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Further Revised Order

Date
2022-11-01

Summary

Exhibit 1, Further Revised Order, filed November 1, 2022 as Doc 190-1 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. It sets out a proposed Final Order authorizing the Debtors to pay prepetition wages, salaries, employee benefits and other compensation and to maintain employee benefit programs. The order would authorize payment of prepetition Employee Obligations not to exceed $1,070,800, with a chart allocating amounts such as $600,000 for Deferred 2020 Payroll Tax and $400,000 for Contractor Workforce Compensation. It limits payments to the statutory caps of sections 507(a)(4) and (5), excludes bonus and severance obligations other than a bonus to one eligible employee not to exceed $20,000, and makes the order effective immediately.

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               Case 22-10951-CTG     Doc 190-1   Filed 11/01/22   Page 1 of 6




                                         Exhibit 1

                                   Further Revised Order




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                            IN THE UNITED STATES BANKRUPTCY COURT
                                 FOR THE 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. 10, 75
------------------------------------------------------------ X

                  FINAL ORDER (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

                      Upon the motion, dated October 3, 2022 (the “Original Motion”) of Kabbage, Inc.

d/b/a/ KServicing and its debtor affiliates, as debtors and debtors in possession in the Chapter 11

Cases (collectively, the “Debtors”), and the supplement thereto, dated October 21, 2022 (the

“Supplement” and collectively with the Original Motion, the “Motion”)2 for entry of an order

pursuant to sections 105(a), 363(b), and 507(a) of the Bankruptcy Code and Bankruptcy Rules

6003 and 6004, (i) authorizing the Debtors to (a) pay the Employee Obligations and (b) maintain,

continue to honor, and pay amounts with respect to the Debtors’ business practices, programs, and

policies for their employees as such were in effect as of the commencement of these Chapter 11

Cases and as such may be modified during the pendency of these Chapter 11 Cases and


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
        Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to such terms in the
        Motion.




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(ii) granting related relief, all as more fully set forth in the Motion; and upon consideration of the

Rieger-Paganis Declaration; and this Court having jurisdiction to consider the Motion, and the

relief requested therein pursuant to 28 U.S.C. §§ 157 and 1334, and the Amended Standing Order

of Reference entered by the United States District Court for the District of Delaware, dated

February 29, 2012; and consideration of the Motion and the requested relief being a core

proceeding pursuant to 28 U.S.C. § 157(b); and venue being proper before this Court pursuant to

28 U.S.C. §§ 1408 and 1409; and due and proper notice of the Motion having been provided; and

such notice having been adequate and appropriate under the circumstances, and it appearing that

no other or further notice need be provided; and this Court having reviewed the Motion; and this

Court having entered an order granting the relief requested in the Motion on an interim basis; and

this Court having held a hearing to consider the relief requested in the Motion; and all objections,

if any, to the Motion having been withdrawn, resolved, or overruled; and this Court having

determined that the legal and factual bases set forth in the Motion establish just cause for the relief

granted herein; and upon all of the proceedings had before this Court and after due deliberation

and sufficient cause appearing therefor,

                   IT IS HEREBY ORDERED THAT

                   1.   The Motion is granted to the extent set forth herein.

                   2.   The Debtors are authorized, but not directed, pursuant to sections 105(a),

363(b), and 507(a) of the Bankruptcy Code, to (i) pay the prepetition Employee Obligations in an

aggregate amount not to exceed, absent further order of this Court, $1,070,800 and any related

expenses, fees and costs incident to the foregoing, and (ii) maintain, honor, and continue the

Employee Benefit Programs in the ordinary course of business, as summarized in further detail in

the chart below:




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 Employee Obligations                                   Final Amount

 Administration Fees                                    $1,000

 Compensation                                           $35,000

 Employee Bonus Program                                 $0

 Employee Benefit Programs                              $22,000

 Employer Taxes                                         $3,000

 Deferred 2020 Payroll Tax                              $600,000

 Reimbursement Programs                                 $5,000

 Contractor Workforce Compensation                      $400,000

 Employee Leave Benefits                                $0

 Health and Welfare Benefits                            $2,800

 Retirement Benefits                                    $2,000

 Total                                                  $1,070,800



                   3.   Notwithstanding any other provision of this Final Order nothing in this

Final Order shall authorize the Debtors to make any payment to, or on behalf of, any Employee or

Contractor on account of prepetition wages and other compensation obligations or other

prepetition obligations in excess of the statutory caps set forth in sections 507(a)(4) and (5) of the

Bankruptcy Code (the “Statutory Caps”); provided, however that the Debtors are authorized but

not directed to pay prepetition obligations on account of one member of the Contractor Workforce

in excess of the Statutory Caps (as applicable) as and to the extent set forth in the Supplement.

                   4.   Except as set forth in paragraph 7 of this Final Order, nothing in the Motion

or this Final Order shall be deemed to (i) authorize the payment of any amounts in satisfaction of

bonus or severance obligations, including but not limited to the KERP program or the Employee



                                                  3
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Bonus Program, or which are subject to section 503(c) of the Bankruptcy Code, including, for the

avoidance of doubt, payment of any obligations to or on behalf of any “insider” (as defined by

section 101(31) of the Bankruptcy Code) of the Debtors or any non-Debtor affiliates or violate or

permit a violation of section 503(c) of the Bankruptcy Code; or (ii) authorize the Debtors to cash

out unpaid vacation or leave time except upon termination of an employee, if applicable state law

requires such payment.

                   5.   The Banks are authorized to receive, process, honor, and pay any and all

checks issued, or to be issued, and electronic funds transfers requested, or to be requested, by the

Debtors relating to such obligations, to the extent that sufficient funds are on deposit and standing

in the Debtors’ credit in the applicable bank accounts to cover such payments. The Banks are

authorized to accept and rely on all representations made by the Debtors with respect to which

checks, drafts, wires, or automated clearing house transfers should be honored or dishonored in

accordance with this or any other order of this Court, whether such checks, drafts, wires, or

transfers are dated prior to, on, or subsequent to the Petition Date, without any duty to inquire

otherwise.

                   6.   The Debtors are authorized, but not directed, to issue new post-petition

checks, or effect new electronic funds transfers, and to replace any prepetition checks or electronic

fund transfer requests that may be lost or dishonored or rejected as a result of the commencement

of the Debtors’ Chapter 11 Cases with respect to any prepetition amounts that are authorized to be

paid pursuant to this Final Order.

                   7.   The Debtors are authorized, but not directed, to honor bonuses to one (1)

eligible Employee pursuant to the Employee Bonus Program, in an amount not to exceed $20,000.




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                   8.    The Debtors are authorized, but not directed, to continue to retain and pay

the Contractor Workforce through the Employment Vendors in the ordinary course of business as

provided for in the Motion. For the avoidance of doubt, nothing in this Final Order authorizes the

Debtors to retain and pay any professional, executive officer or director in violation of sections

327, 328 or 363 of the Bankruptcy Code.

                   9.    Nothing contained in the Motion or this Final Order, nor any payment made

pursuant to the authority granted by this Final Order, is intended to be or shall be construed as an

approval, assumption, adoption, or rejection of any agreement, contract, lease, program, or policy

between the Debtors and any third party under section 365 of the Bankruptcy Code.

                   10.   Nothing in this Final Order shall implicitly or expressly approve or sanction

any current or prospective incentive bonus, key employee incentive or retention program, or any

payment having been made in relation to or pursuant thereto.

                   11.   Notice of the Motion is adequate under Bankruptcy Rule 6004(a).

                   12.   Notwithstanding the provisions of Bankruptcy Rule 6004(h), this Final

Order shall be immediately effective and enforceable upon its entry.

                   13.   The Debtors are authorized to take all actions necessary or appropriate to

effectuate the relief granted in this Final Order.

                   14.   This Court shall retain jurisdiction to hear and determine all matters arising

from or related to the implementation, interpretation, or enforcement of this Final Order.




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