Court filing
Certificate of No Objection Regarding Motion… — In re KServicing Wind Down Corp., et al. (f/k/a Kabbage,… (Dkt. 125)
Summary
A certificate of no objection filed October 20, 2022 as Doc 125 in In re Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), the jointly administered chapter 11 cases in the United States Bankruptcy Court for the District of Delaware. The certificate states that the Debtors received no answer, objection or other responsive pleading to their motion for entry of interim and final orders authorizing them to continue insurance policies and pay all obligations with respect to them, and granting related relief [Docket No. 7], filed October 3, 2022. It states that no objection appeared on the Court's docket and that any objection to the final relief was due by October 19, 2022 at 4:00 p.m. prevailing Eastern Time. It asks that an order substantially in the form attached as Exhibit A be entered. The filing is three pages.
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No. 22-10951 · Doc. 125 · Docket on CourtListener
Full text
Case 22-10951-CTG Doc 125 Filed 10/20/22 Page 1 of 3
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)
:
:
1
Debtors. : (Jointly Administered)
:
: Re: Docket Nos. 7, 72 & 81
------------------------------------------------------------ x
CERTIFICATE OF NO OBJECTION REGARDING MOTION OF DEBTORS
FOR ENTRY OF INTERIM AND FINAL ORDERS (I) AUTHORIZING (A) DEBTORS
TO CONTINUE INSURANCE POLICIES, AND (B) PAY ALL OBLIGATIONS
WITH RESPECT THERETO, AND (II) GRANTING RELATED RELIEF
The undersigned hereby certifies that 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”), have received no answer, objection or any other responsive pleading
with respect to the Motion of Debtors for Entry of Interim and Final Orders (I) Authorizing
(A) Debtors to Continue Insurance Policies, and (B) Pay All Obligations with Respect Thereto,
and (II) Granting Related Relief [Docket No. 7] (the “Motion”) filed by the Debtors with the
United States Bankruptcy Court for the District of Delaware (the “Court”) on October 3, 2022.
The undersigned further certifies that no answer, objection or other responsive pleading to the
Motion has appeared on the Court’s docket in the above-captioned chapter 11 cases. Pursuant to
the Interim Order (I) Authorizing Debtors to (A) Continue Insurance Policies, and (B) Pay All
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.
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Case 22-10951-CTG Doc 125 Filed 10/20/22 Page 2 of 3
Obligations with Respect Thereto, and (II) Granting Related Relief [Docket No. 72] and the Notice
of (A) Entry of Interim Order (I) Authorizing Debtors to (A) Continue Insurance Policies, and
(B) Pay all Obligations with Respect Thereto, and (II) Granting Related Relief; and (B) Final
Hearing Thereon [Docket No. 81], any objection or response to the final relief requested in the
Motion was to be filed and served no later than October 19, 2022 at 4:00 p.m. (prevailing Eastern
Time).
WHEREFORE, the Debtors respectfully request that an order, substantially in the form
attached hereto as Exhibit A, be entered at the earliest convenience of the Court.
Dated: October 20, 2022
Wilmington, Delaware
/s/ Amanda R. Steele
RICHARDS, LAYTON & FINGER, P.A.
Daniel J. DeFranceschi, Esq. (No. 2732)
Amanda R. Steele, Esq. (No. 5530)
Zachary I. Shapiro, Esq. (No. 5103)
Matthew P. Milana, Esq. (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-
2
RLF1 28121052v.1
Case 22-10951-CTG Doc 125 Filed 10/20/22 Page 3 of 3
WEIL, GOTSHAL & MANGES LLP
Ray C. Schrock, P.C. (admitted pro hac vice)
Candace M. Arthur, Esq. (admitted pro hac vice)
Natasha S. Hwangpo, Esq. (admitted pro hac vice)
Chase A. Bentley, Esq. (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
Proposed Attorneys for Debtors
and Debtors in Possession
3
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