Given that we have not heard from you, the Debtors intend to move the court for an order

Summary

Exhibit 3, filed February 24, 2023 as Doc 577-3 in Case No. 22-10951-CTG: an email chain dated December 15, 2022 through December 27, 2022 with the subject In re Kabbage, Inc. d/b/a KServicing, et al. Case No. 22-10951. On December 15, 2022, Theodore E. Tsekerides of Weil, Gotshal & Manges LLP sends Steve McLaughlin and Amar Mehta an attached letter, and McLaughlin replies that the matter will go to Danny Allen, General Counsel, with an official response to follow after internal and counsel review. On December 27, 2022, Tsekerides writes that the Debtors intend to move the court for an order pursuant to Bankruptcy Rule 2004 to compel production of the materials identified in the letter of December 15. Allen replies that a response will follow in the next day or two.

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EXHIBIT 3
Case 22-10951-CTG    Doc 577-3    Filed 02/24/23    Page 1 of 4

From:
Danny Allen
To:
Tsekerides, Theodore; Steve McLaughlin; Amar Mehta
Cc:
Arthur, Candace M.; Hwangpo, Natasha; Shapiro@rlf.com; steele@rlf.com; Trinity Litigation
Subject:
RE: In re Kabbage, Inc. d/b/a KServicing, et al. Case No. 22-10951
Date:
Tuesday, December 27, 2022 7:53:58 PM
Hi Theodore,

We are working on this and will have a response for you in the next day or two.  Apologies for the delay.

Thank you,
Danny

_______________________________
Danny Allen
General Counsel
(929) 562-2156

From: Tsekerides, Theodore <theodore.tsekerides@weil.com>
Sent: Tuesday, December 27, 2022 9:45 AM
To: Steve McLaughlin <steve.mclaughlin@ftpartners.com>; Amar Mehta
<Amar.Mehta@ftpartners.com>; Danny Allen <Danny.Allen@ftpartners.com>
Cc: Arthur, Candace M. <Candace.Arthur@weil.com>; Hwangpo, Natasha
<Natasha.Hwangpo@weil.com>; Shapiro@rlf.com; steele@rlf.com; Trinity Litigation
<Trinity.Litigation@weil.com>
Subject: RE: In re Kabbage, Inc. d/b/a KServicing, et al. Case No. 22-10951

Mr. McLaughlin and Mr. Allen

Given that we have not heard from you, the Debtors intend to move the court for an order
pursuant to Bankruptcy Rule 2004 to compel the production of the materials identified in our
letter of December 15.  Pursuant to Local Rule 2004-1(b), we shall inform the court in our
motion that we attempted to meet and confer but received no response.

Regards,

Theodore E. Tsekerides
Weil, Gotshal & Manges LLP
767 Fifth Avenue
New York, NY 10153
theodore.tsekerides@weil.com
+1 212 310 8218 Direct
+1 516 398 0510 Mobile
+1 212 310 8007 Fax
Case 22-10951-CTG    Doc 577-3    Filed 02/24/23    Page 2 of 4

From: Steve McLaughlin <steve.mclaughlin@ftpartners.com>
Sent: Thursday, December 15, 2022 12:49 PM
To: Tsekerides, Theodore <theodore.tsekerides@weil.com>; Amar Mehta
<Amar.Mehta@ftpartners.com>
Cc: Arthur, Candace M. <Candace.Arthur@weil.com>; Hwangpo, Natasha
<Natasha.Hwangpo@weil.com>; Danny Allen <Danny.Allen@ftpartners.com>
Subject: RE: In re Kabbage, Inc. d/b/a KServicing, et al. Case No. 22-10951

Hello there.  Given we’re under NDA, I’m pretty sure we can’t help voluntarily here.  That said, I’m not a
lawyer, so will turn this over to Danny Allen our GC.  We will come back to you with an official response
once we review internally and with counsel.
All the best,

Steve
415-385-9318

From: Tsekerides, Theodore <theodore.tsekerides@weil.com>
Sent: Thursday, December 15, 2022 12:34 PM
To: Steve McLaughlin <steve.mclaughlin@ftpartners.com>; Amar Mehta
<amar.mehta@ftpartners.com>
Cc: Arthur, Candace M. <Candace.Arthur@weil.com>; Hwangpo, Natasha
<Natasha.Hwangpo@weil.com>
Subject: In re Kabbage, Inc. d/b/a KServicing, et al. Case No. 22-10951

Mr. McLaughlin and Mr. Mehta, please see the attached letter.

Thank you.

Theodore E. Tsekerides
Weil, Gotshal & Manges LLP
767 Fifth Avenue
New York, NY 10153
theodore.tsekerides@weil.com
+1 212 310 8218 Direct
+1 516 398 0510 Mobile
+1 212 310 8007 Fax

The information contained in this email message is intended only for use of the individual or entity named
above. If the reader of this message is not the intended recipient, or the employee or agent responsible to
Case 22-10951-CTG    Doc 577-3    Filed 02/24/23    Page 3 of 4

deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying
of this communication is strictly prohibited. If you have received this communication in error, please
immediately notify us by email, postmaster@weil.com, and destroy the original message. Thank you.
This message is intended only for the personal and confidential use of the designated recipient(s) named above.  If you are not the
intended recipient of this message you are hereby notified that any review, dissemination, distribution or copying of this message is
strictly prohibited.  Please delete it and any attachments and notify the sender that you have received it in error.  Unintended recipients
are prohibited from taking action on the basis of information in this e-mail.  This communication is for informational purposes only and
should not be regarded as an offer to sell or as a solicitation of an offer to buy any financial product.  No representation is being made
that the information presented is accurate, current or complete, and such information is at all times subject to change without notice.

The information contained in this email message is intended only for use of the individual or entity named
above. If the reader of this message is not the intended recipient, or the employee or agent responsible to
deliver it to the intended recipient, you are hereby notified that any dissemination, distribution or copying
of this communication is strictly prohibited. If you have received this communication in error, please
immediately notify us by email, postmaster@weil.com, and destroy the original message. Thank you.
This message is intended only for the personal and confidential use of the designated recipient(s) named above.  If you are not the
intended recipient of this message you are hereby notified that any review, dissemination, distribution or copying of this message is
strictly prohibited.  Please delete it and any attachments and notify the sender that you have received it in error.  Unintended recipients
are prohibited from taking action on the basis of information in this e-mail.  This communication is for informational purposes only and
should not be regarded as an offer to sell or as a solicitation of an offer to buy any financial product.  No representation is being made
that the information presented is accurate, current or complete, and such information is at all times subject to change without notice.
Case 22-10951-CTG    Doc 577-3    Filed 02/24/23    Page 4 of 4

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