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RLF1 28462480v.3
Exhibit A
Proposed Order
Case 22-10951-CTG Doc 450-1 Filed 01/17/23 Page 1 of 3
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UNITED STATES BANKRUPTCY COURT
DISTRICT OF DELAWARE
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:
In re
:
Chapter 11
:
KABBAGE, INC. d/b/a KSERVICING, et al., :
Case No. 22-10951 (CTG)
:
Debtors.1
:
(Jointly Administered)
:
Re: Docket No. __
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ORDER GRANTING MOTION OF DEBTORS
FOR LEAVE TO FILE REPLY IN SUPPORT OF
DISCLOSURE STATEMENT AND SOLICITATION PROCEDURES MOTION
Upon the motion for leave (the “Motion for Leave”)2 of Kabbage, Inc. d/b/a
KServicing and its debtor affiliates, as debtors and debtors in possession in the above-captioned
chapter 11 cases (collectively, the “Debtors”), for entry of an order pursuant to Local Rule 9006-
1(d), granting the Debtors leave to file the Reply after the Reply Deadline; and good and
sufficient cause appearing therefor, all as more fully set forth in the Motion for Leave; and the
Court having jurisdiction to consider the Motion for Leave and the relief requested therein
pursuant to 28 U.S.C. §§ 157 and 1334, and the Amended Standing Order of Reference from the
United States District Court for the District of Delaware dated February 29, 2012; and
consideration of the Motion for Leave 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 for Leave having been provided to the Notice
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 respective meanings ascribed to such terms
in the Motion for Leave.
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Parties 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 for Leave; and this Court having determined that the legal and factual bases set forth in
the Motion for Leave establish just cause for the relief granted herein; and it appearing that the
relief requested in the Motion for Leave is in the best interests of the Debtors, their estates,
creditors, and all parties in interest; 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 for Leave is granted to the extent set forth herein.
2.
The Debtors are granted leave and permission to file and serve the Reply
and the Court will consider the Reply at the hearing on January 19, 2023, at 10:00 a.m.
(prevailing Eastern Time).
3.
The Debtors are authorized to take all actions necessary or appropriate to
carry out the relief granted in this Order.
4.
This Court shall retain jurisdiction to hear and determine all matters
arising from or related to the implementation, interpretation, or enforcement of this Order.
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