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Kservicing Bankruptcy

Date
2023-03-15

Summary

Exhibit 2, filed March 15, 2023 as Doc 685-2 in Case 22-10951-CTG, the KServicing bankruptcy case. It is an email chain dated January 4, 2023 to January 13, 2023 between attorneys at Weil, Gotshal & Manges LLP and Sullivan & Cromwell LLP under the subject KServicing/Amex. The emails arrange calls about options for ongoing loan servicing following the bankruptcy and American Express's role. They also record a request for consent to share three agreements with Cross River Bank, including an Agreement and Plan of Merger dated August 16, 2020, and a reply that American Express consents to sharing them. The final email transmits a letter and a schedule listing requests.

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Full text

Case 22-10951-CTG   Doc 685-2   Filed 03/15/23   Page 1 of 8




                       Exhibit 2
                      Case 22-10951-CTG           Doc 685-2      Filed 03/15/23       Page 2 of 8




From:                             Tsekerides, Theodore <theodore.tsekerides@weil.com>
Sent:                             Friday, January 13, 2023 4:37 PM
To:                               Mehta, Suniti N.; Arthur, Candace M.
Cc:                               Bromley, James L.; Davidoff, Amanda Flug; Hwangpo, Natasha; Bentley, Chase; Ollestad,
                                  Jordan; Trinity Litigation
Subject:                          [EXTERNAL] RE: KServicing/Amex
Attachments:                      Letter to Amex Re Loan Servicing.pdf; KServicing 2004 Request Schedule.pdf



Please see the attached letter and schedule listing the requests. Let’s discuss next week.

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



From: Mehta, Suniti N.
Sent: Wednesday, January 11, 2023 2:41 PM
To: Tsekerides, Theodore ; Arthur, Candace M.
Cc: Bromley, James L. ; Davidoff, Amanda Flug ; Hwangpo, Natasha ; Bentley, Chase ; Ollestad, Jordan
Subject: RE: KServicing/Amex

Ted, Candace,

American Express consents to sharing the Merger Agreement, TSA, and Transfer, Assignment and Assumption
Agreement with Cross River Bank.

We will come back to you on the draft protective order as soon as possible. As discussed on Friday, it would be helpful to
see the list of requests that we discussed, including details about the data transfer that KServicing is interested in
pursuing.

Thanks,
Suni

Suniti N. Mehta
T: (212) 558‐4083 | F: (212) 558‐3588
mehtas@sullcrom.com
                                                            1
                     Case 22-10951-CTG           Doc 685-2      Filed 03/15/23      Page 3 of 8


From: Tsekerides, Theodore <theodore.tsekerides@weil.com>
Sent: Wednesday, January 11, 2023 8:27 AM
To: Arthur, Candace M. <Candace.Arthur@weil.com>
Cc: Bromley, James L. <bromleyj@sullcrom.com>; Mehta, Suniti N. <mehtas@sullcrom.com>; Davidoff, Amanda Flug
<davidoffa@sullcrom.com>; Hwangpo, Natasha <Natasha.Hwangpo@weil.com>; Bentley, Chase
<Chase.Bentley@weil.com>; Ollestad, Jordan <Jordan.Ollestad@weil.com>
Subject: [EXTERNAL] Re: KServicing/Amex

Actually, upon further review, the only agreement of these 3 that requires Amex’s consent is the TSA.

Jim, please let us know about the TSA and also let us know if there were any comments on the proposed protective
order we sent around a while back.

Thanks very much.

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


        On Jan 10, 2023, at 7:47 PM, Arthur, Candace M. <Candace.Arthur@weil.com> wrote:


        Jim, Suniti, and Amanda

        We wanted to see if you had a chance to speak to your client regarding our request for consent to share
        the following documents with Cross River Bank:

                        1. The Transition Services Agreement;
                        2. Agreement and Plan of Merger among American Express Travel Related Services
                           Company, Inc., Green Acquisition Merger Sub, Inc., Kabbage, Inc., Alpha Kabbage,
                           Inc., and Fortis Advisors, LLC, dated August 16, 2020, including all exhibits and
                           schedules thereto, as may be amended from time to time;
                        3. The Transfer, Assignment and Assumption Agreement between Kabbage, LLC and
                           Alpha Kabbage;

        Please advise. Subject to obtaining the requested consent we would like to provide Cross River with the
        documents before their 4pm deadline to object to the Disclosure Statement.

        Best
        Candace



        Candace M. Arthur
        Partner

        Weil, Gotshal & Manges LLP
        767 Fifth Avenue

                                                           2
             Case 22-10951-CTG           Doc 685-2      Filed 03/15/23     Page 4 of 8

New York, NY 10153
candace.arthur@weil.com
+1 212 310 8324 Direct
+1 212 310 8007 Fax

From: Bromley, James L. <bromleyj@sullcrom.com>
Sent: Friday, January 6, 2023 1:03 PM
To: Arthur, Candace M. <Candace.Arthur@weil.com>
Cc: Tsekerides, Theodore <theodore.tsekerides@weil.com>; Mehta, Suniti N. <mehtas@sullcrom.com>;
Davidoff, Amanda Flug <davidoffa@sullcrom.com>; Hwangpo, Natasha <Natasha.Hwangpo@weil.com>;
Bentley, Chase <Chase.Bentley@weil.com>
Subject: RE: [EXTERNAL] Re: KServicing/Amex

I can speak between 2:30 and 4


James L. Bromley
T: (212) 558‐4923 | F: (212) 291‐3588 | C: (973) 901‐6898
bromleyj@sullcrom.com

From: Arthur, Candace M. <Candace.Arthur@weil.com>
Sent: Friday, January 6, 2023 12:24 PM
To: Bromley, James L. <bromleyj@sullcrom.com>
Cc: Tsekerides, Theodore <theodore.tsekerides@weil.com>; Mehta, Suniti N. <mehtas@sullcrom.com>;
Davidoff, Amanda Flug <davidoffa@sullcrom.com>; Hwangpo, Natasha <Natasha.Hwangpo@weil.com>;
Bentley, Chase <Chase.Bentley@weil.com>
Subject: RE: [EXTERNAL] Re: KServicing/Amex

Jim

Thank you for the flexibility. Would this afternoon work for you? Perhaps between 2‐4?




Candace M. Arthur
Partner

Weil, Gotshal & Manges LLP
767 Fifth Avenue
New York, NY 10153
candace.arthur@weil.com
+1 212 310 8324 Direct
+1 212 310 8007 Fax

From: Bromley, James L. <bromleyj@sullcrom.com>
Sent: Thursday, January 5, 2023 6:06 PM
To: Arthur, Candace M. <Candace.Arthur@weil.com>
Cc: Tsekerides, Theodore <theodore.tsekerides@weil.com>; Mehta, Suniti N. <mehtas@sullcrom.com>;
Davidoff, Amanda Flug <davidoffa@sullcrom.com>; Hwangpo, Natasha <Natasha.Hwangpo@weil.com>;


                                                   3
              Case 22-10951-CTG             Doc 685-2        Filed 03/15/23   Page 5 of 8

Bentley, Chase <Chase.Bentley@weil.com>
Subject: RE: [EXTERNAL] Re: KServicing/Amex

Sure




From: Arthur, Candace M. <Candace.Arthur@weil.com>
Date: Thursday, Jan 05, 2023 at 5:31 PM
To: Bromley, James L. <bromleyj@sullcrom.com>
Cc: Tsekerides, Theodore <theodore.tsekerides@weil.com>, Mehta, Suniti N. <mehtas@sullcrom.com>,
Davidoff, Amanda Flug <davidoffa@sullcrom.com>, Hwangpo, Natasha <Natasha.Hwangpo@weil.com>,
Bentley, Chase <Chase.Bentley@weil.com>
Subject: Re: [EXTERNAL] Re: KServicing/Amex

Jim

We are in striking distance of resolving a contested matter that is scheduled for hearing tomorrow. Is it
possible to reschedule our call for tomorrow?


Candace M. Arthur

Weil, Gotshal & Manges LLP
767 Fifth Avenue
New York, NY 10153
candace.arthur@weil.com
+1 212 310 8324 Direct
+1 212 310 8007 Fax


        On Jan 4, 2023, at 9:38 PM, Bromley, James L. <bromleyj@sullcrom.com> wrote:


        Ok




        From: Arthur, Candace M. <Candace.Arthur@weil.com>
        Date: Wednesday, Jan 04, 2023 at 9:32 PM
        To: Bromley, James L. <bromleyj@sullcrom.com>
        Cc: Tsekerides, Theodore <theodore.tsekerides@weil.com>, Mehta, Suniti N.
        <mehtas@sullcrom.com>, Davidoff, Amanda Flug <davidoffa@sullcrom.com>, Hwangpo,
        Natasha <Natasha.Hwangpo@weil.com>, Bentley, Chase <Chase.Bentley@weil.com>
        Subject: Re: [EXTERNAL] Re: KServicing/Amex

        Jim

        Let’s shoot for 6:30. We will circulate a dial‐in.


        Candace M. Arthur

                                                       4
     Case 22-10951-CTG          Doc 685-2      Filed 03/15/23      Page 6 of 8

Weil, Gotshal & Manges LLP
767 Fifth Avenue
New York, NY 10153
candace.arthur@weil.com
+1 212 310 8324 Direct
+1 212 310 8007 Fax


       On Jan 4, 2023, at 11:36 AM, Bromley, James L.
       <bromleyj@sullcrom.com> wrote:


       Ted,
       Thanks for getting back to me so quickly. I am in depositions tomorrow
       until 5:30. I can talk after that if it works for you.
       Jim




       From: Tsekerides, Theodore <theodore.tsekerides@weil.com>
       Date: Wednesday, Jan 04, 2023 at 11:09 AM
       To: Bromley, James L. <bromleyj@sullcrom.com>
       Cc: Mehta, Suniti N. <mehtas@sullcrom.com>, Davidoff, Amanda Flug
       <davidoffa@sullcrom.com>, Arthur, Candace M.
       <Candace.Arthur@weil.com>, Hwangpo, Natasha
       <Natasha.Hwangpo@weil.com>, Bentley, Chase
       <Chase.Bentley@weil.com>
       Subject: [EXTERNAL] Re: KServicing/Amex

       Thanks Jim. We agree it would make a lot of sense to discuss. Would
       you happen to have any availability tomorrow?

       Much appreciated.


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


              On Jan 4, 2023, at 10:33 AM, Bromley, James L.
              <bromleyj@sullcrom.com> wrote:


              Ted,

              Hope you enjoyed the holidays. We understand that
              KServicing has approached American Express about
              options for ongoing loan servicing following bankruptcy.
              It would be helpful to find a time to discuss the current
              status of your investigation with respect to the
                                          5
                      Case 22-10951-CTG           Doc 685-2      Filed 03/15/23      Page 7 of 8

                                bankruptcy and American Express, in order to facilitate
                                a conversation about options for loan servicing and
                                American Express’s role. Please let us know if you have
                                availability this week or early next week to discuss.

                                Best regards,

                                Jim


                                James L. Bromley
                                Sullivan & Cromwell LLP | 125 Broad Street |
                                New York, NY 10004‐2498
                                T: (212) 558‐4923 | F: (212) 291‐3588 | C: (973) 901‐
                                6898
                                bromleyj@sullcrom.com | http://www.sullcrom.com



                                This e‐mail is sent by a law firm and contains
                                information that may be privileged and confidential. If
                                you are not the intended recipient, please delete the e‐
                                mail and notify us immediately.




                        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
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                        **This is an external message from: theodore.tsekerides@weil.com
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        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
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        distribution or copying of this communication is strictly prohibited. If you have received this
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The information contained in this email message is intended only for use of the individual or entity named above. If the
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                                                            6
                      Case 22-10951-CTG            Doc 685-2      Filed 03/15/23       Page 8 of 8

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.




                                                             7


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