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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 15, 2023 at 4:00 p.m. (ET)
Hearing Date: August 22, 2023 at 1:00 p.m. (ET)
NOTICE OF MOTION OF POST-CONFIRMATION DEBTORS, FOR AN ORDER
TERMINATING OMNI AGENT SOLUTIONS, INC. AS CLAIMS AND NOTICING
AGENT EFFECTIVE JULY 26, 2023 AND DIRECTING DELIVERY OF CLAIMS AND
CLAIMS RECORDS
PLEASE TAKE NOTICE that on July 26, 2023, counsel to the post-confirmation
debtors in the above-referenced bankruptcy case (the “Post-Confirmation Debtors”) filed its
Motion of Post-Confirmation Debtors, for an Order Terminating Omni Agent Solutions, Inc. as
Claims and Noticing Agent Effective July 26, 2023 and Directing Delivery of Claims and Claims
Records (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 15, 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 928-1 Filed 07/26/23 Page 1 of 2
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Dated: July 26, 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 928-1 Filed 07/26/23 Page 2 of 2