2
$1,050.00
Matthew P. Milana
Joined firm as associate
in 2022. Member of DE
Bar since 2019.
$675
75.4
$50,895.00
Huiqi Vicky Liu
Joined firm as associate
in 2020. Member of DE
Bar since 2022.
$595
53.6
$31,892.00
James F. McCauley
Joined firm as associate
in 2020. Member of DE
Bar since 2022.
$595
0.5
$297.50
Emily R. Mathews
Joined firm as associate
in 2021. Member of DE
Bar since 2022.
$550
0.5
$275.00
Ashly L. Riches
Joined firm as associate
in 2022.
$495
1.4
$693.00
Barbara J. Witters
Paralegal since 2000.
Joined firm in 2000.
$375
2.7
$1,012.50
M. Lynzy McGee
Paralegal since 2007.
Joined firm in 2016.
$375
44.5
$16,687.50
Rebecca V. Speaker
Paralegal since 2002.
Joined firm in 2001.
$375
7.6
$2,850.00
TOTAL

404.4
$323,673.50
Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 3 of 19

RLF1 28686156v.1

Grand Total

$323,673.50

Attorney Compensation
$303,123.50

Total Attorney Hours
349.6

Blended Rate

$867.06
Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 4 of 19

RLF1 28686156v.1
COMPENSATION BY PROJECT CATEGORY
JANUARY 1, 2023 THROUGH JANUARY 31, 2023

Project Category
Total Hours
Total Fees
Case Administration (A)
5.9
$3,525.00
Creditor Inquiries (B)
2.3
$1,370.50
Meetings (C)
38.9
$36,369.50
Executory Contracts/Unexpired Leases (D)
6.3
$4,418.50
Automatic Stay/Adequate Protection (E)
0.0
$0.00
Plan of Re-Organization/Disclosure Statement (F)
173.0
$145,538.00
Use, Sale, Lease of Assets (G)
5.8
$4,067.00
Cash Collateral/DIP Financing (H)
0.0
$0.00
Claims Administration (I)
24.8
$18,786.00
Court Hearings (J)
81.6
$61,728.00
General Corporate/Real Estate (K)
0.0
$0.00
Schedules/SOFA/U.S. Trustee Reports (L)
3.5
$2,298.50
Employee Issues (M)
0.0
$0.00
Environmental (N)
0.0
$0.00
Tax Issues (O)
0.0
$0.00
Litigation/Adversary Proceedings (P)
28.0
$25,107.00
RL&F Retention (Q-1)
0.0
$0.00
Retention of Others (Q-2)
5.5
$3,370.50
RL&F Fee Applications (R-1)
14.0
$8,802.00
Fee Applications of Others (R-2)
14.8
$8,293.00
Vendor/Supplies (S)
0.0
$0.00
Non-Working Travel (T)
0.0
$0.00
Utilities (U)
0.0
$0.00
Insurance (V)
0.0
$0.00
TOTAL
404.4
$323,673.50

Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 5 of 19

RLF1 28686156v.1
EXPENSE SUMMARY
JANUARY 1, 2023 THROUGH JANUARY 31, 2023

Expense Category
Service Provider
(if applicable)
Total Expenses
Facsimile

$0.00
Conference Calling

$0.00
Long Distance Telephone

$1.47
In-House Reproduction
(Duplication/Printing)
Duplicating: 0 @ $0.10 pg.
Printing: 6,794 @ $0.10 pg.
$679.40
Outside Reproduction
Parcels, Inc.
$3,457.05
Legal Research
Bloomberg, Westlaw
$3,462.68
Filing/Court Fees

$0.00
Court Reporting
Reliable Wilmington
$319.00
Travel Expenses

$0.00
Inside Courier & Expense
Carriers

$0.00
Outside Courier & Expense
Carriers
Parcels, Inc.
$166.00
Postage

$0.00
Binding

$0.00
Business Meals
See attached chart
$1,672.27
Document Retrieval
PACER
$47.40
Record Retrieval

$0.00
Professional Services

$0.00
Overtime
See attached chart
$528.00
Room Rental

$0.00
Equipment Rental

$0.00
Stationery Supplies

$0.00
TOTAL

$10,333.27

Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 6 of 19

RLF1 28686156v.1
BUSINESS MEAL DETAIL
Date
Provider
Meal &
Number of
people
Description
Amount
1/5/2023
DiMeo’s
Dinner for 12
Preparation for 1/6/23 hearing
$177.75
1/6/2023
Manhattan Bagel
Breakfast for 14 Preparation for 1/6/23 hearing
$202.84
1/6/2023
Zoup!
Lunch for 12
Preparation for 1/6/23 hearing
$249.13
1/18/2023
Zoup!
Lunch for 10
Preparation for 1/19/23 hearing
$229.66
1/18/2023
Brio Italian Grill
Dinner for 10
Preparation for 1/19/23 hearing
$446.40
1/19/2023
Manhattan Bagel
Breakfast for 10 Preparation for 1/19/23 hearing
$179.29
1/19/2023
Cavanaugh’s
Restaurant
Lunch for 8
Preparation for 1/19/23 hearing
$187.20
TOTAL

$1,672.27

SECRETARIAL OVERTIME DETAIL
Date
Posted
Secretary
Description
Amount
1/3/2023
Lesley Morris
Assist co-counsel with hearing logistics for 1/6/23
hearing
$48.00
1/15/2023
Lesley Morris
Assist co-counsel with hearing logistics for 1/19/23
hearing
$48.00
1/18/2023
Jeanne Carrera
Assist with preparation for 1/19/23 hearing
$432.00
TOTAL

$528.00

Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 7 of 19

RLF1 28686156v.1
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 28, 2023 at 4:00 p.m. (ET)
------------------------------------------------------------ x

FOURTH MONTHLY APPLICATION OF RICHARDS, LAYTON & FINGER, P.A. FOR
ALLOWANCE OF COMPENSATION FOR SERVICES RENDERED AND FOR
REIMBURSEMENT OF EXPENSES AS CO-COUNSEL TO THE DEBTORS
FOR THE PERIOD FROM JANUARY 1, 2023 THROUGH JANUARY 31, 2023
Pursuant to sections 330 and 331 of title 11 of the United States Code, §§ 101-1532
(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
Order Establishing Procedures for Interim Compensation and Reimbursement of Expenses of
Professionals, dated October 21, 2022 [Docket No. 136] (the “Interim Compensation Order”),
Richards, Layton & Finger, P.A. (“RL&F”) hereby files this Fourth Monthly Application of
Richards, Layton & Finger, P.A. for Allowance of Compensation for Services Rendered and for
Reimbursement of Expenses as Co-Counsel to the Debtors for the Period from January 1, 2023
through January 31, 2023 (the “Application”). By the Application, RL&F seeks a monthly
allowance pursuant to the Interim Compensation Order with respect to the sums of $323,673.50

2
RLF1 28686156v.1
as compensation and $10,333.27 for reimbursement of actual and necessary expenses, for a total
of $334,006.77 for the period January 1, 2023 through and including January 31, 2023 (the
“Compensation Period”). In support of this Application, RL&F 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.
RL&F was retained effective as of the Petition Date by this Court’s order, entered
on October 28, 2022 [Docket No. 175] (the “Retention Order”). The Retention Order authorized
RL&F to be compensated on an hourly basis and to be reimbursed for actual and necessary out-
of-pocket expenses.
Compensation Paid and Its Source
3.
All services for which compensation is requested by RL&F were performed for or
on behalf of the Debtors.
4.
Except to the extent of the retainer paid to RL&F as described in the application
seeking approval of RL&F’s employment by the Debtors during the period covered by this
Application, RL&F has received no payment and no promises for payment from any source for
services rendered or to be rendered in any capacity whatsoever in connection with the matters
covered by this Application. There is no agreement or understanding between RL&F and any
Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 9 of 19

3
RLF1 28686156v.1
other person other than the directors of RL&F for the sharing of compensation to be received for
services rendered in these cases.
Fee Statements
5.
The fee statement for the Compensation Period is attached hereto as Exhibit A.
This statement contains daily time logs describing the time spent by each attorney and
paraprofessional for this period. To the best of RL&F’s knowledge, this Application complies
with sections 330 and 331 of the Bankruptcy Code, the applicable Bankruptcy Rules, the
Guidelines adopted by the Office of the United States Trustee, Local Rule 2016-2, and the Interim
Compensation Order.
Actual and Necessary Expenses
6.
A summary of actual and necessary expenses and daily logs of expenses incurred
by RL&F during the Compensation Period is attached hereto as Exhibit B. RL&F charges all of
its bankruptcy clients $0.10 per page for photocopying expenses and $0.10 per page for printing
jobs.
7.
Regarding providers of on-line legal research (e.g., LEXIS and WESTLAW),
RL&F charges all of its clients the standard usage rates these providers charge, which, due to
contractual flat fees, may not always equal RL&F’s actual cost. RL&F currently is under contract
to pay these providers a flat fee every month. Charging its clients the on-line providers’ standard
usage rates allows RL&F to cover adequately the monthly flat fees it must pay to these types of
providers.
8.
RL&F believes the foregoing rates are the market rates that the majority of law
firms charges clients for such services. In addition, RL&F believes that such charges are in
accordance with the American Bar Association’s (“ABA”) guidelines, as set forth in the ABA’s
Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 10 of 19

4
RLF1 28686156v.1
Statement of Principles, dated January 12, 1995, regarding billing for disbursements and other
charges.
Summary of Services Rendered
9.
The directors, counsel, and associates of RL&F who have rendered professional
services in these cases are as follows: Daniel J. DeFranceschi, Amanda R. Steele, Zachary I.
Shapiro, Cory D. Kandestin, Matthew P. Milana, Huiqi Vicky Liu, James F. McCauley, Emily R.
Mathews and Ashly L. Riches. The paraprofessionals of RL&F who have provided service to these
attorneys in these cases are as follows: Barbara J. Witters, M. Lynzy McGee and Rebecca V.
Speaker.
10.
RL&F, by and through the above-named persons, has prepared and/or assisted in
the preparation of various applications and orders submitted to the Court for consideration, advised
the Debtors on a regular basis with respect to various matters in connection with these cases, and
has performed all necessary professional services which are described and narrated in detail
hereinafter.
Summary of Services By Project
11.
The services rendered by RL&F during the Compensation Period can be grouped
into the categories set forth below. These categories are generally described below, with a more
detailed identification of the actual services provided set forth on the attached Exhibit A. The
attorneys and paraprofessionals who rendered services relating to each category are identified,
along with the number of hours for each individual and the total compensation sought for each
category, in Exhibit A attached hereto.
Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 11 of 19

5
RLF1 28686156v.1
A.
Case Administration/Miscellaneous Matters
Fees: $3,525.00

Total Hours: 5.9
This category includes all matters related to filing documents with the Court,
service thereof, maintenance of calendars, communications with the U.S. Trustee, review of work
in process reports, review of notices of appearance and maintaining service lists.
B.
Creditor Inquiries
Fees: $1,370.50

Total Hours: 2.3
This category includes all matters related to responding to creditor inquiries.
C.
Meetings
Fees: $36,369.50

Total Hours: 38.9
This category includes all matters related to preparing for and attending meetings
with the Debtors, individual creditors, the U.S. Trustee and the Debtors’ other professionals.
D.
Executory Contracts/Unexpired Leases
Fees: $4,418.50

Total Hours: 6.3
This category includes all matters related to contract and lease analysis and matters
related to assumption, assignment or rejection of executory contracts and unexpired leases.
E.
Automatic Stay/Adequate Protection
Fees: $0.00

Total Hours: 0.0
This category includes all matters related to and including all motions to modify
the automatic stay, issues related to the effect of the automatic stay or pending matters, and all
other types of actions where adequate protection is the central issue.
Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 12 of 19

6
RLF1 28686156v.1
F.
Plan of Reorganization/Disclosure Statement
Fees: $145,538.00

Total Hours: 173.0
This category includes all matters related to review, formulation, negotiation,
preparation and promulgation of plans of reorganization, disclosure statements, and related
corporate documentation and research relating thereto.
G.
Use, Sale, Lease of Assets
Fees: $4,067.00

Total Hours: 5.8
This category includes all matters relating to acquisitions, dispositions and other
postpetition uses of property of the estate.
H
Cash Collateral/DIP Financing
Fees: $0.00

Total Hours: 0.0
This category includes all matters relating to negotiation and documentation of
debtor-in-possession financing and related issues.
I.
Claims Administration
Fees: $18,786.00

Total Hours: 24.8
This category includes all matters related to and including claims administration
matters and bar date matters, including claims objections and related contested matters.
J.
Court Hearings
Fees: $61,728.00

Total Hours: 81.6
This category includes all matters related to preparation for and attendance at court
hearings.
Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 13 of 19

7
RLF1 28686156v.1
K.
General Corporate/Real Estate
Fees: $0.00

Total Hours: 0.0
This category includes all matters relating to transactional, corporate governance
and related matters involving the Debtors’ business operations that are not part of a plan of
reorganization or disclosure statement.
L.
Schedules/SOFA/U.S. Trustee Reports
Fees: $2,298.50

Total Hours: 3.5
This category includes preparation of schedules and amendments, statements of
financial affairs and amendments, operating reports and other reports required by the U.S. Trustee
or the Court.
M.
Employee Issues
Fees: $0.00

Total Hours: 0.0
This category includes all matters related to employee wages, benefits, collective
bargaining issues, other employee relations matters, ERISA, and retirement benefits.
N.
Environmental
Fees: $0.00

Total Hours: 0.0
This category includes all environmental matters, other than environmental aspects
of the plan of reorganization.
O.
Tax Issues
Fees: $0.00

Total Hours: 0.0
This category includes all federal and state income, property, employment, excise
and other tax matters, other than the tax aspects of the plan of reorganization.
Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 14 of 19

8
RLF1 28686156v.1
P.
Litigation/Adversary Proceedings
Fees: $25,107.00

Total Hours: 28.0
This category includes all matters related to litigation and adversary proceedings.
Q-1.
RL&F Applications
Fees: $0.00

Total Hours: 0.0
This category includes all matters related to preparing applications to retain RL&F
and supplements thereto.
Q-2.
Retention of Others
Fees: $3,370.50

Total Hours: 5.5
This category includes time spent reviewing applications for retention of other
professionals, objecting to the retention of other professionals and assisting other professionals
with preparing and filing retention applications.
R-1.
RL&F Fee Applications
Fees: $8,802.00

Total Hours: 14.0
This category includes all time spent preparing, reviewing, filing and circulating
monthly invoices and fee applications for RL&F.
R-2.
Fee Applications of Others
Fees: $8,293.00

Total Hours: 14.8
This category includes time spent reviewing invoices or applications of other
professionals, objecting to fees of other professionals and assisting other professionals with filing
and circulating monthly invoices and applications.
Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 15 of 19

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RLF1 28686156v.1
S.
Vendor/Suppliers
Fees: $0.00

Total Hours: 0.0
This category includes all matters related to vendors and suppliers, including
reclamation issues.
T.
Non-Working Travel
Fees: $0.00

Total Hours: 0.0
This category includes all travel time not otherwise chargeable.
U.
Utilities
Fees: $0.00

Total Hours: 0.0
This category includes all matters related to utility issues.
V.
Insurance
Fees: $0.00

Total Hours: 0.0
This category includes all matters related to insurance policies or coverage.
Valuation of Services
12.
Attorneys and paraprofessionals of RL&F have expended a total of 404.4 hours in
connection with this matter during the Compensation Period, as follows:
ATTORNEYS

HOURS
HOURLY RATE

Daniel J. DeFranceschi

7.0

$1,300

Amanda R. Steele

77.3

$995

Zachary I. Shapiro

132.5
$995

Zachary I. Shapiro

0.2

$850

Cory D. Kandestin

1.2

$875

Matthew P. Milana

75.4

$675

Huiqi Vicky Liu

53.6

$595

James F. McCauley

0.5

$595

Emily R. Mathews

0.5

$550

Ashly L. Riches

1.4

$495

Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 16 of 19

10
RLF1 28686156v.1

PARAPROFESSIONALS

HOURS
HOURLY RATE

Barbara J. Witters

2.7

$375

M. Lynzy McGee

44.5

$375

Rebecca V. Speaker

7.6

$375

The nature of the work performed by these persons is fully set forth in Exhibit A attached hereto.
These are RL&F’s normal hourly rates for work of this character. The reasonable value of the
services rendered by RL&F to the Debtors during the Compensation Period is $323,673.50.
13.
In accordance with the factors enumerated in Section 330 of the Bankruptcy Code,
it is respectfully submitted that the amount requested by RL&F is fair and reasonable given (a) the
complexity of these cases, (b) the time expended, (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. Moreover, RL&F has reviewed the requirements of Local Rule 2016-2 and believes that
this Application complies with that Rule.
WHEREFORE, RL&F respectfully requests that the Court authorize that for the
Compensation Period, an allowance be made to RL&F pursuant to the terms of the Interim
Compensation Order, with respect to the sum of $323,673.50 as compensation for necessary
professional services rendered (80% of which equals $258,938.80), and the sum of $10,333.27 as
100% reimbursement of actual necessary costs and expenses, for a total of $334,006.77 and that
such sums be authorized for payment and for such other and further relief as this Court may deem
just and proper.
Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 17 of 19

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RLF1 28686156v.1
Dated:
March 8, 2023

Wilmington, Delaware
/s/ Amanda R. Steele
RICHARDS, LAYTON & FINGER, P.A.
Daniel J. DeFranceschi, Esq. (No. 2732)
Amanda R. Steele (No. 5530)
Zachary I. Shapiro (No. 5103)
Matthew P. Milana (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

Attorneys for the Debtors and Debtors in
Possession

Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 18 of 19

RLF1 28686156v.1
CERTIFICATION OF COMPLIANCE WITH DEL. BANKR. L.R. 2016-2

I, Amanda R. Steele, on this 8th day of March, 2023, certify as follows:
a)
I am director with the applicant firm, Richards, Layton & Finger, P.A.,
(“RL&F”) and have been admitted to appear before this Court.
b)
I have personally performed many of the legal services rendered by RL&F,
as counsel to the Debtors, and am thoroughly familiar with the other work performed on behalf of
the Debtors by the lawyers and other professionals of RL&F.
c)
I have reviewed the foregoing Application 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 Application substantially complies with such rule.

/s/ Amanda R. Steele

Amanda R. Steele (No. 5530)
Case 22-10951-CTG Doc 621 Filed 03/08/23 Page 19 of 19

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Monthly Fee Application (Richards Layton & Finger — January 2023) — In re KServicing

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