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Certification of Counsel Regarding Order… — In re KServicing Wind Down Corp., et al. (f/k/a Kabbage, Inc.… (Dkt. 128)

Summary

A certification of counsel regarding an order authorizing the debtors to employ and retain AlixPartners, LLP as financial advisor effective as of the petition date, in In re Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), filed October 20, 2022 as Doc 128 in the United States Bankruptcy Court for the District of Delaware. The certification states that the debtors filed the retention application on October 4, 2022 with a proposed form of order attached, and that a notice of application and hearing filed October 5, 2022 set an objection deadline of October 19, 2022 at 4:00 p.m. It states that before that deadline the debtors received informal comments from the Office of the United States Trustee for the District of Delaware. A revised proposed order is attached as Exhibit 1 and a redline comparison as Exhibit 2, and the certification asks that the revised order be entered.

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No. 22-10951 · Doc. 128 · Docket on CourtListener

Full text

                   Case 22-10951-CTG              Doc 128       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)
                                                             :
                                                             :
                  Debtors.1                                  : (Jointly Administered)
                                                             :
                                                             : Re: Docket No. 16 & 49
------------------------------------------------------------ x
                     CERTIFICATION OF COUNSEL REGARDING ORDER
  AUTHORIZING DEBTORS TO EMPLOY AND RETAIN ALIXPARTNERS, LLP AS
             FINANCIAL ADVISOR EFFECTIVE AS OF THE PETITION DATE

                    The undersigned hereby certifies as follows:

                    1.       On October 4, 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”), filed the Application of Debtors for Entry of Order Authorizing

Employment and Retention of AlixPartners, LLP as Financial Advisor to the Debtors Effective as

of the Petition Date [Docket No. 16] (the “Application”) with the United States Bankruptcy Court

for the District of Delaware (the “Court”).                  A proposed form of order granting the relief

requested in the Application was attached to the Application as Exhibit A (the “Proposed

Order”).

                    2.       Pursuant to the Notice of Application and Hearing [Docket No. 49], filed

on October 5, 2022, objections or responses to the relief requested in the Application, if any, must


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 28104492v.2
                   Case 22-10951-CTG     Doc 128      Filed 10/20/22   Page 2 of 3




be made in writing and filed with the Court on or before October 19, 2022 at 4:00 p.m. (prevailing

Eastern Time) (the “Objection Deadline”).

                   3.    Prior to the Objection Deadline, the Debtors received certain informal

comments (the “Comments”) to the relief requested in the Application from the Office of the

United States Trustee for the District of Delaware (the “U.S. Trustee”).

                   4.    To resolve the Comments, the Debtors have prepared a revised form of

Proposed Order (the “Revised Order”), attached hereto as Exhibit 1.        The Revised Order has

been circulated to the U.S. Trustee and the Federal Reserve Bank of San Francisco, and the

aforementioned parties do not object to the entry of the Revised Order. For the convenience of

the Court and all parties in interest, a redline comparison of the Revised Order marked against the

Proposed Order is attached hereto as Exhibit 2.



                            [Remainder of page intentionally left blank]




                                                  2
RLF1 28104492v.2
                   Case 22-10951-CTG        Doc 128     Filed 10/20/22   Page 3 of 3




                   WHEREFORE the Debtors respectfully request that the Revised Order 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-

                                            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 28104492v.2


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