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In re Kabbage, Inc. d/b/a KServicing — Notice of Motion to Approve Customers Bank Settlement

Date
2022-11-07

Summary

Doc 172-1, a notice of motions and hearing filed October 27, 2022 by the debtors in the Chapter 11 cases of 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 gives notice of the debtors' motion for an order approving a settlement agreement between the debtors and Customers Bank, and of a motion to shorten the notice and objection periods. If the motion to shorten is granted, a hearing will be held on November 7, 2022 before The Honorable Craig T. Goldblatt, and objections may be made by November 4, 2022. If the Court approves or denies that motion in whole or in part, parties-in-interest will receive separate notice of the Court-approved deadline and hearing date. It is signed by Zachary I. Shapiro of Richards, Layton & Finger, proposed attorneys for the debtors, with Weil, Gotshal & Manges LLP also listed.

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Full text

                 Case 22-10951-CTG              Doc 172-1        Filed 10/27/22        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)
                                                             :
                                                             : Proposed Hearing Date: Nov. 7, 2022 at 1:00 p.m. (ET)
                                                             : Proposed Obj. Deadline: Nov. 4, 2022 at 4:00 p.m. (ET)
                             1
                  Debtors.                                   :
------------------------------------------------------------ x
                                 NOTICE OF MOTIONS AND HEARING


                    PLEASE TAKE NOTICE that the debtors in possession in the above-captioned

cases (collectively, the “Debtors”) have today filed the attached Debtors’ Motion for Entry of an

Order (I) Authorizing and Approving Settlement Agreement Between Debtors and Customers Bank

and (II) Granting Related Relief (the “Motion”) with the United States Bankruptcy Court for the

District of Delaware (the “Court”).

                    PLEASE TAKE FURTHER NOTICE that contemporaneously with the filing of

the Motion, the Debtors also filed a motion to shorten the notice and objection periods with respect

to the Motion (the “Motion to Shorten”).

                    PLEASE TAKE FURTHER NOTICE that if the Court grants the relief requested

in the Motion to Shorten: (i) a hearing to consider the Motion will be held on November 7, 2022

at 1:00 p.m. (Eastern Time) before The Honorable Craig T. Goldblatt, United States Bankruptcy

Judge for the District of Delaware, at the Court, 824 North Market Street, 3rd Floor, Courtroom 7,



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 28165325v.2
               Case 22-10951-CTG      Doc 172-1     Filed 10/27/22     Page 2 of 3




Wilmington, Delaware 19801, and (ii) any responses or objections to the Motion may be made by

November 4, 2022 at 4:00 p.m. (Eastern Time).

                   PLEASE TAKE FURTHER NOTICE that if the Court approves or denies, in

whole or in part, the relief requested in the Motion to Shorten, parties-in-interest will receive

separate notice of the Court-approved objection deadline and hearing date for the Motion.




                                               2
RLF1 28165325v.2
               Case 22-10951-CTG   Doc 172-1    Filed 10/27/22   Page 3 of 3




Dated: October 27, 2022
Wilmington, Delaware
                                        /s/ Zachary I. Shapiro
                                        RICHARDS, LAYTON & FINGER, P.A.
                                        Daniel J. DeFranceschi (No. 2732)
                                        Amanda R. Steele (No. 5530)
                                        Zachary I. Shapiro (No. 5103)
                                        Matthew P. Milana (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

                                        Proposed Attorneys for Debtors
                                        and Debtors in Possession

                                        -and-

                                        WEIL, GOTSHAL & MANGES LLP
                                        Ray C. Schrock, P.C. (admitted pro hac vice)
                                        Candace M. Arthur (admitted pro hac vice)
                                        Natasha S. Hwangpo (admitted pro hac vice)
                                        Chase A. Bentley (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




                                          3
RLF1 28165325v.2


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