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Notice of Agenda of Matters Scheduled for… — In re KServicing Wind Down Corp., et al. (f/k/a Kabbage, Inc.… (Dkt. 41)

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A notice of the filing of bankruptcy petitions and agenda for the first day hearing in In re 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 October 4, 2022 as Doc 41. It states the debtors filed voluntary chapter 11 petitions on October 3, 2022 and lists the six debtor entities. The agenda lists the first day declaration and first day motions on joint administration, cash management, prepetition taxes, wages, utilities, insurance, servicing activities and the appointment of Omni Agent Solutions, Inc. as claims and noticing agent, each with its docket number. It schedules the hearing by Zoom for October 6, 2022 at 9:30 a.m. before Judge Craig T. Goldblatt. Richards, Layton & Finger, P.A. and Weil, Gotshal & Manges LLP sign as proposed attorneys for the debtors.

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No. 22-10951 · Doc. 41 · Docket on CourtListener

Full text

                   Case 22-10951-CTG              Doc 41       Filed 10/04/22        Page 1 of 4




                               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
                                                             :         (Joint Administration Requested)
------------------------------------------------------------ x

    NOTICE OF (I) FILING OF BANKRUPTCY PETITIONS AND RELATED
   DOCUMENTS AND (II) AGENDA FOR HEARING ON FIRST DAY MOTIONS
SCHEDULED FOR OCTOBER 6, 2022 AT 9:30 A.M. (EASTERN TIME), BEFORE THE
 HONORABLE CRAIG T. GOLDBLATT, AT THE UNITED STATES BANKRUPTCY
             COURT FOR THE DISTRICT OF DELAWARE 2


          THE REMOTE HEARING WILL BE CONDUCTED ENTIRELY BY ZOOM
           AND REQUIRES ALL PARTICIPANTS TO REGISTER IN ADVANCE.
                  COURTCALL WILL NOT BE USED TO DIAL IN.

        PLEASE USE THE FOLLOWING LINK TO REGISTER FOR THE HEARING:

       https://debuscourts.zoomgov.com/meeting/register/vJIscOmqrjopEgowpay0iWsy3su4azEcW3A

        PLEASE REGISTER NO LATER THAN OCTOBER 5, 2022 AT 4:00 P.M. (ET)

       ONCE REGISTERED, PARTIES WILL RECEIVE A CONFIRMATION EMAIL
        CONTAINING PERSONAL LOG-IN INFORMATION FOR THE HEARING.


        PLEASE TAKE NOTICE that on October 3, 2022, the above-captioned debtors and
debtors in possession (collectively, the “Debtors”) filed the following voluntary petitions
(collectively, the “Petitions”) for relief under chapter 11 of title 11 of the United States Code, 11
U.S.C. §§ 101-1532:


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
    All motions and other pleadings referenced herein are available online at the following address:
    https://omniagentsolutions.com/kservicing.



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                   Case 22-10951-CTG      Doc 41        Filed 10/04/22   Page 2 of 4




A.       Voluntary Petitions:

         1.        Kabbage, Inc. d/b/a KServicing

         2.        Kabbage Canada Holdings, LLC

         3.        Kabbage Asset Securitization LLC

         4.        Kabbage Asset Funding 2017-A LLC

         5.        Kabbage Asset Funding 2019-A LLC

         6.        Kabbage Diameter, LLC

      PLEASE TAKE FURTHER NOTICE that in addition to filing the Petitions, the
Debtors filed the following first day motions and related documents (collectively, the “First
Day Motions”):

B.       First Day Declaration:
         7.        Declaration of Deborah Rieger-Paganis in Support of the Chapter 11 Petitions
                   and First-Day Pleadings [Docket No. 13 – filed October 4, 2022]

C.       First Day Motions:
         8.        Motion of Debtors Pursuant for Entry of Order Directing Joint Administration
                   of Related Chapter 11 Cases [Docket No. 3 – filed October 3, 2022]

         9.        Motion of Debtors for Entry of Interim and Final Orders (I) Authorizing
                   Debtors to (A) Continue Using Existing Cash Management System, Bank
                   Accounts, and Business Forms, (B) Implement Changes to Cash Management
                   in the Ordinary Course of Business; and (II) Granting Related Relief [Docket
                   No. 12 – filed October 3, 2022]

         10.       Motion of Debtors for Entry of Interim and Final Orders Establishing
                   Notification Procedures and Approving Restrictions on Certain Transfers of
                   Interests in the Debtors [Docket No. 6 – filed October 3, 2022]

         11.       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 – filed October 3, 2022]

         12.       Motion of Debtors for Entry of Interim and Final Orders (I) Authorizing
                   Debtors to (A) Pay Prepetition Wages, Salaries, Employee Benefits, and
                   Other Compensation and (B) Maintain Employee Benefit Programs and Pay
                   Related Obligations and (II) Granting Related Relief [Docket No. 10 – filed
                   October 3, 2022]



                                                    2
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                   Case 22-10951-CTG      Doc 41      Filed 10/04/22    Page 3 of 4




         13.       Motion of Debtors for Entry of Interim and Final Orders (I) Approving
                   Debtors’ Proposed Form of Adequate Assurance of Payment to Utility
                   Providers, (II) Establishing Procedures for Resolving Objections by Utility
                   Providers, (III) Prohibiting Utility Providers from Altering, Refusing, or
                   Discontinuing Service, and (IV) Granting Related Relief [Docket No. 8 –
                   filed October 3, 2022]

         14.       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 – filed
                   October 3, 2022]

         15.       Motion of Debtors for Interim and Final Orders Authorizing Debtors to
                   (I) Continue Servicing and Subservicing Activities and (II) Perform Related
                   Obligations [Docket No. 11 – filed October 3, 2022]

         16.       Application of Debtors Pursuant to 11 U.S.C. § 105(a) and 28 U.S.C. § 156(c)
                   for Appointment of Omni Agent Solutions, Inc. as Claims and Noticing Agent
                   Effective as of the Petition Date [Docket No. 4 – filed October 3, 2022]

         17.       Motion of Debtors for Entry of an Order (I) Authorizing the Debtors to
                   (A) File and Maintain Consolidated Creditor Lists, and (B) Redact Certain
                   Personal Identification Information for Individuals, (II) Approving Special
                   Electronic Noticing Procedures, and (III) Granting Related Relief [Docket
                   No. 5 – filed October 3, 2022]

        PLEASE TAKE FURTHER NOTICE that a hearing with respect to the First Day
Motions is scheduled for October 6, 2022 at 9:30 a.m. (Eastern Time) before The Honorable
Craig T. Goldblatt, United States Bankruptcy Judge for the District of Delaware (the “First Day
Hearing”). Parties who wish to participate in the First Day Hearing may do so by joining the
Zoom hearing at the below link:
https://debuscourts.zoomgov.com/meeting/register/vJIscOmqrjopEgowpay0iWsy3su4azEcW3A.

      PLEASE TAKE FURTHER NOTICE that objections, if any, to the First Day
Motions may be made at the First Day Hearing.



                             [Remainder of page intentionally left blank]




                                                  3
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                   Case 22-10951-CTG    Doc 41     Filed 10/04/22   Page 4 of 4




Dated: October 4, 2022
       Wilmington, Delaware

                                       /s/ Matthew P. Milana
                                       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




                                               4
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