Motion to File Under Seal - Notice

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Notice of Motion dated December 7, 2022, filed as Doc 338-1 in In re Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), U.S. Bankruptcy Court for the District of Delaware, Chapter 11, jointly administered. It gives notice that on December 7, 2022 Customers Bank filed a motion for authorization to file Exhibits A and C of the Declaration of Alyssa White under seal, in support of its motion to compel compliance with the court-approved settlement agreement and order and to require additional adequate protection. Objections are due December 21, 2022 at 4:00 p.m., with a hearing set for January 6, 2023 at 10:00 a.m. before the Honorable Craig T. Goldblatt. The notice is signed by counsel at Sullivan Hazeltine Allinson LLC and Holland & Knight LLP.

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IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE

In re:

KABBAGE, INC. d/b/a KSERVICING, et al.,1

Debtors.
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Chapter 11

Case No. 22-10951 (CTG)

(Jointly Administered)

Hearing Date:  January 6, 2023 at 10:00 a.m.
Obj. Deadline:  December 21, 2023 at 4:00 p.m.

Related Docket No. 337

NOTICE OF MOTION

PLEASE TAKE NOTICE that, on December 7, 2022, Customers Bank (the “Movant”),
filed its Motion of Customers Bank for Authorization to File Under Seal Exhibits A and C of the
Declaration of Alyssa White in Support of the Motion of Customers Bank for Entry of an Order (I)
Compelling Compliance With Court Approved Settlement Agreement and Order; (II) Requiring
Additional Adequate Protection In Favor of Customers Bank; and (III) Granting Related Relief
(the “Motion”) with the United States Bankruptcy Court for the District of Delaware (the
“Bankruptcy Court”).
PLEASE TAKE FURTHER NOTICE that objections or responses to the Motion, if any,
must be made in writing, filed with the Bankruptcy Court, and served so as to actually be received
by the undersigned attorneys for the Movant on or before December 21, 2022 at 4:00 p.m. (the
“Objection Deadline”).

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 338-1    Filed 12/07/22    Page 1 of 2

2

PLEASE TAKE FURTHER NOTICE that a hearing with respect to the Motion, if
required, is scheduled before the Honorable Craig T. Goldblatt at the Bankruptcy Court, 824 North
Market Street, Third Floor, Courtroom #7, Wilmington, Delaware 19081 on January 6, 2023 at
10:00 a.m.
PLEASE TAKE FURTHER NOTICE THAT IF NO OBJECTION TO THE
MOTION IS TIMELY FILED BY THE OBJECTION DEADLINE IN ACCORDANCE
WITH THIS NOTICE, THE BANKRUPTCY COURT MAY GRANT THE RELIEF
REQUESTED IN THE MOTION WITHOUT FURTHER NOTICE OR HEARING.

Date: December 7, 2022

SULLIVAN • HAZELTINE • ALLINSON LLC
Wilmington, Delaware

 /s/ William A. Hazeltine

William A. Hazeltine (No. 3294)
919 North Market Street, Suite 420
Wilmington, DE 19801
Tel. (302) 428-8191
Fax (302) 428-8195
Email: whazeltine@sha-llc.com

and

HOLLAND & KNIGHT LLP
John J. Monaghan (admitted pro hac vice)
Jeremy M. Sternberg (admitted pro hac vice)
Lynne B. Xerras (pro hac vice forthcoming)
10 St. James Avenue
Boston, MA 02116
Telephone: 617-523-2700
Facsimile: 617-523-685
john.monaghan@hklaw.com
jeremy.sternberg@hkaw.com
lynne.xerras@hklaw.com

Counsel to Customers Bank
Case 22-10951-CTG    Doc 338-1    Filed 12/07/22    Page 2 of 2

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