Court filing
Certificate of No Objection Regarding Motion… — In re KServicing Wind Down Corp., et al. (f/k/a Kabbage,… (Dkt. 126)
Summary
A certificate of no objection filed October 20, 2022 as Doc 126 in the jointly administered Chapter 11 cases of Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), in the United States Bankruptcy Court for the District of Delaware. It certifies that the debtors received no answer, objection or other responsive pleading to their motion for interim and final orders authorizing them to pay certain prepetition taxes and assessments, filed October 3, 2022 as Docket No. 9. The certificate states that objections to the final relief were due by October 19, 2022 at 4:00 p.m. under the interim order and notice at Docket No. 70 and Docket No. 79. It asks the court to enter an order substantially in the form attached as Exhibit A. The three-page filing is signed by debtors' counsel at Richards, Layton & Finger, P.A., with Weil, Gotshal & Manges LLP as proposed attorneys for the debtors.
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No. 22-10951 · Doc. 126 · Docket on CourtListener
Full text
Case 22-10951-CTG Doc 126 Filed 10/20/22 Page 1 of 3
UNITED STATES BANKRUPTCY COURT
DISTRICT OF DELAWARE
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In re : Chapter 11
:
KABBAGE, INC. d/b/a KSERVICING, et al., : Case No. 22-10951 (CTG)
:
:
1
Debtors. : (Jointly Administered)
:
: Re: Docket Nos. 9, 70 & 79
------------------------------------------------------------ x
CERTIFICATE OF NO OBJECTION REGARDING MOTION OF
DEBTORS FOR ENTRY OF INTERIM AND FINAL ORDERS
(I) AUTHORIZING DEBTORS (A) TO PAY CERTAIN PREPETITION
TAXES AND ASSESSMENTS AND (B) 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
Debtors (A) to Pay Certain Prepetition Taxes and Assessments and (B) Granting Related Relief
[Docket No. 9] (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
(A) to Pay Certain Prepetition Taxes and Assessments and (B) Granting Related Relief [Docket
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.
RLF1 28121334v.1
Case 22-10951-CTG Doc 126 Filed 10/20/22 Page 2 of 3
No. 70] and the Notice of (A) Entry of Interim Order (I) Authorizing Debtors (A) to Pay Certain
Prepetition Taxes and Assessments and (B) Granting Related Relief; and (B) Final Hearing
Thereon [Docket No. 79], 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 28121334v.1
Case 22-10951-CTG Doc 126 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
RLF1 28121334v.1
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