In re Kabbage — Email Correspondence re Document Production (Exhibit 5)

Summary

Exhibit 5, filed February 24, 2023 as Doc 577-5 in Case 22-10951-CTG, In re Kabbage. The five-page exhibit reproduces an email chain with the subject line KServicing between Theodore E. Tsekerides of Weil, Gotshal & Manges LLP and Craig A. Wolfe of Morgan, Lewis & Bockius LLP, running from January 10, 2023 to January 29, 2023. In the messages, Mr. Tsekerides asks for updates on a response to a letter and on document production and says his side wants to avoid filing a 2004 motion. Mr. Wolfe replies that the client is collecting documents, that a litigation hold has been implemented and that production will be made on a rolling basis.

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Case 22-10951-CTG   Doc 577-5   Filed 02/24/23   Page 1 of 5




               EXHIBIT 5
                       Case 22-10951-CTG            Doc 577-5       Filed 02/24/23   Page 2 of 5




From:                               Wolfe, Craig A. <craig.wolfe@morganlewis.com>
Sent:                               Sunday, January 29, 2023 5:04 AM
To:                                 Tsekerides, Theodore
Subject:                            Re: KServicing



We actually got a slug of documents on Friday. We will get those reviewed and over to you on a rolling basis.

Craig A. Wolfe

Morgan, Lewis & Bockius LLP

101 Park Avenue | New York, NY 10178-0060

Direct: +1.212.309.6204 | Main: +1.212.309.6000 | Fax: +1.212.309.6001

Cell: (213) 514-3423

craig.wolfe@morganlewis.com | www.morganlewis.com

Assistant: Lisa Edwards | +1.212.309.6393 | lisa.edwards@morganlewis.com




From: Tsekerides, Theodore <theodore.tsekerides@weil.com>
Sent: Saturday, January 28, 2023 6:49:59 AM
To: Wolfe, Craig A. <craig.wolfe@morganlewis.com>
Subject: RE: KServicing

[EXTERNAL EMAIL]
Craig, this is moving too slowly. We need to start getting documents early this coming week to avoid us filing
a 2004 motion.

Thanks




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



From: Wolfe, Craig A. <craig.wolfe@morganlewis.com>
Sent: Friday, January 13, 2023 5:09 PM
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                       Case 22-10951-CTG            Doc 577-5       Filed 02/24/23   Page 3 of 5

To: Tsekerides, Theodore <theodore.tsekerides@weil.com>
Subject: Re: KServicing

The team is still collecting documents. They are busy on deals, so they don’t have an army to dedicate to the
project but are taking it very seriously. We should start producing next week.


Craig A. Wolfe


Morgan, Lewis & Bockius LLP


101 Park Avenue | New York, NY 10178-0060


Direct: +1.212.309.6204 | Main: +1.212.309.6000 | Fax: +1.212.309.6001


Cell: (213) 514-3423


craig.wolfe@morganlewis.com | www.morganlewis.com


Assistant: Lisa Edwards | +1.212.309.6393 | lisa.edwards@morganlewis.com




From: Tsekerides, Theodore <theodore.tsekerides@weil.com>
Sent: Friday, January 13, 2023 1:44:08 PM
To: Wolfe, Craig A. <craig.wolfe@morganlewis.com>
Subject: RE: KServicing

[EXTERNAL EMAIL]
Craig, where do we stand? I’d like to avoid filing a motion but we need to get this going. We have a lot of
stakeholders and they are pressing us.

Thanks very much.




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




                                                              2
                       Case 22-10951-CTG            Doc 577-5       Filed 02/24/23     Page 4 of 5

From: Wolfe, Craig A. <craig.wolfe@morganlewis.com>
Sent: Tuesday, January 10, 2023 3:22 PM
To: Tsekerides, Theodore <theodore.tsekerides@weil.com>
Subject: RE: KServicing

Yes, I just got off a long call with the client to provide them with guidance on the production of documents. The plan is
to produce on a rolling basis, so you guys start getting some materials. A litigation hold has also been implemented. I
should have an update by Friday. Keep you posted and do not hesitate to contact me.

Craig A. Wolfe
Morgan, Lewis & Bockius LLP
101 Park Avenue | New York, NY 10178-0060
Direct: +1.212.309.6204 | Main:+1.212.309.6000 | Fax: +1.212.309.6001
Cell: (213) 514-3423
craig.wolfe@morganlewis.com| www.morganlewis.com
Assistant: Lisa Edwards | +1.212.309.6393 | lisa.edwards@morganlewis.com



From: Tsekerides, Theodore <theodore.tsekerides@weil.com>
Sent: Tuesday, January 10, 2023 11:50 AM
To: Wolfe, Craig A. <craig.wolfe@morganlewis.com>
Subject: KServicing

[EXTERNAL EMAIL]
Craig, any update on the response to our letter? Thanks very much

Theodore E. Tsekerides
Partner
Weil, Gotshal & Manges LLP
212-310-8218 Office
516-398-0510 Mobile



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.




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.




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


                                                              3
                     Case 22-10951-CTG           Doc 577-5       Filed 02/24/23      Page 5 of 5
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.




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