Notice of Motion to Amend Case Caption — In re Kabbage (KServicing)

Summary

Notice of Motion of the Post-Confirmation Debtors for Entry of an Order Amending Case Caption, Doc 910-1 filed July 20, 2023 in Chapter 11 Case No. 22-10951 (CTG), In re Kabbage, Inc. d/b/a KServicing, et al., in the U.S. Bankruptcy Court for the District of Delaware. The notice states that on July 20, 2023 counsel to the Post-Confirmation Debtors filed their Motion of the Post Confirmation Debtors for Entry of an Order Amending Case Caption. It sets an objection deadline of August 3, 2023 at 4:00 p.m. (ET) and a hearing before the Honorable Craig T. Goldblatt on August 22, 2023 at 1:00 p.m. It is signed /s/ Brya M. Keilson of Morris James LLP, counsel to the Post-Confirmation Debtors, operating as the Wind Down Estates.

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16212813/2
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re:
KABBAGE, INC. d/b/a KSERVICING, et al.,1
Debtors.
Chapter 11

Case No. 22-10951 (CTG)

(Jointly Administered)

Obj. Deadline: August 3, 2023 at 4:00 p.m. (ET)
Hearing Date: August 22, 2023 at 1:00 p.m. (ET

NOTICE OF MOTION OF THE POST-CONFIRMATION DEBTORS FOR
ENTRY OF AN ORDER AMENDING CASE CAPTION

PLEASE TAKE NOTICE that on July 20, 2023, counsel to the post-confirmation debtors
in the above-referenced bankruptcy case (the “Post-Confirmation Debtors”) filed its Motion of the
Post Confirmation Debtors for Entry of an Order Amending Case Caption (the “Motion”) with the
United States Bankruptcy Court for the District of Delaware (the “Bankruptcy Court”).
PLEASE TAKE FURTHER NOTICE that responses, if any, to the Motion must be in
writing, in conformity with the Federal Rules of Bankruptcy Procedure and the Local Rules of the
United States Bankruptcy Court for the District of Delaware, filed with the Bankruptcy Court so
as to be received on or before August 3, 2023 at 4:00 p.m. (ET) (the “Objection Deadline”). At
the same time, you must also serve a copy of the response upon the upon the undersigned
Post-Confirmation Debtors’ counsel:
PLEASE TAKE FURTHER NOTICE THAT a hearing on the Motion is scheduled for
August 22, 2023 at 1:00 p.m. prevailing Eastern Time before the Honorable Craig T. Goldblatt,
United States Bankruptcy Court for the District of Delaware, 824 North Market Street, 3rd Floor,
Courtroom #7, Wilmington, Delaware 19801.

IF NO OBJECTIONS ARE TIMELY FILED, SERVED, AND RECEIVED IN
ACCORDANCE WITH THIS NOTICE, THE COURT MAY GRANT THE RELIEF
REQUESTED IN CONNECTION WITH SUCH PLEADINGS WITHOUT FURTHER
NOTICE OR HEARING.

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). The Debtors’ mailing and service address is 925B Peachtree Street NE,
Suite 383, Atlanta, GA 30309.
Case 22-10951-CTG    Doc 910-1    Filed 07/20/23    Page 1 of 2

2

16212813/2
Dated: July 20, 2023

MORRIS JAMES LLP
/s/ Brya M. Keilson

Eric J. Monzo (DE Bar No. 5214)
Brya M. Keilson (DE Bar No. 4643)
Tara C. Pakrouh (DE Bar No. 6192)
500 Delaware Avenue, Suite 1500

Wilmington, DE 19801
Telephone: (302) 888-6800
Facsimile: (302) 571-1750
E-mail: emonzo@morrisjames.com
E-mail: bkeilson@morrisjames.com
E-mail: tpakrouh@morrisjames.com

and

PERKINS COIE LLP
Bradley A. Cosman (admitted pro hac vice)
Kathleen Allare (admitted pro hac vice)
2901 North Central Avenue, Suite 2000
Phoenix, AZ 85012-2788
Telephone: (602) 351-8000
Facsimile: (602) 648-7000
E-mail: BCosman@perkinscoie.com
E-mail: KAllare@perkinscoie.com

and

John D. Penn (admitted pro hac vice)
500 North Akard Street, Suite 3300
Dallas, TX  75201-3347
Telephone: (214) 965-7700
Facsimile: (214) 965-7799
E-mail: JPenn@perkinscoie.com

Counsel to the Post-Confirmation Debtors,
operating as the Wind Down Estates

Case 22-10951-CTG    Doc 910-1    Filed 07/20/23    Page 2 of 2

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