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