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Notice of Filing of Executed Wind Down Agreement — In re KServicing

Summary

A notice of filing of the executed Wind Down Agreement in In re Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), filed May 11, 2023 as Doc 814 in the United States Bankruptcy Court for the District of Delaware. The notice recites that the debtors commenced their jointly administered chapter 11 cases on October 3, 2022, that they filed a third plan supplement on March 9, 2023 attaching a revised Wind Down Agreement as Exhibit E, and that the Court entered an order confirming the plan on March 15, 2023. It states that the debtors and the Wind Down Officer entered into the Wind Down Agreement on April 28, 2023, that the agreement becomes effective only on the Effective Date, and that the Effective Date had not yet occurred. An executed copy is attached as Exhibit A and a blackline comparison as Exhibit B. The notice is three pages.

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No. 22-10951 · Doc. 814 · Docket on CourtListener

Full text

                   Case 22-10951-CTG              Doc 814       Filed 05/11/23        Page 1 of 3




                          IN THE UNITED STATES BANKRUPTCY COURT
                               FOR THE DISTRICT OF DELAWARE
---------------------------------------------------------- x
                                                           :        Chapter 11
In re                                                      :
                                                           :        Case No. 22-10951 (CTG)
KABBAGE, INC. d/b/a KSERVICING, et al., :
                                                           :        (Jointly Administered)
                                                           :
                                   1                                Re: Docket Nos. 627, 630 & 680
                        Debtors.                           :
                                                           :
---------------------------------------------------------- x

               NOTICE OF FILING OF EXECUTED WIND DOWN AGREEMENT

                    PLEASE TAKE NOTICE that on October 3, 2022, 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”), commenced cases under chapter 11 of title 11 of

the United States Code in the United States Bankruptcy Court for the District of Delaware (the

“Court”).

                    PLEASE TAKE FURTHER NOTICE that on March 9, 2023, the Debtors filed

the Notice of Filing of Third Supplement to the Amended Joint Chapter 11 Plan of Liquidation of

Kabbage, Inc. (d/b/a KServicing) and its Affiliated Debtors [Docket No. 630] (the “Third Plan

Supplement”) in connection with the Amended Joint Chapter 11 Plan of Liquidation of Kabbage,

Inc. (d/b/a KServicing) and its Affiliated Debtors [Docket No. 630] (as amended, modified, and

supplemented, the “Plan”).2 Attached as Exhibit E to the Third Plan Supplement was a revised

version of the Wind Down Agreement.


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.
2
    Capitalized terms used herein and not otherwise defined shall have the meanings given to them in the Plan.


RLF1 28889140v.2
                   Case 22-10951-CTG      Doc 814     Filed 05/11/23     Page 2 of 3




                   PLEASE TAKE FURTHER NOTICE that on March 15, 2023, the Court entered

an order [Docket No. 680] confirming the Plan. As of the date of filing of this notice, the Effective

Date has not yet occurred.

                   PLEASE TAKE FURTHER NOTICE that, on April 28, 2023, the Debtors and

Jeremiah Foster, in his capacity as the Wind Down Officer, entered into the Wind Down

Agreement. An executed copy of the Wind Down Agreement is attached hereto as Exhibit A.

Pursuant to section 1 of the Wind Down Agreement, notwithstanding that the Wind Down

Agreement was executed on April 28, 2023, the Wind Down Agreement shall only become

effective on the Effective Date. For the convenience of the Court and all parties in interest, a

blackline comparison of the executed Wind Down Agreement marked against the version of the

Wind Down Agreement that was attached to the Third Plan Supplement is attached hereto as

Exhibit B.




                             [Remainder of page intentionally left blank]




                                                  2
RLF1 28889140v.2
                   Case 22-10951-CTG   Doc 814     Filed 05/11/23    Page 3 of 3




Dated: May 11, 2023
       Wilmington, Delaware
                                                 /s/ Matthew P. Milana
                                                 RICHARDS, LAYTON & FINGER, P.A.
                                                 Daniel J. DeFranceschi (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

                                                 -and-

                                                 WEIL, GOTSHAL & MANGES LLP
                                                 Ray C. Schrock (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




                                             3
RLF1 28889140v.2


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