Certification of Counsel Regarding First Omnibus Order

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Certification of Counsel Regarding First Omnibus Order Awarding Interim Allowance of Compensation for Services Rendered and for Reimbursement of Expenses, Doc 675 filed March 14, 2023 in In re Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), a jointly administered Chapter 11 case, in the U.S. Bankruptcy Court for the District of Delaware. It states that the professionals listed on Exhibit A filed interim fee applications under the Interim Compensation Order entered October 21, 2022 [Docket No. 136], that the last objection deadline expired on March 6, 2023, and that no objections or responses were received. It states that a hearing to consider approval is scheduled for March 20, 2023 at 10:00 a.m. (Eastern Time), and requests entry of the proposed omnibus order. The certification is signed /s/ Matthew P. Milana of Richards, Layton & Finger, P.A.

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RLF1 28682579v.1
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 Nos. 530, 531, 532, 533, 534 & 535
------------------------------------------------------------ x

CERTIFICATION OF COUNSEL REGARDING FIRST OMNIBUS ORDER
AWARDING INTERIM ALLOWANCE OF COMPENSATION FOR SERVICES
RENDERED AND FOR REIMBURSEMENT OF EXPENSES

The undersigned hereby certifies as follows:
1.
In accordance with the Order Establishing Procedures for Interim
Compensation and Reimbursement of Expenses of Professionals, entered October 21, 2022
[Docket No. 136] (the “Interim Compensation Order”), those professionals listed on Exhibit
A attached hereto (each, an “Applicant” and collectively, the “Applicants”) filed their
respective interim fee applications [Docket Nos. 530, 531, 532, 533, 534 and 535] (the “Interim
Applications”) with the United States Bankruptcy Court for the District of Delaware (the
“Court”).
2.
Pursuant to the Interim Applications, objections to each of the Interim
Applications, if any, were to be filed and served no later than the objection deadline set forth on
each of the Interim Applications in accordance with the Interim Compensation Order (as
applicable, the “Objection Deadline”), the last of which expired on March 6, 2023.  The

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.
Case 22-10951-CTG    Doc 675    Filed 03/14/23    Page 1 of 3

2
RLF1 28682579v.1
Applicants received no objections or responses to the Interim Applications prior to the applicable
Objection Deadline.  The hearing to consider approval of the Interim Applications is currently
scheduled for March 20, 2023 at 10:00 a.m. (Eastern Time).
3.
As there are no objections to the approval of the Interim Applications,
counsel to the above-captioned debtors and debtors in possession (the “Debtors”) prepared a
proposed form of omnibus order (the “Proposed Order”) approving the Interim Applications.  A
copy of the Proposed Order is attached hereto as Exhibit A.
4.
The Proposed Order has been circulated to each Applicant and the Office
of the United States Trustee for the District of Delaware (the “U.S. Trustee”).  The Applicants
have agreed to entry of the Proposed Order, and the U.S. Trustee does not object to the entry of
the Proposed Order.
WHEREFORE, the Debtors respectfully request that the Proposed Order,
substantially in the form attached hereto as Exhibit A, be entered at the earliest convenience of
the Court.

(Remainder of Page Intentionally Left Blank)
Case 22-10951-CTG    Doc 675    Filed 03/14/23    Page 2 of 3

3

RLF1 28682579v.1
Dated: March 14, 2023
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, Esq. (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

Attorneys for Debtors
and Debtors in Possession
Case 22-10951-CTG    Doc 675    Filed 03/14/23    Page 3 of 3

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