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Home Source documents Order Granting Debtors’ First Omnibus

Order Granting Debtors’ First Omnibus

Date
2023-02-16

Summary

Doc 542-1 in In re Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), in the U.S. Bankruptcy Court for the District of Delaware, filed February 16, 2023, is Exhibit A, an order granting the debtors' First Omnibus Objection (Substantive) to Certain Misclassified Claims, referencing Docket No. 491. The order text reclassifies claims listed on Schedule 1, Schedule 2 and Schedule 3 as general unsecured claims and overrules unresolved responses. It treats each objection as a separate contested matter, preserves the debtors' rights to further objections, and authorizes the debtors and Omni Agent Solutions to modify the claims register. Schedule 1 lists misclassified priority claims with claim numbers, amounts and the debtors' stated reason, generally that the claimant is a borrower on a loan the debtors service. The 20-page filing closes with secured claims of $11,000,000.00.

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 542-1   Filed 02/16/23   Page 1 of 20




                                     EXHIBIT A




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                               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)
                                                             :
                                                             :
                                    1
                         Debtors.                            :       (Jointly Administered)
                                                             :
                                                                     Re: Docket No. 491
------------------------------------------------------------ x

                   ORDER GRANTING DEBTORS’ FIRST OMNIBUS
           OBJECTION (SUBSTANTIVE) TO CERTAIN MISCLASSIFIED CLAIMS

                    Upon the Debtors’ First Omnibus Objection (Substantive) to Certain Misclassified

Claims (the “Objection”)2 of Kabbage, Inc. d/b/a KServicing and its debtor affiliates, as debtors

and debtors in possession in the Chapter 11 Cases (collectively, the “Debtors”), for entry of an

order pursuant to section 502 under title 11 of the United States Code (the “Bankruptcy Code”),

Rule 3007 of the Federal Rules of Bankruptcy Procedures (the “Bankruptcy Rules”), and Rule

3007-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy

Court for the District of Delaware (the “Local Rules”), (i) reclassifying the Misclassified Priority

Claims as general unsecured claims, (ii) reclassifying the Misclassified Administrative Expense

Claims as general unsecured claims, (iii) reclassifying the Misclassified Secured Claims as general




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 Objection.




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unsecured claims, and (iv) granting related relief, all as more fully set forth in the Objection; and

this Court having jurisdiction to consider the Objection and the relief requested therein pursuant

to 28 U.S.C. §§ 157(a)–(b) and 1334(b) and the Amended Standing Order of Reference from the

United States District Court for the District of Delaware, dated February 29, 2012; and upon

consideration of the Objection 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 Objection having been provided; 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 held a hearing to consider the relief requested in

the Objection (the “Hearing”), if necessary; and upon the record of the Hearing; and this Court

having determined that the legal and factual bases set forth in the Objection establish just cause

for the relief granted herein; and it appearing that the relief requested in the Objection is in the best

interests of the Debtors, their estates, creditors, and all parties in interest; and upon all of the

proceedings had before the Court and after due deliberation and sufficient cause appearing

therefor,

                   IT IS HEREBY ORDERED THAT:

                   1.   The Objection is granted to the extent set forth herein.

                   2.   Each proof of claim listed under the heading “Misclassified Priority

Claims” on Schedule 1 annexed hereto is hereby reclassified as set forth on Schedule 1 under the

column “Modified Classification Status”.

                   3.   Each proof of claim listed under the heading “Misclassified Administrative

Expense Claims” on Schedule 2 annexed hereto is hereby reclassified as set forth on Schedule 2

under the column “Modified Classification Status”.




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                   4.   Each proof of claim listed under the heading “Misclassified Secured

Claims” on Schedule 3 annexed hereto is hereby reclassified as set forth on Schedule 3 under the

column “Modified Classification Status”.

                   5.   Any Response to the Objection not otherwise withdrawn, resolved, or

adjourned is hereby overruled on the merits.

                   6.   The objections by the Debtors to the Misclassified Claims, as addressed in

the Objection and the schedules hereto, constitute a separate contested matter with respect to each

such proof of claim, as contemplated by Bankruptcy Rule 9014 and Local Rule 3007-1. This Order

shall be deemed a separate Order with respect to each Misclassified Claim.

                   7.   Any stay of this Order pending appeal by any holder of a Misclassified

Claim or any other party with an interest in such claims that are subject to this Order shall only

apply to the contested matter which involves such party and shall not act to stay the applicability

and/or finality of this Order with respect to the other contested matters arising from the Objection

or this Order.

                   8.   This Order has no res judicata, estoppel, or other effect on the validity,

allowance, or disallowance of any claim referenced and/or identified in the Objection that is not

listed on Schedule 1, Schedule 2, or Schedule 3 annexed hereto as a Misclassified Priority Claim,

Misclassified Administrative Expense Claim, and a Misclassified Secured Claim, respectively, and

all rights to object or defend against such claims on any basis are expressly reserved.

                   9.   The rights of the Debtors, or any other party in interest, as applicable, to (a)

file subsequent objections to any of the Misclassified Claims on any and all substantive and/or

non-substantive grounds; (b) amend, modify, and/or supplement the Objection, including, without

limitation, the filing of objections to further amended or newly filed Claims; (c) seek expungement




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or reduction of any claim to the extent all or a portion of such claim has been paid; and (d) settle

any claim for less than the asserted amount are preserved.

                   10.   The Debtors and Omni Agent Solutions are authorized to modify the Claims

Register to comport with the entry of this Order.

                   11.   Nothing contained in the Objection or this Order, nor any payment made

pursuant to the authority granted by this Order, is intended to be or shall be construed as (a) an

admission as to the validity of any claim against the Debtors; (b) an agreement or obligation to pay

any claims; (c) a waiver of the Debtors’ or any appropriate party in interest’s rights to dispute the

amount of, basis for, or validity of any claim against the Debtors, including but not limited to, any

future objections on substantive and/or non-substantive grounds; (d) a waiver of any claim or cause

of action which may exist against any creditor or interest holder; or (e) an approval, assumption,

adoption, or rejection of any agreement, contract, lease, program, or policy between the Debtors

and any third party under section 365 of the Bankruptcy Code.

                   12.   Notwithstanding entry of this Order, nothing herein shall create, nor is

intended to create, any rights in favor of or enhance the status of any claim held by any party.

                   13.   The Debtors are authorized to take all action necessary to effectuate the

relief granted in this Order.

                   14.   The 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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                                           Schedule 1

                                  Misclassified Priority Claims




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                                                                                          Misclassified Priority Claims1
                                                                                         (Claims are listed alphabetically)

                   Claimant Name                                                            Misclassified         Modified
                                              Date Claim    Claim
     #                                                                 Debtor Name         Priority Claim       Classification                                    Reason for Reclassification
                                                Filed        No.
                                                                                              Amount               Status2
                                                                                                                                     Alicia Bryant filed a $3,466 priority claim pursuant to section 507(a)(4) of the
                                                                                                                         $0.00 (A)
                                                                                                                                     Bankruptcy Code. No basis is asserted for the claim. See proof of claim no. 951-41.
          Alicia Bryant                                                                                                  $0.00 (S)
                                                                      Kabbage, Inc.                                                  Based on a review of the Debtors’ books and records, the Debtors have determined
     1                                        11/18/2022    951-41                            $3,466.00 (P)              $0.00 (P)
                                                                      d/b/a KServicing                                               Alicia Bryant is a borrower of a PPP Loan that the Debtors service, and there are no
                                                                                                                     $3,466.00 (U)
                                                                                                                                     amounts entitled to priority due and owing to Alicia Bryant under section 507(a)(4)
                                                                                                                     $3,466.00 (T)
                                                                                                                                     (the claim is not on account of wages) of the Bankruptcy Code.
                                                                                                                                     AVDN Enterprise filed a $3,125 priority claim pursuant to an unspecified subsection
                                                                                                                         $0.00 (A)   of 507(a) of the Bankruptcy Code. The proof of claim asserts the “Paycheck
          AVDN Enterprise LLC                                                                                            $0.00 (S)   Protection Program” as the basis for the claim. See proof of claim no. 951-224. Based
                                                                      Kabbage, Inc.
     2                                        12/30/2022    951-224                           $3,125.00 (P)              $0.00 (P)   on a review of the Debtors’ books and records, the Debtors have determined AVDN
                                                                      d/b/a KServicing
                                                                                                                     $3,125.00 (U)   Enterprise is a borrower of a PPP Loan that the Debtors service, and there are no
                                                                                                                     $3,125.00 (T)   amounts entitled to priority due and owing to AVDN Enterprise under section 507(a)
                                                                                                                                     of the Bankruptcy Code.
                                                                                                                                     Charmaine Busch filed a proof of claim asserting a total claim of $30,000. The
                                                                                                                                     claimant asserts that $25,500 is entitled to priority pursuant to sections 507(a)(1)(A)
                                                                                                                                     and (a)(1)(B), 507(a)(4), 507(a)(7), and 507(a)(8) of the Bankruptcy Code. The proof
                                                                                                                                     of claim asserts “money loaned . . .” as the basis for the claim. See proof of claim no.
                                                                                                                        $0.00 (A)    951-27. Based on a review of the Debtors’ books and records, the Debtors have
          Charmaine Busch                                                                                               $0.00 (S)    determined Charmaine Busch is a borrower of a Legacy Loan that the Debtors service,
                                                                      Kabbage, Inc.
     3                                        11/5/2022     951-27                           $25,500.00 (P)             $0.00 (P)    and there are no amounts entitled to priority due and owing to Charmaine Busch under
                                                                      d/b/a KServicing
                                                                                                                   $30,000.00 (U)    sections 507(a)(1)(A) (the claim is not on account of domestic support obligations)
                                                                                                                   $30,000.00 (T)    and (a)(1)(B) (the claim is not on account of domestic support obligations), 507(a)(4)
                                                                                                                                     (the claim is not on account of wages), 507(a)(7) (the claim is not on account of a
                                                                                                                                     deposit in connection with the purchase, lease, or rental of property or purchase of
                                                                                                                                     services), 507(a)(8) (the claim is not on account of governmental units) of the
                                                                                                                                     Bankruptcy Code.
                                                                                                                                     Wellness Rehabilitation filed a $20,833 priority claim pursuant to an unspecified
                                                                                                                                     subsection of 507(a) of the Bankruptcy Code. The proof of claim asserts the “Paycheck
                                                                                                                         $0.00 (A)
          Corinthus Omari Pittman (Wellness                                                                                          Protection Program” as the basis for the claim. See proof of claim no. 951-218. Based
                                                                                                                         $0.00 (S)
          Rehabilitation LLC)                                         Kabbage, Inc.                                                  on a review of the Debtors’ books and records, the Debtors have determined Wellness
     4                                        12/19/2022    951-218                          $20,833.00 (P)              $0.00 (P)
                                                                      d/b/a KServicing                                               Rehabilitation is a borrower of a PPP Loan that the Debtors service, and there are no
                                                                                                                    $20,833.00 (U)
                                                                                                                                     amounts entitled to priority due and owing to Wellness Rehabilitation under section
                                                                                                                    $20,833.00 (T)
                                                                                                                                     507(a) of the Bankruptcy Code. Further, Wellness Rehabilitation does not provide any
                                                                                                                                     documentation in support of the claim.
          Deborah A Mastrandrea                                       Kabbage, Inc.                                      $0.00 (A)   Deborah A. Mastrandrea filed a $3,900 priority claim pursuant to section 507(a)(7) of
     5                                        11/15/2022    951-30                            $3,900.00 (P)
                                                                      d/b/a KServicing                                   $0.00 (S)   the Bankruptcy Code. The proof of claim asserts “money loaned” as the basis for the


1
    Certain of the Misclassified Priority Claims assert more than one incorrect classification status. This schedule lists only the misclassified priority amounts.
2
    (A) - Administrative, including 503(b)(9); (S) - Secured; (P) - Priority; (U) - Unsecured; (T) – Total.




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                   Claimant Name                                               Misclassified          Modified
                                   Date Claim    Claim
   #                                                        Debtor Name       Priority Claim        Classification                                      Reason for Reclassification
                                     Filed        No.
                                                                                 Amount                Status2
                                                                                                              $0.00 (P) claim. See proof of claim no. 951-30. Based on a review of the Debtors’ books and
                                                                                                         $3,900.00 (U) records, the Debtors have determined Deborah A. Mastrandrea is a borrower of a PPP
                                                                                                         $3,900.00 (T) Loan that the Debtors service, and there are no amounts entitled to priority due and
                                                                                                                        owing to Deborah A. Mastrandrea under section 507(a)(7) (the claim is not on account
                                                                                                                        of a deposit in connection with the purchase, lease, or rental of property or purchase of
                                                                                                                        services) of the Bankruptcy Code. Further, Deborah A. Mastrandrea does not provide
                                                                                                                        any documentation in support of the claim.
                                                                                                                        Kelvin Foster filed a proof of claim asserting a total claim of $3,000. The claimant
                                                                                                                        asserts that $2,000 is entitled to priority pursuant to section 507(a)(7) of the
                                                                                                                        Bankruptcy Code. The proof of claim asserts “goods sold” as the basis for the claim.
                                                                                                              $0.00 (A)
                                                                                                                        See proof of claim no. 951-231. Based on a review of the Debtors’ books and records,
        Kelvin Foster                                                                                         $0.00 (S)
                                                           Kabbage, Inc.                                                the Debtors have determined Kelvin Foster is a borrower of a PPP Loan that the
   6                               01/23/2023    951-231                         $2,000.00 (P)                $0.00 (P)
                                                           d/b/a KServicing                                             Debtors service, and there are no amounts entitled to priority due and owing to Kelvin
                                                                                                         $3,000.00 (U)
                                                                                                                        Foster under section 507(a)(7) (the claim is not on account of a deposit in connection
                                                                                                         $3,000.00 (T)
                                                                                                                        with the purchase, lease, or rental of property or purchase of services) of the
                                                                                                                        Bankruptcy Code. Further, Kelvin Foster does not provide any documentation in
                                                                                                                        support of the claim.
                                                                                                                        Lakeysha James filed a $12,708 priority claim pursuant to section 507(a)(4) of the
                                                                                                              $0.00 (A) Bankruptcy Code. The proof of claim asserts “services performed” as the basis for the
        Lakeysha James                                                                                        $0.00 (S) claim. See Proof of claim no. 951-229. Based on a review of the Debtors’ books and
                                                           Kabbage, Inc.
   7                               01/17/2023    951-229                        $12,708.00 (P)                $0.00 (P) records, the Debtors have determined Lakeysha James is a borrower of a PPP Loan that
                                                           d/b/a KServicing
                                                                                                       $12,708.00 (U) the Debtors service, and there are no amounts entitled to priority due and owing to
                                                                                                        $12,708.00 (T) Lakeysha James under section 507(a)(4) (the claim is not on account of wages) of the
                                                                                                                        Bankruptcy Code.
                                                                                                                        Lakina Evans filed two proofs of claim, each asserting a total claim of $3,216.00.
                                                                                                                        Notwithstanding the asserted total value of the claim, proof of claim no. 951-3 asserts a
                                                                                                                        $3,350 priority claim pursuant to section 507(a)(7) of the Bankruptcy Code. No basis
                                                                                                              $0.00 (A)
                                                                                                                        is asserted for the claim. See proof of claim no. 951-3. Based on a review of the
        Lakina Evans                                                                                          $0.00 (S)
                                                           Kabbage, Inc.                                                Debtors’ books and records, the Debtors have determined Lakina Evans is a borrower
   8                               10/29/2022     951-3                          $3,350.00 (P)                $0.00 (P)
                                                           d/b/a KServicing                                             of a PPP Loan that the Debtors service, and there are no amounts entitled to priority
                                                                                                         $3,216.00 (U)
                                                                                                                        due and owing to Lakina Evans under section 507(a)(7) (the claim is not on account of
                                                                                                         $3,216.00 (T)
                                                                                                                        a deposit in connection with the purchase, lease, or rental of property or purchase of
                                                                                                                        services) of the Bankruptcy Code. Further, Lakina Evans does not provide any
                                                                                                                        documentation in support of the claim.
                                                                                                                        Lakina Evans filed two proofs of claim, each asserting a total claim of $3,216.00.
                                                                                                                        Notwithstanding the asserted total value of the claim, proof of claim no. 951-4 asserts a
                                                                                                                        $3,250 priority claim pursuant to section 507(a)(7) of the Bankruptcy Code. No basis
                                                                                                              $0.00 (A)
                                                                                                                        is asserted for the claim. See proof of claim no. 951-4. Based on a review of the
        Lakina Evans                                                                                          $0.00 (S)
                                                           Kabbage, Inc.                                                Debtors’ books and records, the Debtors have determined Lakina Evans is a borrower
   9                               10/29/2022     951-4                          $3,250.00 (P)                $0.00 (P)
                                                           d/b/a KServicing                                             of a PPP Loan that the Debtors service, and there are no amounts entitled to priority
                                                                                                         $3,216.00 (U)
                                                                                                                        due and owing to Lakina Evans under section 507(a)(7) (the claim is not on account of
                                                                                                         $3,216.00 (T)
                                                                                                                        a deposit in connection with the purchase, lease, or rental of property or purchase of
                                                                                                                        services) of the Bankruptcy Code. Further, Lakina Evans does not provide any
                                                                                                                        documentation in support of the claim.




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                   Claimant Name                                               Misclassified          Modified
                                   Date Claim    Claim
   #                                                        Debtor Name       Priority Claim        Classification                                    Reason for Reclassification
                                     Filed        No.
                                                                                 Amount                Status2
                                                                                                                         Lauren Garber filed a $17,700 priority claim pursuant to sections 507(a)(4) and
                                                                                                                         507(a)(5) of the Bankruptcy Code. The proof of claim form asserts “Paycheck
                                                                                                             $0.00 (A)   Protection Program loan approved by [the] SBA” as the basis for the priority claim.
        Lauren Garber                                                                                        $0.00 (S)   See proof of claim form no. 951-153. Based on a review of the Debtors’ books and
                                                           Kabbage, Inc.
  10                               11/30/2022    951-153                        $17,700.00 (P)               $0.00 (P)   records, the Debtors have determined Lauren Garber is a borrower of a PPP Loan that
                                                           d/b/a KServicing
                                                                                                        $17,700.00 (U)   the Debtors service, and there are no amounts entitled to priority due and owing to
                                                                                                        $17,700.00 (T)   Lauren Garber under sections 507(a)(4) (the claim is not on account of wages) and
                                                                                                                         507(a)(5) (the claim is not on account of contributions to an employee benefit plan) of
                                                                                                                         the Bankruptcy Code.
                                                                                                                         Michael Hamlin filed a $13,000 priority claim pursuant to an unspecified subsection of
                                                                                                                         section 507(a) of the Bankruptcy Code. The proof of claim asserts a “foreclosure with
                                                                                                             $0.00 (A)
                                                                                                                         court agreement” as the basis for the claim. See proof of claim no. 955-2. Based on a
        Michael Hamlin                                     Kabbage Asset                                     $0.00 (S)
                                                                                                                         review of the Debtors’ books and records, the Debtors have determined Michael
  11                               11/12/2022     955-2    Funding 2019-A,      $13,000.00 (P)               $0.00 (P)
                                                                                                                         Hamlin is a borrower of a Legacy Loan that the Debtors service, and there are no
                                                           LLC                                          $13,000.00 (U)
                                                                                                                         amounts entitled to priority due and owing to Michael Hamlin under section 507(a) of
                                                                                                        $13,000.00 (T)
                                                                                                                         the Bankruptcy Code. Further, Michael Hamlin does not provide any documentation in
                                                                                                                         support of the claim.
                                                                                                                         Michael R. Hamlin filed a $500,000 priority claim pursuant to an unspecified
                                                                                                                         subsection of section 507(a) of the Bankruptcy Code. The proof of claim asserts a “lien
                                                                                                            $0.00 (A)    against property that Kabbage, Inc must [have] purchased” as the basis for the claim.
        Michael R. Hamlin                                                                                   $0.00 (S)    See proof of claim no. 951-25. Based on a review of the Debtors’ books and records,
                                                           Kabbage, Inc.
  12                               11/12/2022    951-25                        $500,000.00 (P)              $0.00 (P)    the Debtors have determined Michael R. Hamlin is a borrower of a Legacy Loan that
                                                           d/b/a KServicing
                                                                                                      $500,000.00 (U)    the Debtors service, and there are no amounts entitled to priority due and owing to
                                                                                                      $500,000.00 (T)    Michael R. Hamlin under section 507(a) of the Bankruptcy Code, and no record of the
                                                                                                                         alleged lien. Further, Michael R. Hamlin does not provide any documentation in
                                                                                                                         support of the claim.
                                                                                                                         Nicolas E. Feliz filed an $866.49 priority claim pursuant to section of 507(a)(4) of the
                                                                                                             $0.00 (A)   Bankruptcy Code. The proof of claim asserts “PPP loan paid by me to Kabbage on
        Nicolas E. Feliz                                                                                     $0.00 (S)   08/2022 . . .” as the basis for the claim. See proof of claim no. 951-23. Based on a
                                                           Kabbage, Inc.
  13                               11/8/2022     951-23                            $886.49 (P)               $0.00 (P)   review of the Debtors’ books and records, the Debtors have determined Nicolas E.
                                                           d/b/a KServicing
                                                                                                           $886.49 (U)   Feliz is a borrower of a PPP Loan that the Debtors service, and there are no amounts
                                                                                                           $886.49 (T)   entitled to priority due and owing to Nicolas E. Feliz under section 507(a)(4) (the claim
                                                                                                                         is not on account of wages) of the Bankruptcy Code.
                                                                                                                         Quyen Nguyen filed a proof of claim asserting a total claim of $3,349.27. The
                                                                                                                         claimant asserts that $3,270 is entitled to priority pursuant to section 507(a)(4) of the
                                                                                                             $0.00 (A)
                                                                                                                         Bankruptcy Code. The proof of claim form asserts “services performed” as the basis
        Quyen Nguyen                                                                                         $0.00 (S)
                                                           Kabbage, Inc.                                                 for the claim. See proof of claim no. 951-194. Based on a review of the Debtors’
  14                               12/2/2022     951-194                         $3,270.00 (P)               $0.00 (P)
                                                           d/b/a KServicing                                              books and records, the Debtors have determined Quyen Nguyen is a borrower of a PPP
                                                                                                         $3,349.27 (U)
                                                                                                                         Loan that the Debtors service, and there are no amounts entitled to priority due and
                                                                                                         $3,349.27 (T)
                                                                                                                         owing to Quyen Nguyen under section 507(a)(4) (the claim is not on account of wages)
                                                                                                                         of the Bankruptcy Code.
                                                                                                             $0.00 (A)   Rajesh Oza filed a $2,800 priority claim pursuant to section 507(a)(7) of the
        Rajesh Oza                                         Kabbage, Inc.                                     $0.00 (S)   Bankruptcy Code. No basis is asserted for the claim. See proof of claim no. 951-24.
  15                               11/15/2022    951-24                          $2,800.00 (P)
                                                           d/b/a KServicing                                  $0.00 (P)   Based on a review of the Debtors’ books and records, the Debtors have determined
                                                                                                         $2,800.00 (U)   Rajesh Oza is a borrower of a PPP Loan that the Debtors service, and there are no




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                   Claimant Name                                                         Misclassified          Modified
                                            Date Claim     Claim
   #                                                                  Debtor Name       Priority Claim        Classification                                     Reason for Reclassification
                                              Filed         No.
                                                                                           Amount                Status2
                                                                                                                   $2,800.00 (T) amounts entitled to priority due and owing to Rajesh Oza under section 507(a)(7) (the
                                                                                                                                  claim is not on account of a deposit in connection with the purchase, lease, or rental of
                                                                                                                                  property or purchase of services) of the Bankruptcy Code. Further, Rajesh Oza does
                                                                                                                                  not provide any documentation in support of the claim.
                                                                                                                                  Randolph Redley filed a $16,248 priority claim pursuant to an unspecified subsection
                                                                                                                        $0.00 (A) of 507(a) of the Bankruptcy Code. The proof of claim asserts “PPP loan forgiveness”
        Randolph Redley                                                                                                 $0.00 (S) as the basis for the claim. See proof of claim no. 951-136. Based on a review of the
                                                                     Kabbage, Inc.
  16                                        11/30/2022     951-136                        $16,248.00 (P)                $0.00 (P) Debtors’ books and records, the Debtors have determined Randolph Redley is a
                                                                     d/b/a KServicing
                                                                                                                 $16,248.00 (U) borrower of a PPP Loan that the Debtors service, and there are no amounts entitled to
                                                                                                                  $16,248.00 (T) priority due and owing to Randolph Redley under section 507(a) of the Bankruptcy
                                                                                                                                  Code.
                                                                                                                                  Robert Clifton filed a $19,000 priority claim pursuant to section 507(a)(4) of the
                                                                                                                                  Bankruptcy Code. The proof of claim form asserts “bank account / my own money was
                                                                                                                        $0.00 (A) fraudulently withdrawn” as the basis for the priority claim. See proof of claim no. 951-
        Robert Clifton                                                                                                  $0.00 (S) 173. Based on a review of the Debtors’ books and records, the Debtors have
                                                                     Kabbage, Inc.
  17                                        11/30/2022     951-173                        $19,000.00 (P)                $0.00 (P) determined Robert Clifton is a borrower of a PPP Loan that the Debtors service, and
                                                                     d/b/a KServicing
                                                                                                                 $19,000.00 (U) there are no amounts entitled to priority due and owing to Robert Clifton under section
                                                                                                                  $19,000.00 (T) 507(a)(4) (the claim is not on account of wages) of the Bankruptcy Code. Further, the
                                                                                                                                  claim is in excess of the statutory limit under section 507(a)(4) of the Bankruptcy
                                                                                                                                  Code, and Robert Clifton does not provide any documentation in support of the claim.
                                                                                                                                  The Orthodox Church filed a $10,227 priority claim pursuant to section 507(a)(4) of
                                                                                                                        $0.00 (A) the Bankruptcy Code. The proof of claim asserts the “Paycheck Protection Program” as
        SS Peter and Paul Orthodox Church                                                                               $0.00 (S) the basis for the claim. See proof of claim no. 951-195. Based on a review of the
        EIN 06-6087116                                               Kabbage, Inc.
  18                                        12/3/2022      951-195                        $10,227.00 (P)                $0.00 (P) Debtors’ books and records, the Debtors have determined the Orthodox Church is a
                                                                     d/b/a KServicing
                                                                                                                 $10,227.00 (U) borrower of a PPP Loan that the Debtors service, and there are no amounts entitled to
                                                                                                                  $10,227.00 (T) priority due and owing to the Orthodox Church under section 507(a)(4) (the claim is
                                                                                                                                  not on account of wages) of the Bankruptcy Code.
                                                                                                                                  Stewart Williams filed a proof of claim asserting a total claim of $20,000.
                                                                                                                                  Notwithstanding the asserted total value of the claim, the claimant asserts that $30,000
                                                                                                                                  is entitled to priority pursuant to sections 507(a)(1)(A) and (a)(1)(B), 507(a)(4), and
                                                                                                                                  507(a)(7) of the Bankruptcy Code. The proof of claim asserts “they sent money to the
                                                                                                                                  wrong account, got it back and held it, after I got credits against the money they said
                                                                                                                        $0.00 (A) time run out” as the basis for the claim. See proof of claim no. 951-213. Based on a
        Stewart Williams                                                                                                $0.00 (S) review of the Debtors’ books and records, the Debtors have determined that there are
                                                                     Kabbage, Inc.
  19                                        12/8/2022      951-213                        $30,000.00 (P)                $0.00 (P) no amounts entitled to priority due and owing to Stewart Williams under sections
                                                                     d/b/a KServicing
                                                                                                                 $20,000.00 (U) 507(a)(1)(A) (the claim is not on account of domestic support obligations) and
                                                                                                                  $20,000.00 (T) (a)(1)(B) (the claim is not on account of domestic support obligations), 507(a)(4) (the
                                                                                                                                  claim is not on account of wages), and 507(a)(7) (the claim is not on account of a
                                                                                                                                  deposit in connection with the purchase, lease, or rental of property or purchase of
                                                                                                                                  services) of the Bankruptcy Code. Further, Stewart Williams does not provide any
                                                                                                                                  documentation in support of the claim, and the claim is in excess of the statutory limit
                                                                                                                                  under section 507(a)(7) of the Bankruptcy Code.
        Summer Stegall                                                                                                  $0.00 (A) Summer Stegall filed a proof of claim asserting a total claim of $42,023.65. The
                                                                     Kabbage, Inc.
  20                                        11/24/2022     951-49                         $30,523.00 (P)                $0.00 (S) claimant asserts that $30,523 is entitled to priority pursuant to sections 507(a)(1)(A)
                                                                     d/b/a KServicing
                                                                                                                        $0.00 (P) and (a)(1)(B), 507(a)(4), 507(a)(7), and 507(a)(8) of the Bankruptcy Code. The proof




                                                                                                         4
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                   Claimant Name                                                Misclassified          Modified
                                   Date Claim     Claim
   #                                                        Debtor Name        Priority Claim        Classification                                     Reason for Reclassification
                                     Filed         No.
                                                                                  Amount                Status2
                                                                                                         $42,023.65 (U) of claim asserts “money loaned/personal injury” as the basis for the claim. See proof
                                                                                                         $42,023.65 (T) of claim no. 951-49. Based on a review of the Debtors’ books and records, the Debtors
                                                                                                                         have determined Summer Stegall is a borrower of a PPP Loan that the Debtors service,
                                                                                                                         and there are no amounts entitled to priority due and owing to Summer Stegall under
                                                                                                                         sections 507(a)(1)(A) (the claim is not on account of domestic support obligations) and
                                                                                                                         (a)(1)(B) (the claim is not on account of domestic support obligations), 507(a)(4) (the
                                                                                                                         claim is not on account of wages), 507(a)(7) (the claim is not on account of a deposit in
                                                                                                                         connection with the purchase, lease, or rental of property or purchase of services), and
                                                                                                                         507(a)(8) (the claim is not on account of governmental units) of the Bankruptcy Code.
                                                                                                                         Further, the claim is in excess of the statutory limit under section 507(a)(7).
                                                                                                                         The Juneau Group filed identical $11,000,000 priority claims against each of the
                                                                                                                         Debtor entities pursuant to sections 507(a)(4), 507(a)(7), 507(a)(8), and an unspecified
                                                                                                                         subsection of 507(a) of the Bankruptcy Code. No basis is asserted for any of the
                                                                                                                         claims. See proof of claim no. 951-91. Based on a review of the Debtors’ books and
                                                                                                               $0.00 (A)
                                                                                                                         records, the Debtors have determined the Juneau Group is a borrower of a PPP Loan
        The Juneau Group, LLC                                                                                  $0.00 (S)
                                                           Kabbage, Inc.                                                 that the Debtors service, and there are no amounts entitled to priority due and owing to
  21                               11/28/2022     951-91                      $11,000,000.00 (P)               $0.00 (P)
                                                           d/b/a KServicing                                              the Juneau Group under sections 507(a)(4) (the claim is not on account of wages),
                                                                                                     $11,000,000.00 (U)
                                                                                                                         507(a)(7) (the claim is not on account of a deposit in connection with the purchase,
                                                                                                     $11,000,000.00 (T)
                                                                                                                         lease, or rental of property or purchase of services), and 507(a)(8) (the claim is not on
                                                                                                                         account of governmental units) of the Bankruptcy Code. Further, the Juneau Group
                                                                                                                         does not provide any documentation in support of the $11,000,000 claims, and the
                                                                                                                         total value of the Juneau Group’s PPP Loan is only $2,223.
                                                                                                                         The Juneau Group filed identical $11,000,000 priority claims against each of the
                                                                                                                         Debtor entities pursuant to sections 507(a)(4), 507(a)(7), 507(a)(8), and an unspecified
                                                                                                                         subsection of 507(a) of the Bankruptcy Code. No basis is asserted for any of the
                                                                                                                         claims. See proof of claim no. 955-4. Based on a review of the Debtors’ books and
                                                                                                               $0.00 (A)
                                                                                                                         records, the Debtors have determined the Juneau Group is a borrower of a PPP Loan
        The Juneau Group, LLC                              Kabbage Asset                                       $0.00 (S)
                                                                                                                         that the Debtors service, and there are no amounts entitled to priority due and owing to
  22                               11/28/2022     955-4    Funding 2019-A,    $11,000,000.00 (P)               $0.00 (P)
                                                                                                                         the Juneau Group under sections 507(a)(4) (the claim is not on account of wages),
                                                           LLC                                       $11,000,000.00 (U)
                                                                                                                         507(a)(7) (the claim is not on account of a deposit in connection with the purchase,
                                                                                                     $11,000,000.00 (T)
                                                                                                                         lease, or rental of property or purchase of services), and 507(a)(8) (the claim is not on
                                                                                                                         account of governmental units) of the Bankruptcy Code. Further, the Juneau Group
                                                                                                                         does not provide any documentation in support of the $11,000,000 claims, and the total
                                                                                                                         value of the Juneau Group’s PPP Loan is only $2,223.
                                                                                                                         The Juneau Group filed identical $11,000,000 priority claims against each of the
                                                                                                                         Debtor entities pursuant to sections 507(a)(4), 507(a)(7), 507(a)(8), and an unspecified
                                                                                                                         subsection of 507(a) of the Bankruptcy Code. No basis is asserted for any of the
                                                                                                               $0.00 (A)
                                                                                                                         claims. See proof of claim no. 952-2. Based on a review of the Debtors’ books and
        The Juneau Group, LLC                                                                                  $0.00 (S)
                                                           Kabbage Canada                                                records, the Debtors have determined the Juneau Group is a borrower of a PPP Loan
  23                               11/28/2022     952-2                       $11,000,000.00 (P)               $0.00 (P)
                                                           Holdings, LLC                                                 that the Debtors service, and there are no amounts entitled to priority due and owing to
                                                                                                     $11,000,000.00 (U)
                                                                                                                         the Juneau Group under sections 507(a)(4) (the claim is not on account of wages),
                                                                                                     $11,000,000.00 (T)
                                                                                                                         507(a)(7) (the claim is not on account of a deposit in connection with the purchase,
                                                                                                                         lease, or rental of property or purchase of services), and 507(a)(8) (the claim is not on
                                                                                                                         account of governmental units) of the Bankruptcy Code. Further, the Juneau Group




                                                                                                5
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                   Claimant Name                                                 Misclassified          Modified
                                   Date Claim     Claim
   #                                                         Debtor Name        Priority Claim        Classification                                    Reason for Reclassification
                                     Filed         No.
                                                                                   Amount                Status2
                                                                                                                           does not provide any documentation in support of the $11,000,000 claims, and the
                                                                                                                           total value of the Juneau Group’s PPP Loan is only $2,223.
                                                                                                                           The Juneau Group filed identical $11,000,000 priority claims against each of the
                                                                                                                           Debtor entities pursuant to sections 507(a)(4), 507(a)(7), 507(a)(8), and an unspecified
                                                                                                                           subsection of 507(a) of the Bankruptcy Code. No basis is asserted for any of the
                                                                                                                           claims. See proof of claim no. 953-2. Based on a review of the Debtors’ books and
                                                                                                               $0.00 (A)
                                                                                                                           records, the Debtors have determined the Juneau Group is a borrower of a PPP Loan
        The Juneau Group, LLC                               Kabbage Asset                                      $0.00 (S)
                                                                                                                           that the Debtors service, and there are no amounts entitled to priority due and owing to
  24                               11/28/2022      953-2    Securitization,    $11,000,000.00 (P)              $0.00 (P)
                                                                                                                           the Juneau Group under sections 507(a)(4) (the claim is not on account of wages),
                                                            LLC                                       $11,000,000.00 (U)
                                                                                                                           507(a)(7) (the claim is not on account of a deposit in connection with the purchase,
                                                                                                      $11,000,000.00 (T)
                                                                                                                           lease, or rental of property or purchase of services), and 507(a)(8) (the claim is not on
                                                                                                                           account of governmental units) of the Bankruptcy Code. Further, the Juneau Group
                                                                                                                           does not provide any documentation in support of the $11,000,000 claims, and the
                                                                                                                           total value of the Juneau Group’s PPP Loan is only $2,223.
                                                                                                                           The Juneau Group filed identical $11,000,000 priority claims against each of the
                                                                                                                           Debtor entities pursuant to sections 507(a)(4), 507(a)(7), 507(a)(8), and an unspecified
                                                                                                                           subsection of 507(a) of the Bankruptcy Code. No basis is asserted for any of the
                                                                                                                           claims. See proof of claim no. 954-2. Based on a review of the Debtors’ books and
                                                                                                               $0.00 (A)
                                                                                                                           records, the Debtors have determined the Juneau Group is a borrower of a PPP Loan
        The Juneau Group LLC                                Kabbage Asset                                      $0.00 (S)
                                                                                                                           that the Debtors service, and there are no amounts entitled to priority due and owing to
  25                               11/28/2022      954-2    Funding 2017-A,    $11,000,000.00 (P)              $0.00 (P)
                                                                                                                           the Juneau Group under sections 507(a)(4) (the claim is not on account of wages),
                                                            LLC                                       $11,000,000.00 (U)
                                                                                                                           507(a)(7) (the claim is not on account of a deposit in connection with the purchase,
                                                                                                      $11,000,000.00 (T)
                                                                                                                           lease, or rental of property or purchase of services), and 507(a)(8) (the claim is not on
                                                                                                                           account of governmental units) of the Bankruptcy Code. Further, the Juneau Group
                                                                                                                           does not provide any documentation in support of the $11,000,000 claims, and the total
                                                                                                                           value of the Juneau Group’s PPP Loan is only $2,223.
                                                                                                                           The Juneau Group filed identical $11,000,000 priority claims against each of the
                                                                                                                           Debtor entities pursuant to sections 507(a)(4), 507(a)(7), 507(a)(8), and an unspecified
                                                                                                                           subsection of 507(a) of the Bankruptcy Code. No basis is asserted for any of the
                                                                                                                           claims. See proof of claim no. 956-2. Based on a review of the Debtors’ books and
                                                                                                               $0.00 (A)
                                                                                                                           records, the Debtors have determined the Juneau Group is a borrower of a PPP Loan
        The Juneau Group LLC                                                                                   $0.00 (S)
                                                            Kabbage                                                        that the Debtors service, and there are no amounts entitled to priority due and owing to
  26                               11/28/2022      956-2                       $11,000,000.00 (P)              $0.00 (P)
                                                            Diameter, LLC                                                  the Juneau Group under sections 507(a)(4) (the claim is not on account of wages),
                                                                                                      $11,000,000.00 (U)
                                                                                                                           507(a)(7) (the claim is not on account of a deposit in connection with the purchase,
                                                                                                      $11,000,000.00 (T)
                                                                                                                           lease, or rental of property or purchase of services), and 507(a)(8) (the claim is not on
                                                                                                                           account of governmental units) of the Bankruptcy Code. Further, the Juneau Group
                                                                                                                           does not provide any documentation in support of the $11,000,000 claims, and the total
                                                                                                                           value of the Juneau Group’s PPP Loan is only $2,223.
                                                                                                                           Valeria Sanders filed a $17,378 priority claim pursuant to an unspecified subsection of
                                                                                                               $0.00 (A)
                                                                                                                           section 507(a) of the Bankruptcy Code. The proof of claim asserts “money loaned but
        Valeria Sanders                                                                                        $0.00 (S)
                                                            Kabbage, Inc.                                                  never received” as the basis for the priority claim. See proof of claim no. 951-108.
  27                               11/29/2022     951-108                          $17,378.00 (P)              $0.00 (P)
                                                            d/b/a KServicing                                               Based on a review of the Debtors’ books and records, the Debtors have determined
                                                                                                          $17,378.00 (U)
                                                                                                                           Valeria Sanders is a borrower of a PPP Loan that the Debtors service, and there are no
                                                                                                          $17,378.00 (T)
                                                                                                                           amounts entitled to priority due and owing to Valeria Sanders under section 507(a) of




                                                                                                 6
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                   Claimant Name                                                Misclassified          Modified
                                   Date Claim     Claim
   #                                                         Debtor Name       Priority Claim        Classification                                   Reason for Reclassification
                                     Filed         No.
                                                                                  Amount                Status2
                                                                                                                          the Bankruptcy Code. Further, Valeria Sanders does not provide any documentation in
                                                                                                                          support of the claim.
                                                                                                                          Yanelys Gomez filed a $3,600 priority claim pursuant to section 507(a)(4) of the
                                                                                                              $0.00 (A)   Bankruptcy Code. The proof of claim asserts “loaned” as the basis for the claim. See
        Yanelys Gomez                                                                                         $0.00 (S)   proof of claim no. 951-205. Based on a review of the Debtors’ books and records, the
                                                            Kabbage, Inc.
  28                               12/6/2022      951-205                         $3,600.00 (P)               $0.00 (P)   Debtors have determined Yanelys Gomez is a borrower of a PPP Loan that the Debtors
                                                            d/b/a KServicing
                                                                                                          $3,600.00 (U)   service, and there are no amounts entitled to priority due and owing to Yanelys Gomez
                                                                                                          $3,600.00 (T)   under section 507(a)(4) (the claim is not on account of wages) of the Bankruptcy Code.
                                                                                                                          Further, Yanelys Gomez does not provide any documentation in support of the claim.




                                                                                                7
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                                            Schedule 2

                            Misclassified Administrative Expense Claims




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                                                                              Misclassified Administrative Expense Claims1
                                                                                     (Claims are listed alphabetically)

                                                                                          Misclassified
                                             Date Claim     Claim                                          Modified Classification
     #             Claimant Name                                       Debtor Name       Administrative                                                          Reason for Reclassification
                                               Filed         No.                                                  Status2
                                                                                         Claim Amount
                                                                                                                                     Best Sister filed a $21,120.34 administrative expense claim pursuant to section
                                                                                                                         $0.00 (A)   503(b)(9) of the Bankruptcy Code. The proof of claim asserts “money loaned” as the
          Best Sister Friends Catering and                                                                               $0.00 (S)   basis for the claim. See proof of claim no. 951-58. Based on a review of the Debtors’
          Events LLC                                                  Kabbage, Inc.
     1                                       11/25/2022     951-58                        $21,120.34 (A)                 $0.00 (P)   books and records, the Debtors have determined Best Sister is a borrower of a PPP
                                                                      d/b/a KServicing
                                                                                                                    $21,120.34 (U)   Loan that the Debtors service, and there is no evidence of the Debtors receiving goods
                                                                                                                    $21,120.34 (T)   from Best Sister within the twenty days prior to the Petition Date, in the ordinary
                                                                                                                                     course, as required by section 503(b)(9) of the Bankruptcy Code.
                                                                                                                                     Carlos Aceves filed a proof of claim asserting a total claim of $63,490. The
                                                                                                                                     claimant asserts that $1,549 is an administrative expense claim pursuant to section
                                                                                                                         $0.00 (A)   503(b)(9) of the Bankruptcy Code. The proof of claim asserts “loan was approved
          Carlos Aceves                                                                                                  $0.00 (S)   f[or] $63,490 after months a deposit of $1,590” as the basis for the claim. See
                                                                      Kabbage, Inc.
     2                                       12/10/2022     951-215                        $1,549.00 (A)                 $0.00 (P)   proof of claim no. 951-215. Based on a review of the Debtors’ books and records,
                                                                      d/b/a KServicing
                                                                                                                    $63,490.00 (U)   the Debtors have determined Carlos Aceves is a borrower of a PPP Loan that the
                                                                                                                    $63,490.00 (T)   Debtors service, and there is no evidence of the Debtors receiving goods from
                                                                                                                                     Carlos Aceves within the twenty days prior to the Petition Date, in the ordinary
                                                                                                                                     course, as required by section 503(b)(9) of the Bankruptcy Code.
                                                                                                                                     Charmaine Busch filed a $30,000 administrative expense claim pursuant to section
                                                                                                                                     503(b)(9) of the Bankruptcy Code. The proof of claim asserts “money loaned . . .”
                                                                                                                         $0.00 (A)
                                                                                                                                     as the basis for the claim. See proof of claim no. 951-27. Based on a review of the
          Charmaine Busch                                                                                                $0.00 (S)
                                                                      Kabbage, Inc.                                                  Debtors’ books and records, the Debtors have determined Charmaine Busch is a
     3                                       11/5/2022      951-27                        $30,000.00 (A)                 $0.00 (P)
                                                                      d/b/a KServicing                                               borrower of a Legacy Loan that the Debtors service, and there is no evidence of the
                                                                                                                    $30,000.00 (U)
                                                                                                                                     Debtors receiving goods from Charmaine Busch within the twenty days prior to the
                                                                                                                    $30,000.00 (T)
                                                                                                                                     Petition Date, in the ordinary course, as required by section 503(b)(9) of the
                                                                                                                                     Bankruptcy Code.
                                                                                                                                     Deborah A. Mastrandrea filed a $3,900 administrative expense claim pursuant to
                                                                                                                                     section 503(b)(9) of the Bankruptcy Code. The proof of claim asserts “money
                                                                                                                         $0.00 (A)   loaned” as the basis for the claim. See proof of claim no. 951-30. Based on a
          Deborah A Mastrandrea                                                                                          $0.00 (S)   review of the Debtors’ books and records, the Debtors have determined Deborah A.
                                                                      Kabbage, Inc.
     4                                       11/15/2022     951-30                         $3,900.00 (A)                 $0.00 (P)   Mastrandrea is a borrower of a PPP loan that the Debtors service, and there is no
                                                                      d/b/a KServicing
                                                                                                                     $3,900.00 (U)   evidence of the Debtors receiving goods from Deborah A. Mastrandrea within the
                                                                                                                     $3,900.00 (T)   twenty days prior to the Petition Date, in the ordinary course, as required by
                                                                                                                                     section 503(b)(9) of the Bankruptcy Code. Further, Deborah A. Mastrandrea does
                                                                                                                                     not attach any documentation in support of the claim.




1
    Certain of the Misclassified Administrative Expense Claims assert more than one incorrect classification status. This schedule lists only the misclassified administrative expense amounts.
2
    (A) - Administrative, including 503(b)(9); (S) - Secured; (P) - Priority; (U) - Unsecured; (T) – Total.




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                                                                                  Misclassified
                                     Date Claim     Claim                                              Modified Classification
   #               Claimant Name                               Debtor Name       Administrative                                                               Reason for Reclassification
                                       Filed         No.                                                      Status2
                                                                                 Claim Amount
                                                                                                                                 George Mallios filed three proofs of claim, each asserting a $209,816.08 administrative
                                                                                                                                 expense claim pursuant to section 503(b)(9) of the Bankruptcy Code. The proofs of
                                                                                                                    $0.00 (A)
                                                                                                                                 claim assert “failure to provide forgiveness” as the basis for the claim. See proof of
        George James Mallios, PC                                                                                    $0.00 (S)
                                                              Kabbage, Inc.                                                      claim no. 951-196. Based on a review of the Debtors’ books and records, the Debtors
   5                                 12/5/2022      951-196                      $209,816.08 (A)                    $0.00 (P)
                                                              d/b/a KServicing                                                   have determined George Mallios is a borrower of a PPP Loan that the Debtors service,
                                                                                                              $209,816.08 (U)
                                                                                                                                 and there is no evidence of the Debtors receiving goods from George Mallios within
                                                                                                              $209,816.08 (T)
                                                                                                                                 the twenty days prior to the Petition Date, in the ordinary course, as required by section
                                                                                                                                 503(b)(9) of the Bankruptcy Code.
                                                                                                                                 George Mallios filed three proofs of claim, each asserting a $209,816.08
                                                                                                                                 administrative expense claim pursuant to section 503(b)(9) of the Bankruptcy Code.
                                                                                                                    $0.00 (A)
                                                                                                                                 The proofs of claim assert “failure to provide forgiveness” as the basis for the claim.
        George James Mallios, PC                                                                                    $0.00 (S)
                                                              Kabbage, Inc.                                                      See proof of claim no. 951-207. Based on a review of the Debtors’ books and records,
   6                                  12/5/2022     951-207                      $209,816.08 (A)                    $0.00 (P)
                                                              d/b/a KServicing                                                   the Debtors have determined George Mallios is a borrower of a PPP Loan that the
                                                                                                              $209,816.08 (U)
                                                                                                                                 Debtors service, and there is no evidence of the Debtors receiving goods from George
                                                                                                              $209,816.08 (T)
                                                                                                                                 Mallios within the twenty days prior to the Petition Date, in the ordinary course, as
                                                                                                                                 required by section 503(b)(9) of the Bankruptcy Code.
                                                                                                                                 George Mallios filed three proofs of claim, each asserting a $209,816.08 administrative
                                                                                                                                 expense claim pursuant to section 503(b)(9) of the Bankruptcy Code. The proofs of
                                                                                                                    $0.00 (A)
                                                                                                                                 claim assert “failure to provide forgiveness” as the basis for the claim. See proof of
        George James Mallios, PC                                                                                    $0.00 (S)
                                                              Kabbage, Inc.                                                      claim no. 951-216. Based on a review of the Debtors’ books and records, the Debtors
   7                                 12/10/2022     951-216                      $209,816.08 (A)                    $0.00 (P)
                                                              d/b/a KServicing                                                   have determined George Mallios is a borrower of a PPP Loan that the Debtors service,
                                                                                                              $209,816.08 (U)
                                                                                                                                 and there is no evidence of the Debtors receiving goods from George Mallios within
                                                                                                              $209,816.08 (T)
                                                                                                                                 the twenty days prior to the Petition Date, in the ordinary course, as required by section
                                                                                                                                 503(b)(9) of the Bankruptcy Code.
                                                                                                                                 Kelvin Foster filed a proof of claim asserting a total claim of $3,000. The claimant
                                                                                                                                 asserts that $2,000 is an administrative expense claim pursuant to section 503(b)(9) of
                                                                                                                     $0.00 (A)
                                                                                                                                 the Bankruptcy Code. The proof of claim asserts “goods sold” as the basis for the
        Kelvin Foster                                                                                                $0.00 (S)
                                                              Kabbage, Inc.                                                      claim. See proof of claim no. 951-231. Based on a review of the Debtors’ books and
   8                                 01/23/2023     951-231                        $2,000.00 (A)                     $0.00 (P)
                                                              d/b/a KServicing                                                   records, the Debtors have determined Kelvin Foster is a borrower of a PPP Loan that
                                                                                                                 $3,000.00 (U)
                                                                                                                                 the Debtors service, and there is no evidence of the Debtors receiving goods from
                                                                                                                 $3,000.00 (T)
                                                                                                                                 Kelvin Foster within the twenty days prior to the Petition Date, in the ordinary course,
                                                                                                                                 as required by section 503(b)(9) of the Bankruptcy Code.
                                                                                                                                 Madel Hernandez filed a $32,000 administrative expense claim pursuant to section
                                                                                                                                 503(b)(9) of the Bankruptcy Code. The proof of claim asserts “Loan” as the basis
                                                                                                                     $0.00 (A)
        Madel Carmen Hernandez dba                                                                                               for the claim. See proof of claim no. 951-15. Based on a review of the Debtors’
                                                                                                                     $0.00 (S)
        TODO PARA TU PACHANG                                  Kabbage, Inc.                                                      books and records, the Debtors have determined Madel Hernandez is a borrower of
   9                                 11/3/2022      951-15                        $32,000.00 (A)                     $0.00 (P)
                                                              d/b/a KServicing                                                   a Legacy Loan that the Debtors service, and there is no evidence of the Debtors
                                                                                                                $32,000.00 (U)
                                                                                                                                 receiving goods from Madel Hernandez within the twenty days prior to the Petition
                                                                                                                $32,000.00 (T)
                                                                                                                                 Date, in the ordinary course, as required by section 503(b)(9) of the Bankruptcy
                                                                                                                                 Code.




                                                                                                   2
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                                                                                Misclassified
                                   Date Claim     Claim                                              Modified Classification
   #               Claimant Name                             Debtor Name       Administrative                                                              Reason for Reclassification
                                     Filed         No.                                                      Status2
                                                                               Claim Amount
                                                                                                                               Paula Roach filed three proofs of claim, each asserting a $112,770 administrative
                                                                                                                               expense claim pursuant to section 503(b)(9) of the Bankruptcy Code. The proofs of
                                                                                                                  $0.00 (A)
                                                                                                                               claim assert “failure to provide forgiveness” as the basis for the claim. See proof of
        Paula Roach                                                                                               $0.00 (S)
                                                            Kabbage, Inc.                                                      claim no. 951-208. Based on a review of the Debtors’ books and records, the Debtors
  10                               12/5/2022      951-208                      $112,770.00 (A)                    $0.00 (P)
                                                            d/b/a KServicing                                                   have determined Paula Roach is a borrower of a PPP Loan that the Debtors service,
                                                                                                            $112,770.00 (U)
                                                                                                                               and there is no evidence of the Debtors receiving goods from Paula Roach within the
                                                                                                            $112,770.00 (T)
                                                                                                                               twenty days prior to the Petition Date, in the ordinary course, as required by section
                                                                                                                               503(b)(9) of the Bankruptcy Code.
                                                                                                                               Paula Roach filed three proofs of claim, each asserting a $112,770 administrative
                                                                                                                               expense claim pursuant to section 503(b)(9) of the Bankruptcy Code. The proofs of
                                                                                                                  $0.00 (A)
                                                                                                                               claim assert “failure to provide forgiveness” as the basis for the claim. See proof of
        Paula Roach                                                                                               $0.00 (S)
                                                            Kabbage, Inc.                                                      claim no. 951-210. Based on a review of the Debtors’ books and records, the Debtors
  11                               12/5/2022      951-210                      $112,770.00 (A)                    $0.00 (P)
                                                            d/b/a KServicing                                                   have determined Paula Roach is a borrower of a PPP Loan that the Debtors service,
                                                                                                            $112,770.00 (U)
                                                                                                                               and there is no evidence of the Debtors receiving goods from Paula Roach within the
                                                                                                            $112,770.00 (T)
                                                                                                                               twenty days prior to the Petition Date, in the ordinary course, as required by section
                                                                                                                               503(b)(9) of the Bankruptcy Code.
                                                                                                                               Paula Roach filed three proofs of claim, each asserting a $112,770 administrative
                                                                                                                               expense claim pursuant to section 503(b)(9) of the Bankruptcy Code. The proofs of
                                                                                                                  $0.00 (A)
                                                                                                                               claim assert “failure to provide forgiveness” as the basis for the claim. See proof of
        Paula Roach                                                                                               $0.00 (S)
                                                            Kabbage, Inc.                                                      claim no. 951-214. Based on a review of the Debtors’ books and records, the Debtors
  12                               12/7/2022      951-214                      $112,770.00 (A)                    $0.00 (P)
                                                            d/b/a KServicing                                                   have determined Paula Roach is a borrower of a PPP Loan that the Debtors service,
                                                                                                            $112,770.00 (U)
                                                                                                                               and there is no evidence of the Debtors receiving goods from Paula Roach within the
                                                                                                            $112,770.00 (T)
                                                                                                                               twenty days prior to the Petition Date, in the ordinary course, as required by section
                                                                                                                               503(b)(9) of the Bankruptcy Code.
                                                                                                                               Randolph Redley filed a $16,248 administrative expense claim pursuant to section
                                                                                                                               503(b)(9) of the Bankruptcy Code. The proof of claim asserts “SBA PPP loan
                                                                                                                   $0.00 (A)
                                                                                                                               forgiveness” as the basis for the claim. See proof of claim no. 951-136. Based on
        Randolph Redley                                                                                            $0.00 (S)
                                                            Kabbage, Inc.                                                      a review of the Debtors’ books and records, the Debtors have determined
  13                               11/30/2022     951-136                       $16,248.00 (A)                     $0.00 (P)
                                                            d/b/a KServicing                                                   Randolph Redley is a borrower of a PPP Loan that the Debtors service, and there is
                                                                                                              $16,248.00 (U)
                                                                                                                               no evidence of the Debtors receiving goods from Randolph Redley within the
                                                                                                              $16,248.00 (T)
                                                                                                                               twenty days prior to the Petition Date, in the ordinary course, as required by section
                                                                                                                               503(b)(9) of the Bankruptcy Code.
                                                                                                                               The Juneau Group filed an administrative expense claim pursuant to section 503(b)(9)
                                                                                                                               of the Bankruptcy Code, in the amount of $20,833 per month for the duration of the
                                                                                                                               Chapter 11 Cases for an aggregate amount of $499,999.99. The proof of claim asserts
                                                                                                                  $0.00 (A)    “TIME” as the basis for the claim. See proof claim no. 951-184. Based on a review of
        The Juneau Group, LLC                                                                                     $0.00 (S)    the Debtors’ books and records, the Debtors have determined the Juneau Group is a
                                                            Kabbage, Inc.
  14                               11/28/2022     951-184                      $499,999.99 (A)                    $0.00 (P)    borrower of a PPP Loan that the Debtors service, and there is no evidence of the
                                                            d/b/a KServicing
                                                                                                            $499,999.99 (U)    Debtors receiving goods from the Juneau Group within the twenty days prior to the
                                                                                                            $499,999.99 (T)    Petition Date, in the ordinary course, as required by section 503(b)(9) of the
                                                                                                                               Bankruptcy Code. Further, the Juneau Group does not attach any documentation in
                                                                                                                               support of the $499,999.99 claim, and the total value of the Juneau Group’s PPP Loan
                                                                                                                               is only $2,223.




                                                                                                 3
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                                           Schedule 3

                                  Misclassified Secured Claims




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                                                                                       Misclassified Secured Claims1
                                                                                      (Claims are listed alphabetically)

                                                                                         Misclassified
                                          Date Claim      Claim                                                   Modified
     #            Claimant Name                                     Debtor Name         Secured Claim                                                             Reason for Reclassification
                                            Filed          No.                                              Classification Status2
                                                                                           Amount
                                                                                                                         $0.00 (A)   Anthony Dinish filed a secured claim for an unliquidated amount. The proof of
                                                                                                                                     claim asserts “chapter 11 bankruptcy” as the basis for the claim. See proof of claim
          Anthony Dinish                                                                                                 $0.00 (S)
                                                                   Kabbage, Inc.                                                     no. 951-185. Based on a review of the Debtors’ books and records, the Debtors
     1                                     11/28/2022    951-185                                $0.00 (S)                $0.00 (P)
                                                                   d/b/a KServicing                                                  have determined Anthony Dinish is a borrower of a PPP Loan that the Debtors
                                                                                                                         $0.00 (U)   service, and there is no basis for the claim’s secured status under section 506 of the
                                                                                                                         $0.00 (T)   Bankruptcy Code.
                                                                                                                        $0.00 (A)    Kadada filed a $22,000 secured claim. The proof of claim asserts “money loaned”
          Kadada, LLC                                                                                                   $0.00 (S)    as the basis for the claim. See proof of claim no. 951-226. Based on a review of the
                                                                   Kabbage, Inc.
     2                                      1/5/2023     951-226                           $22,000.00 (S)               $0.00 (P)    Debtors’ books and records, the Debtors have determined Kadada is a borrower of a
                                                                   d/b/a KServicing
                                                                                                                   $22,000.00 (U)    PPP Loan that the Debtors service, and there is no basis for the claim’s secured status
                                                                                                                   $22,000.00 (T)    under section 506 of the Bankruptcy Code.
                                                                                                                                     Michael R. Hamlin filed a $500,000 secured claim. The proof of claim asserts “a lien
                                                                                                                        $0.00 (A)    against property, that Kabbage Inc, must [have] purchased” as the basis for the claim.
                                                                                                                                     The claimant further asserts that the lien is against 13 River Street, Sanford, Maine,
          Michael R. Hamlin                                                                                             $0.00 (S)
                                                                   Kabbage, Inc.                                                     which is on file at the York County Registry of Deeds. See proof of claim no. 951-25.
     3                                     11/12/2022     951-25                         $500,000.00 (S)                $0.00 (P)
                                                                   d/b/a KServicing                                                  Based on a review of the Debtors’ books and records, the Debtors have determined
                                                                                                                  $500,000.00 (U)    Michael R. Hamlin is a borrower of a Legacy Loan that the Debtors service, there is no
                                                                                                                  $500,000.00 (T)    evidence of the alleged lien, and no basis for the claim’s secured status under section
                                                                                                                                     506 of the Bankruptcy Code.
                                                                                                                        $0.00 (A)    Summer Stegall filed a filed a proof of claim asserting a total claim of $42,023.65,
                                                                                                                                     including a $42,023 secured claim. The proof of claim asserts “money loaned/personal
          Summer Stegall                                                                                                $0.00 (S)
                                                                   Kabbage, Inc.                                                     injury” as the basis for the claim. See proof of claim no. 951-49. Based on a review of
     4                                     11/24/2022     951-49                           $42,023.65 (S)               $0.00 (P)
                                                                   d/b/a KServicing                                                  the Debtors’ books and records, the Debtors have determined Summer Stegall is a
                                                                                                                   $42,023.65 (U)    borrower of a PPP Loan that the Debtors service, and there is no basis for the claim’s
                                                                                                                   $42,023.65 (T)    secured status under section 506 of the Bankruptcy Code.
                                                                                                                                     The Juneau Group filed identical $11,000,000 secured claims against each of the
                                                                                                                        $0.00 (A)    Debtor entities. No basis for the claims is provided. See proof of claim no. 954-2.
                                                                                                                                     Based on a review of the Debtors’ books and records, the Debtors have determined the
          The Juneau Group, LLC                                    Kabbage Asset                                        $0.00 (S)
                                                                                                                                     Juneau Group is a borrower of a PPP Loan that the Debtors service, there is no
     5                                     11/28/2022     954-2    Funding 2017-A,     $11,000,000.00 (S)               $0.00 (P)    evidence of the Juneau Group’s claims, and no basis for the claims’ secured status
                                                                   LLC                                         $11,000,000.00 (U)    under section 506 of the Bankruptcy Code. Further, the Juneau Group provides no
                                                                                                               $11,000,000.00 (T)    documentation in support of the claims, and the total value of the Juneau Group’s PPP
                                                                                                                                     Loan is only $2,223.




1
    Certain of the Misclassified Secured Claims assert more than one incorrect classification status. This schedule lists only the misclassified secured amounts.
2
    (A) - Administrative, including 503(b)(9); (S) - Secured; (P) - Priority; (U) - Unsecured; (T) – Total.




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                                                                            Misclassified
                               Date Claim     Claim                                                   Modified
  #            Claimant Name                            Debtor Name        Secured Claim                                                             Reason for Reclassification
                                 Filed         No.                                              Classification Status2
                                                                              Amount
                                                                                                                         The Juneau Group filed identical $11,000,000 secured claims against each of the
                                                                                                            $0.00 (A)    Debtor entities. No basis for the claims is provided. See proof of claim no. 956-2.
                                                                                                                         Based on a review of the Debtors’ books and records, the Debtors have determined the
       The Juneau Group LLC                                                                                 $0.00 (S)
                                                       Kabbage                                                           Juneau Group is a borrower of a PPP Loan that the Debtors service, there is no
  6                            11/28/2022     956-2                       $11,000,000.00 (S)                $0.00 (P)
                                                       Diameter, LLC                                                     evidence of the Juneau Group’s claims, and no basis for the claims’ secured status
                                                                                                   $11,000,000.00 (U)    under section 506 of the Bankruptcy Code. Further, the Juneau Group provides no
                                                                                                   $11,000,000.00 (T)    documentation in support of the claims, and the total value of the Juneau Group’s PPP
                                                                                                                         Loan is only $2,223.
                                                                                                                         The Juneau Group filed identical $11,000,000 secured claims against each of the
                                                                                                            $0.00 (A)    Debtor entities. No basis for the claims is provided. See proof of claim no. 951-91.
                                                                                                                         Based on a review of the Debtors’ books and records, the Debtors have determined the
       The Juneau Group, LLC                                                                                $0.00 (S)
                                                       Kabbage, Inc.                                                     Juneau Group is a borrower of a PPP Loan that the Debtors service, there is no
  7                            11/28/2022     951-91                      $11,000,000.00 (S)                $0.00 (P)
                                                       d/b/a KServicing                                                  evidence of the Juneau Group’s claims, and no basis for the claims’ secured status
                                                                                                   $11,000,000.00 (U)    under section 506 of the Bankruptcy Code. Further, the Juneau Group provides no
                                                                                                   $11,000,000.00 (T)    documentation in support of the claims, and the total value of the Juneau Group’s PPP
                                                                                                                         Loan is only $2,223.
                                                                                                                         The Juneau Group filed identical $11,000,000 secured claims against each of the
                                                                                                                         Debtor entities. No basis for the claims is provided. See proof of claim no. 955-4.
                                                                                                            $0.00 (A)    Based on a review of the Debtors’ books and records, the Debtors have determined the
       The Juneau Group, LLC                           Kabbage Asset
                                                                                                    $0.00 (S)$0.00 (P)   Juneau Group is a borrower of a PPP Loan that the Debtors service, there is no
  8                            11/28/2022     955-4    Funding 2019-A,    $11,000,000.00 (S)
                                                                                                   $11,000,000.00 (U)    evidence of the Juneau Group’s claims, and no basis for the claims’ secured status
                                                       LLC
                                                                                                   $11,000,000.00 (T)    under section 506 of the Bankruptcy Code. Further, the Juneau Group provides no
                                                                                                                         documentation in support of the claims, and the total value of the Juneau Group’s PPP
                                                                                                                         Loan is only $2,223.
                                                                                                                         The Juneau Group filed identical $11,000,000 secured claims against each of the
                                                                                                            $0.00 (A)    Debtor entities. No basis for the claims is provided. See proof of claim no. 952-2.
                                                                                                                         Based on a review of the Debtors’ books and records, the Debtors have determined the
       The Juneau Group, LLC                                                                                $0.00 (S)
                                                       Kabbage Canada                                                    Juneau Group is a borrower of a PPP Loan that the Debtors service, there is no
  9                            11/28/2022     952-2                       $11,000,000.00 (S)                $0.00 (P)
                                                       Holdings, LLC                                                     evidence of the Juneau Group’s claims, and no basis for the claims’ secured status
                                                                                                   $11,000,000.00 (U)    under section 506 of the Bankruptcy Code. Further, the Juneau Group provides no
                                                                                                   $11,000,000.00 (T)    documentation in support of the claims, and the total value of the Juneau Group’s PPP
                                                                                                                         Loan is only $2,223.
                                                                                                                         The Juneau Group filed identical $11,000,000 secured claims against each of the
                                                                                                            $0.00 (A)    Debtor entities. No basis for the claims is provided. See proof of claim no. 953-2.
                                                                                                                         Based on a review of the Debtors’ books and records, the Debtors have determined the
       The Juneau Group, LLC                           Kabbage Asset                                        $0.00 (S)
                                                                                                                         Juneau Group is a borrower of a PPP Loan that the Debtors service, there is no
 10                            11/28/2022     953-2    Securitization,    $11,000,000.00 (S)                $0.00 (P)    evidence of the Juneau Group’s claims, and no basis for the claims’ secured status
                                                       LLC                                         $11,000,000.00 (U)    under section 506 of the Bankruptcy Code. Further, the Juneau Group provides no
                                                                                                   $11,000,000.00 (T)    documentation in support of the claims, and the total value of the Juneau Group’s PPP
                                                                                                                         Loan is only $2,223.




                                                                                            2
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