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In re Kabbage, Inc. d/b/a KServicing — Notice of Omni Agent Solutions Third Monthly Fee Statement

Date
2022-12-01

Summary

A Notice of Fee Application filed January 30, 2023 as Doc 499-1 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 gives notice that Omni Agent Solutions filed its Third Monthly Fee Statement for December 1, 2022 through December 31, 2022. Objections must follow the Interim Compensation Order of October 21, 2022 [Docket No. 136] and be filed by 4:00 p.m. on February 20, 2023. If no objections are filed, the Applicant may file a certificate of no objection, after which the Debtors shall be authorized to pay 80% of the fees and 100% of the expenses requested without further order. The three-page notice is signed by Richards, Layton & Finger, P.A. as attorneys for the Debtors; the signature block also lists Weil, Gotshal & Manges LLP.

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Full text

                 Case 22-10951-CTG              Doc 499-1         Filed 01/30/23       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)
                                                             :
                                                             :         (Jointly Administered)
                             1
                  Debtors.                                   :
                                                             :         Obj. Deadline: Feb. 20, 2023 at 4:00 p.m. (ET)
------------------------------------------------------------ x

                                     NOTICE OF FEE APPLICATION

                    PLEASE TAKE NOTICE that Omni Agent Solutions (the “Applicant”) has

today filed the attached Third Monthly Fee Statement of Omni Agent Solutions for Payment of

Compensation and Reimbursement of Expenses for Period December 1, 2022 through

December 31, 2022 (the “Application”) with the United States Bankruptcy Court for the District

of Delaware (the “Court”).

                    PLEASE TAKE FURTHER NOTICE that objections to the Application, if any,

must be made in accordance with the Order Establishing Procedures for Interim Compensation

and Reimbursement of Expenses of Professionals, dated October 21, 2022 [Docket No. 136] (the

“Interim Compensation Order”) and must be filed with the Clerk of the Court, 824 North

Market Street, 3rd Floor, Wilmington, Delaware 19801 no later than 4:00 p.m. (prevailing

Eastern Time) on February 20, 2023 (the “Objection Deadline”) and served upon and

received by: (i) the Debtors, c/o Kabbage, Inc. d/b/a KServicing, 925B Peachtree Street NE,

Suite       383,      Atlanta,      GA       30309       (Attn:     Holly      Loiseau,       General       Counsel


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 28540172v.1
               Case 22-10951-CTG         Doc 499-1      Filed 01/30/23        Page 2 of 3




(hloiseau@kservicecorp.com)); (b) counsel for the Debtors, (i) Weil, Gotshal & Manges LLP,

767 Fifth Avenue, New York, NY 10153 (Attn: Candace M. Arthur (candace.arthur@weil.com),

Natasha       S.     Hwangpo      (natasha.hwangpo@weil.com),           and    Chase     A.   Bentley

(chase.bentley@weil.com)) and (ii) Richards, Layton & Finger, P.A., One Rodney Square, 920

North      King      Street,   Wilmington,   DE       19801    (Attn:     Daniel    J.   DeFranceschi

(defranceschi@rlf.com), Amanda R. Steele (steele@rlf.com), and Zachary I. Shapiro

(shapiro@rlf.com)); and (c) the Office of the United States Trustee for the District of Delaware,

844 King Street, Suite 2207, Wilmington, DE 19801 (Attn: Richard L. Schepacarter

(richard.schepacarter@usdoj.gov) and Rosa Sierra-Fox (rosa.sierra-fox@usdoj.gov)).

                   PLEASE TAKE FURTHER NOTICE that if no objections to the Application are

filed prior to the Objection Deadline, the Applicant may file a certificate of no objection with the

Court, after which the Debtors shall be authorized by the Interim Compensation Order to pay the

Applicant an amount equal to 80% of the fees and 100% of the expenses requested in the

Application without the need for further order of the Court.

                   PLEASE TAKE FURTHER NOTICE that if an objection to the Application is

filed prior to the Objection Deadline, the Debtors shall be authorized by the Interim

Compensation Order to pay the Applicant 80% of the fees and 100% of the expenses requested

in the Application not subject to such objection without the need for further order of the Court.




                                                  2
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               Case 22-10951-CTG   Doc 499-1   Filed 01/30/23    Page 3 of 3




Dated: January 30, 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




                                           3
RLF1 28540172v.1


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