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Notice of Submission of Proofs of Claim — KServicing

Summary

A Notice of Submission of Proofs of Claim filed October 10, 2024 as Doc 1057 in In re 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 Third (Substantive) Omnibus Objection to Proofs of Claim [PPP Borrower Claims], filed September 30, 2024 as Docket No. 1053, with a hearing set for November 4, 2024 at 10:00 a.m. (ET). The notice states that, under Del. Bankr. L.R. 3007-1(e)(iv), copies of the objected-to proofs of claim were delivered to Chambers with the objection, and that parties may request copies from counsel. It is signed by Eric J. Monzo of Morris James LLP, and its signature block lists Morris James LLP and Perkins Coie LLP as counsel to the post-confirmation debtors.

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               Case 22-10951-CTG              Doc 1057        Filed 10/10/24        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. 1053

      NOTICE OF SUBMISSION OF PROOFS OF CLAIM IN CONNECTION WITH
    KSERVICING WIND DOWN CORPORATION’S THIRD (SUBSTANTIVE) OMNIBUS
          OBJECTION TO PROOFS OF CLAIM [PPP BORROWER CLAIMS]

         On September 30, 2024, 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 Third

(Substantive) Omnibus Objection to Proofs of Claim [PPP Borrower Claims] [Docket No. 1053]

(the “Objection”) with the United States Bankruptcy Court for the District of Delaware. A hearing

on the Objection is to be held on November 4, 2024 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.

            Case 22-10951-CTG        Doc 1057     Filed 10/10/24    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: October 10, 2024                           MORRIS JAMES LLP

                                                  /s/ Eric J. Monzo
                                                  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: 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)
                                                  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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