United States Bankruptcy Court for the District of Delaware — In re: Kabbage, Case 22-10951-CTG, Doc 336-1

Summary

Notice of Motion, Doc 336-1 in Case No. 22-10951 (CTG), the jointly administered chapter 11 cases of Kabbage, Inc. d/b/a KServicing, et al., in the U.S. Bankruptcy Court for the District of Delaware, filed December 7, 2022. The notice states that on December 7, 2022, Customers Bank filed a motion for an order compelling compliance with a Court Approved Settlement Agreement and Order and requiring additional adequate protection in favor of Customers Bank. It sets a hearing before the Honorable Craig T. Goldblatt on January 6, 2023 at 10:00 a.m. The notice states that if no objection is timely filed, the court may grant the relief requested without further notice or hearing. It is signed by William A. Hazeltine as counsel to Customers Bank.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

                 Case 22-10951-CTG       Doc 336-1      Filed 12/07/22     Page 1 of 2




                       IN THE UNITED STATES BANKRUPTCY COURT
                            FOR THE DISTRICT OF DELAWARE

    In re:                                             )   Chapter 11
                                                       )
    KABBAGE, INC. d/b/a KSERVICING, et al.,1           )   Case No. 22-10951 (CTG)
                                                       )
                                 Debtors.              )   (Jointly Administered)
                                                       )
                                                       )   Hearing Date: January 6, 2023 at 10:00 a.m.
                                                       )   Obj. Deadline: December 21, 2023 at 4:00 p.m.

                                      NOTICE OF MOTION

             PLEASE TAKE NOTICE that, on December 7, 2022, Customers Bank (the “Movant”),

filed its 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”).

             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




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 336-1       Filed 12/07/22   Page 2 of 2




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




                                            2


File and source

File

gov.uscourts.deb.188293.336.1.pdf

Size

143,049 bytes

SHA-256

d641b620225b19a3204ff49735db9e96352d1fa27c87819117753adb8171d133

Our copy

gov.uscourts.deb.188293.336.1.pdf

Original

archive.org