Amended Notice of Agenda for July 2, 2025 Hearing — In re KServicing Wind Down Corp. (Bankr. D. Del.)
- Date
- 2024-09-30
Summary
An Amended Notice of Agenda of Matters Scheduled for Hearing on July 2, 2025 at 2:00 p.m. (ET), filed June 30, 2025 as Doc 1163 in In re: KServicing Wind Down Corp., et al., Case No. 22-10951 (CTG), a jointly administered Chapter 11 case in the United States Bankruptcy Court for the District of Delaware. The notice states that the hearing was cancelled with the court's permission because no matters were scheduled to go forward. It lists the Third (Substantive) Omnibus Objection to PPP borrower proofs of claim (Docket No. 1053) as adjourned, the Fourth Motion to extend the claims objection deadline (Docket No. 1150) as resolved by order, and the Fourth (Substantive) Omnibus Objection (Docket No. 1054) with its responses, stipulations and status. It records a hearing on one claimant's response set for August 5, 2025. Counsel to the Post-Confirmation Debtors signed the six-page notice.
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Case 22-10951-CTG Doc 1163 Filed 06/30/25 Page 1 of 6
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re: Chapter 11
KServicing Wind Down Corp., et al.,1 Case No. 22-10951 (CTG)
Post-Confirmation Debtors. (Jointly Administered)
AMENDED2 NOTICE OF AGENDA OF MATTERS SCHEDULED
FOR HEARING ON JULY 2, 2025 AT 2:00 P.M. (ET)
** AS NO MATTERS ARE SCHEDULED TO GO FORWARD, THIS HEARING HAS
BEEN CANCELLED WITH PERMISSION OF THE COURT **
ADJOURNED MATTERS:
1. KServicing Wind Down Corporation's Third (Substantive) Omnibus Objection to Proofs
of Claim [PPP Borrower Claims] [Filed September 30, 2024; Docket No. 1053].
Objection Deadline: October 28, 2024 at 4:00 p.m. (ET); extended to January 31, 2025 for
Creative Property Preservation Inc.
Responses/Objections Received:
A. Informal response received from Built By Brenda, Inc. (Claim C951-187).
B. Informal response received from Clutter Control, LLC (Claims C951-179 and
C951-178).
C. Informal response received from Christine Hare (Claim C951-93).
D. Informal response received from Margaret Kokah (Claim C951-240).
E. Informal response received from Bais Medrash L'Torah (Claim No. C951-112).
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: KServicing Wind Down Corp. (f/k/a Kabbage, Inc. d/b/a KServicing) (3937); KServicing
Wind Down Canada Holdings LLC (f/k/a Kabbage Canada Holdings, LLC) (N/A); KServicing Wind Down Asset
Securitization LLC (f/k/a Kabbage Asset Securitization LLC) (N/A); KServicing Wind Down Asset Funding 2017-A
LLC (f/k/a Kabbage Asset Funding 2017-A LLC) (4803); KServicing Wind Down Asset Funding 2019-A LLC (f/k/a
Kabbage Asset Funding 2019-A LLC) (8973); and KServicing Wind Down Diameter LLC (f/k/a Kabbage Diameter,
LLC) (N/A). The Debtors’ mailing and service address is 925B Peachtree Street NE, Suite 383, Atlanta, GA 30309.
2
Amended items appear in BOLD.
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Case 22-10951-CTG Doc 1163 Filed 06/30/25 Page 2 of 6
F. Response of Creative Property Preservation Inc. to Third Omnibus Objection to
Claims (Claims C951-251 and C951-74) [Filed October 30, 2024; Docket No.
1066].
G. Letter and Proof of Federal Deployment (Creative Property Preservation) [Filed
November 1, 2024; Docket No. 1072].
Related Documents:
A. Notice of Submission of Proof of Claim in Connection with KServicing Wind
Down Corporation's Third (Substantive) Omnibus Objection to Proofs of Claim
[PPP Borrower Claims] [Filed October 10, 2024; Docket No. 1057].
B. Certification of Counsel Regarding Order Sustaining KServicing Wind Down
Corporation's Third (Substantive) Omnibus Objection to Proofs of Claim [PPP
Borrower Claims] [Filed October 31, 2024; Docket No. 1068].
C. Order Sustaining KServicing Wind Down Corporation's Third (Substantive)
Omnibus Objection to Proofs of Claim [PPP Borrower Claims] [Entered
November 1, 2024; Docket No. 1073].
D. Order Regarding Creative Property Preservation Inc.'s Response to Disallowance
of Claims [Entered December 11, 2024; Docket No. 1091].
E. Certification of Counsel Regarding Order Approving Stipulation Between
KServicing and Creative Property Preservation Inc. [Filed January 15, 2025;
Docket No. 1105].
F. Order Approving Stipulation Between KServicing and Creative Property
Preservation Inc. [Entered January 16, 2025; Docket No. 1109].
G. Certification of Counsel Regarding Order Approving Stipulation Between
KServicing and Clutter Control, LLC [Filed April 2, 2025; Docket No. 1126].
H. Order Approving Stipulation Between KServicing and Clutter Control, LLC
[Entered April 3, 2025; Docket No. 1127].
Status: The informal responses of Build by Brenda, Inc., Margaret Kokah, and Christine
Hare are resolved. The responses of Creative Property Preservation and Clutter Control,
LLC have been resolved by stipulation. An Order has been entered by the Court sustaining
the Third Omnibus Objection [Docket No. 1073], other than those continued matters. With
respect to the response of Bais Medrash L'Torah, the Post-Confirmation Debtors believe
this matter has been resolved and are working through the terms of the resolution.
2
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Case 22-10951-CTG Doc 1163 Filed 06/30/25 Page 3 of 6
RESOLVED MATTERS:
2. Fourth Motion of the KServicing Wind Down Corp. for Entry of an Order Extending the
Claims Objection Deadline [Filed June 11, 2025; Docket No. 1150].
Objection Deadline: June 25 2025 at 4:00 p.m. (ET).
Responses/Objections Received: None.
Related Documents:
A. Certificate of No Objection Regarding Fourth Motion of the KServicing Wind
Down Corp. for Entry of an Order Extending the Claims Objection Deadline
[Filed June 29, 2025; Docket No. 1160].
B. Order Extending the Claims Objection Deadline [Entered June 30, 2025; Docket
No. 1161].
Status: An order has been entered by the Court. Accordingly, a hearing on this matter is
no longer required.
MATTERS GOING FORWARD:
3. KServicing Wind Down Corporation's Fourth (Substantive) Omnibus Objection to Proofs
of Claim [PPP Borrower Claims] [Filed September 30, 2024; Docket No. 1054].
Objection Deadline: October 28, 2024 at 4:00 p.m. (ET).
Responses/Objections Received:
A. Informal response received from R & G Springs Co. Inc. (Claim C951-236).
B. Informal response received from Ina McGuinness for McGuinness
Communications (Claim C951-176).
C. Informal response received from Michael Rischer (Claim C951-140).
D. Informal response received from Prime Painting and Finishing LLC (Claim C951-
122).
E. Informal response received from Neuro Connections Occupational Therapy LLC
(Claim C951-126).
F. Response of Tinton Falls Limousine, LLC to Fourth Omnibus Objection to Claims
(Claim C951-183) [Filed October 23, 2024; Docket No. 1062].
3
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Case 22-10951-CTG Doc 1163 Filed 06/30/25 Page 4 of 6
G. Response of Thweatt Management Consultants to Fourth Omnibus Objection to
Claims (Claim C951-77) [Filed October 28, 2024; Docket No. 1063].
H. Response of Pia Hoyt LLC to Fourth Omnibus Objection to Claims (Claim C951-
97) [Filed October 28, 2024; Docket No. 1064].
I. Letter to the Honorable Craig T. Goldblatt from Richard Calanni Regarding Tinton
Falls Limousine, LLC’s Claim Objection [Received May 14, 2025; Docket
No. 1141]
Related Documents:
A. Notice of Submission of Proof of Claim in Connection with KServicing Wind
Down Corporation's Fourth (Substantive) Omnibus Objection to Proofs of Claim
[PPP Borrower Claims] [Filed October 10, 2024; Docket No. 1058].
B. Certification of Counsel Regarding Order Sustaining KServicing Wind Down
Corporation's Fourth (Substantive) Omnibus Objection to Proofs of Claim [PPP
Borrower Claims] [Filed October 31, 2024; Docket No. 1069].
C. Order Sustaining KServicing Wind Down Corporation's Fourth (Substantive)
Omnibus Objection to Proofs of Claim [PPP Borrower Claims] [Entered
November 1, 2024; Docket No. 1074].
D. Certification of Counsel Regarding Order Approving Stipulation Between
KServicing and Ina McGuinness [Filed January 14, 2025; Docket No. 1103].
E. Certification of Counsel Regarding Order Approving Stipulation Between
KServicing and Thweatt Management Consultants [Filed January 14, 2025;
Docket No. 1104].
F. Order Approving Stipulation Between KServicing and Ina McGuinness [Entered
January 16, 2025; Docket No. 1107].
G. Order Approving Stipulation Between KServicing and Thweatt Management
Consultants [Entered January 16, 2025; Docket No. 1108].
H. Certification of Counsel Regarding Order Approving Stipulation Between
KServicing and Neuro Connections Occupational Therapy LLC [Filed February
6, 2025; Docket No. 1112].
I. Order Approving Stipulation Between KServicing and Neuro Connections
Occupational Therapy LLC [Entered February 10, 2025; Docket No. 1113].
J. Notice of Withdrawal of Objection to Claim No. 97 (Pia Hoyt LLC) [Filed April
17, 2025; Docket No. 1130].
4
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Case 22-10951-CTG Doc 1163 Filed 06/30/25 Page 5 of 6
K. Certification of Counsel Regarding Order Approving Stipulation between
KServicing and R & G Springs Co. Inc. [Filed April 22, 2025; Docket No. 1132].
L. Order Approving Stipulation between KServicing and R & G Springs Co. Inc.
[Entered April 22, 2025; Docket No. 1133].
M. KServicing's Exhibit List for Hearing on May 7, 2025 at 10:00 a.m. (ET) [Filed
May 5, 2025; Docket No. 1135].
Status: The response of Michael Rischer is resolved. The responses of Neuro Connections
Occupational Therapy LLC, Ina McGuinness, Thweatt Management Consultants, and R &
G Springs Co. Inc. have been resolved by stipulation. The objection to Pia Hoyt LLC’s
Claim No. 97 has been withdrawn. An Order has been entered by the Court sustaining the
Fourth Omnibus Objection [Docket No. 1074], other than those continued matters. With
respect to the response of Prime Painting and Finishing LLC, the Post-Confirmation
Debtors believe this matter has been resolved and are working through the terms of the
resolution. With respect to the response of Tinton Falls Limousine, LLC, the Post-
Confirmation Debtors have spoken with Mr. Calanni and mutually agree to set the
hearing regarding the response of Tinton Falls Limousine, LLC for August 5, 2025 at
11:00 a.m. (ET).
[Signature Page to Follow]
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Case 22-10951-CTG Doc 1163 Filed 06/30/25 Page 6 of 6
Dated: June 30, 2025 MORRIS JAMES LLP
Wilmington, Delaware
/s/ Carl N. Kunz, III
Carl N. Kunz, III (DE Bar No. 3201)
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, Delaware 19801
Telephone: (302) 888-6800
Facsimile: (302) 571-1750
E-mail: ckunz@morrisjames.com
emonzo@morrisjames.com
bkeilson@morrisjames.com
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, Arizona 85012-2788
Telephone: (602) 351-8000
Facsimile: (602) 648-7000
E-mail: BCosman@perkinscoie.com
KAllare@perkinscoie.com
and
John D. Penn (admitted pro hac vice)
500 North Akard Street, Suite 3300
Dallas, Texas 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
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