In re KServicing Wind Down Corp — Notice of Submission of Proofs of Claim re Fifth Omnibus Objection

Summary

A Notice of Submission of Proofs of Claim filed December 31, 2025 as Doc 1190 in the jointly administered Chapter 11 cases of KServicing Wind Down Corp., et al., Case No. 22-10951 (CTG), in the U.S. Bankruptcy Court for the District of Delaware. It relates to KServicing Wind Down Corporation's Fifth (Substantive) Omnibus Objection to certain no liability claims and unliquidated claims, filed December 15, 2025 as Docket No. 1185. The notice states that a hearing on the objection is set for January 14, 2026 at 10:00 a.m. (ET) and that copies of the challenged proofs of claim were delivered to Chambers under Del. Bankr. L.R. 3007-1(e)(iv). Parties may request copies from counsel. It is signed by Morris James LLP and also carries the signature block of Perkins Coie LLP, as counsel to the Post-Confirmation Debtors.

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                  Case 22-10951-CTG           Doc 1190        Filed 12/31/25        Page 1 of 2




                         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)

                                                           Re: Docket No. 1185

             NOTICE OF SUBMISSION OF PROOFS OF CLAIM IN CONNECTION
                 WITH KSERVICING WIND DOWN CORPORATION’S FIFTH
                    (SUBSTANTIVE) OMNIBUS OBJECTION TO CERTAIN
               (I) NO LIABILITY CLAIMS, AND (II) UNLIQUIDATED CLAIMS

         On December 15, 2025, KServicing Wind Down Corporation (“KServicing WD”) and its

affiliates, as successors to Kabbage, Inc. d/b/a KServicing (“KServicing”) and its affiliates, by and

through their undersigned counsel, filed the KServicing Wind Down Corporation’s Fifth

(Substantive) Omnibus Objection to Certain (I) No Liability Claims, and (II) Unliquidated Claims

[Docket No. 1185] (the “Objection”) with the United States Bankruptcy Court for the District of

Delaware. A hearing on the Objection is to be held on January 14, 2026 at 10:00 a.m. (ET).

         Pursuant to Del. Bankr. L.R. 3007-1(e)(iv), copies of the proofs of claim (the “Proofs of

Claim”) 2 to which KServicing WD objected to under Del. Bankr. L.R. 3007-1 have been delivered

to Chambers together with a copy of the Objection.

             This notice of submission of proofs of claims has been served upon all parties requesting

notice under Fed. R. Bankr. P. 2002 in compliance with Del. Bankr. L.R. 3007-1(e)(iv)(C). Any


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
  Pursuant to the Local Rules, a copy of all claims referenced in the Objection have been included in the submission
to Chambers.


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             Case 22-10951-CTG       Doc 1190     Filed 12/31/25    Page 2 of 2




parties who wish to acquire copies of the Proofs of Claim may do so by making a request to the

undersigned counsel.

Dated: December 31, 2025                          MORRIS JAMES LLP

                                                  /s/ Samantha L. Rodriguez
                                                  Eric J. Monzo (DE Bar No. 5214)
                                                  Brya M. Keilson (DE Bar No. 4643)
                                                  Samantha L. Rodriguez (DE Bar No. 7524)
                                                  3205 Avenue North Blvd., Suite 100
                                                  Wilmington, Delaware 19803
                                                  Telephone: (302) 888-6800
                                                  Facsimile: (302) 571-1750
                                                  E-mail: emonzo@morrisjames.com
                                                  E-mail: bkeilson@morrisjames.com
                                                  E-mail: srodriguez@morrisjames.com

                                                  and

                                                  PERKINS COIE LLP
                                                  Bradley A. Cosman (admitted pro hac vice)
                                                  Kathleen Allare (admitted pro hac vice)
                                                  2525 E. Camelback Road, Suite 500
                                                  Phoenix, Arizona 85016-4227
                                                  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, 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




                                              2
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