Pandemic Darlings The pandemic economy, in original documents
Home Court filings Kservicing Bankruptcy Monthly Fee Statement (Omni Agent Solutions, Sixth) — In re KServicing

Court filing

Monthly Fee Statement (Omni Agent Solutions, Sixth) — In re KServicing

Summary

The sixth monthly fee statement of Omni Agent Solutions, administrative agent for the debtors, 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, filed May 8, 2023 as Doc 807. It covers the period from March 1, 2023 through March 31, 2023 and seeks $4,325.48, or 80% of $5,406.85 in fees, with $0.00 in expenses. A summary table lists prior monthly applications totaling $53,650.00 in requested fees, and a compensation table lists 31.0 hours, all in the Balloting category, for preparing plan solicitation and tabulation. The statement sets an objection deadline of May 30, 2023 at 4:00 p.m. (ET). It is ten pages and closes with a supporting declaration of Omni's executive vice president.

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

No. 22-10951 · Doc. 807 · Docket on CourtListener

Full text

                   Case 22-10951-CTG            Doc 807        Filed 05/08/23        Page 1 of 10




                               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: May 30, 2023 at 4:00 p.m. (ET)


                SUMMARY OF SIXTH MONTHLY FEE STATEMENT
        OF OMNI AGENT SOLUTIONS FOR PAYMENT OF COMPENSATION AND
       REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM MARCH 1, 2023
                         THROUGH MARCH 31, 2023


    Name of Applicant:                                         Omni Agent Solutions

    Authorized to Provide Professional Services to:            Debtors and Debtors in Possession

    Date of Retention:                                         October 3, 2022

    Period for which compensation and
    reimbursement are sought:                                  March 1, 2023 through March 31, 2023

    Amount of compensation sought as actual,
    reasonable, and necessary:                                 $4,325.48 (80% of $5,406.85)
    Amount of expense reimbursement sought as
    actual, reasonable, and necessary:                         $0.00


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 98919797V.2
                   Case 22-10951-CTG           Doc 807          Filed 05/08/23    Page 2 of 10


      Prior Monthly Applications:

                Date
                                      Requested     Requested                     Paid
             Filed/Dkt.   Period                                   Paid Fees                Outstanding
                                        Fees          Costs                     Expenses
                 No.
                           10/3/22
              12/2/22
                              -        $5,083.50           $0.00   $4,066.80       $0.00       $1,016.70
              No. 324
                          10/31/22
                           11/1/22
              12/29/22
                              -        $8,751.50           $0.00   $7,001.20       $0.00       $1,750.30
              No. 390
                          11/30/22
                           12/1/22
             1/30/2023
                              –        $3,965.25           $0.00   $3,172.20       $0.00        $793.05
              No.499
                          12/31/22
              3/3/2023    1/1/23 -
                                      $28,394.25           $0.00 $22,715.40        $0.00       $5,678.85
              No. 602      1/31/23
              3/29/23     2/2/23 –
                                       $7,455.50           $0.00   $5,964.40       $0.00       $1,491.10
                737       2/28/23
              TOTAL                   $53,650.00           $0.00 $42,920.00        $0.00      $10,730.00



                               COMPENSATION BY PROFESSIONAL
                              MARCH 1, 2023 THROUGH MARCH 31, 2023

The Omni professionals who rendered services in these chapter 11 cases from March 1, 2023 through
March 31, 2023 (the “Fee Period”) are:

                         Professional          Hours               Rate              Total
                    Ashley Dionisio             0.3                  $130.00             $39.00
                    Carolyn Cashman             0.2                  $150.00             $30.00
                    David Neece                 0.3                  $139.50             $41.85
                    Emma Guandique              2.4                  $100.00           $240.00
                    Javon Couch                 0.2                  $130.00             $26.00
                    Jennifer Lizakowski         1.0                  $150.00            $150.00
                    Jeriad Paul                 6.1                  $187.50          $1,143.75
                    Kim Steverson               16.1                 $187.50          $3,018.75
                    Michelle Ignacio            3.7                  $175.00           $647.50
                    Paula Gray                     0.7                $100.00              $70.00
                                     TOTAL         31.0             ----              $5,406.85



                             COMPENSATION BY PROJECT CATEGORY
                             MARCH 1, 2023 THROUGH MARCH 31, 2023

                               Category                   Hours            Fees
                             Balloting                     31.0            $5,406.85
                                    TOTAL                  31.0            $5,406.85


                                                            2
                  Case 22-10951-CTG             Doc 807        Filed 05/08/23        Page 3 of 10




                               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: May 30, 2023 at 4:00 p.m. (ET)


                      SIXTH MONTHLY FEE STATEMENT
        OF OMNI AGENT SOLUTIONS FOR PAYMENT OF COMPENSATION AND
       REIMBURSEMENT OF EXPENSES FOR THE PERIOD FROM MARCH 1, 2023
                          THROUGH MARCH 31, 2023


                    Omni Agent Solutions (“Omni” or the “Firm”), administrative agent 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 March 1, 2023 through and including March 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



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 807        Filed 05/08/23        Page 4 of 10




Court’s Order Establishing Procedures for Interim Compensation and Reimbursement of

Expenses of Professionals [Docket No. 136] (the “Interim Compensation Order”). In support

of this Fee Statement, Omni 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] (the “First Day Declaration”).2

                    4.       This Court authorized Omni’s retention as administrative agent for the

Debtors pursuant to the Order Authorizing Debtors to Employ and Retain Omni Agent Solutions,

Inc. as Administrative Agent Effective as of the Petition Date [Docket No. 138] (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


2
    Capitalized terms used but not defined herein shall have the respective meanings ascribed to such terms in the First
    Day Declaration.



                                                            2
             Case 22-10951-CTG           Doc 807     Filed 05/08/23     Page 5 of 10




District Court for the District of Delaware, dated February 29, 2012. This is a core proceeding

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, Omni requests allowance and payment of $4,325.48

(80% of $5,406.85) as compensation for professional services rendered to the Debtors during the

Fee Period and allowance and payment of $0.00 as reimbursement for actual and necessary

expenses incurred by Omni during the Fee Period. All services for which compensation is

requested by Omni were performed for or on behalf of the Debtors.

               8.      During the Fee Period, Omni received no payment and no promises of

payment from any source other than the Debtors 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 Omni and any other person, other than members of Omni,

for the sharing of compensation to be received for services rendered in these Chapter 11 Cases.

               9.      The fees charged by Omni 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.     Omni maintains computerized records of the time spent by all Omni

professionals in connection with the Firm’s representation of the Debtors. Annexed hereto as




                                                 3
                  Case 22-10951-CTG             Doc 807       Filed 05/08/23        Page 6 of 10




Exhibit A are copies of Omni’s itemized time records for professionals performing services for

the Debtors during the Fee Period. Omni’s time records comply with the requirements set forth in

Local Rule 2016-2.

                                              Summary of Services

                    11.     The following is a summary of the significant professional services

rendered by Omni during the Fee Period. This summary is organized in accordance with the

internal system of task codes set up by Omni at the outset of these Chapter 11 Cases.3 If a task

code does not appear below, then Omni 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.      Balloting
                            Fees: $5,406.85; Total Hours: 31.0

                                This category includes all services provided by Omni in
                                 preparation of the anticipated solicitation and tabulation of the
                                 Debtors’ plan and disclosure statement, including the preparation
                                 of a plan/class report and eballoting portal.

                    12.     The foregoing professional services performed by Omni 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.     Omni did not incur any expenses during the Fee Period.




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.



                                                          4
             Case 22-10951-CTG          Doc 807     Filed 05/08/23     Page 7 of 10




                                     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 Omni 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, Omni 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.

       WHEREFORE Omni respectfully requests (a) interim allowance of compensation for

professional services rendered to the Debtors during the Fee Period in the amount of $5,406.85

and for expenses incurred by Omni during the Fee Period in the amount of $0.00; (b) that, in

accordance with the Interim Compensation Order, the Debtors pay Omni a total of $4,325.48

consisting of fees of $4,325.48 (representing 80% of the total amount of fees allowed) and $0.00

(representing 100% of the expenses allowed), if no objections are timely filed and Omni 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 Omni’s right to




                                                5
             Case 22-10951-CTG          Doc 807       Filed 05/08/23    Page 8 of 10




seek such further compensation for the full value of services performed and expenses incurred;

and (d) that the Court grant Omni such other and further relief as is just.


Dated: May 8, 2023
       New York, New York

                                      /s/ Paul H. Deutch
                                      Paul H. Deutch
                                      Omni Agent Solutions
                                      1120 Avenue of the Americas, 4th Fl
                                      New York, NY 10035
                                      212-302-3580
                                      pdeutch@omniagnt.com

                                      Administrative Agent for Debtors
                                      and Debtors in Possession




                                                  6
                  Case 22-10951-CTG             Doc 807        Filed 05/08/23        Page 9 of 10




                               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 PAUL H. DEUTCH

                    I, Paul H. Deutch, hereby declare the following under penalty of perjury:

                    1.      I am the Executive Vice President of the applicant firm, Omni (“Omni” or

the “Firm”).

                    2.      I am familiar with the services rendered by Omni Agent Solutions as

Administrative Agent to the Debtors as set forth in the Sixth Monthly Fee Statement of Omni

Agent Solutions for Payment of Compensation and Reimbursement of Expenses for Period From

March 1, 2023 Through and Including March 31, 2023.

                    3.      I have reviewed the foregoing Sixth Monthly 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




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 807       Filed 05/08/23   Page 10 of 10




such rule.

 Dated: May 8, 2023
        New York, New York                 /s/ Paul H. Deutch
                                           Paul H. Deutch




                                           2


File and source

File
gov.uscourts.deb.188293.807.0.pdf
Size
340,808 bytes
SHA-256
533c9fd126b5d0f0b3902bf31033816f2cd5018e428735029df7a02c83bc102a
Our copy
gov.uscourts.deb.188293.807.0.pdf
Original
archive.org
Back to top