Notice Of Appearance And Request For Service (Doc 111)
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A Notice of Appearance and Request for Service (Doc 111) in Case No. 22-10951 (CTG), the jointly administered chapter 11 cases of Kabbage, Inc. d/b/a KServicing, and its debtor affiliates. It states that Quinn Emanuel Urquhart & Sullivan, LLP and Benesch, Friedlander, Coplan & Aronoff, LLP enter their appearance as counsel for Cross River Bank. It requests that copies of all notices and papers filed or entered in the cases be served on them under sections 342 and 1109(b) of the Bankruptcy Code.
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“Notice Of Appearance And Request For Service (Doc 111).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-deb-188293-111-0-4983ee0f34/
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Case 22-10951-CTG Doc 111 Filed 10/18/22 Page 1 of 3
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re: Chapter 11
KABBAGE, INC. d/b/a KSERVICING, et al., 1 Case No. 22-10951 (CTG)
Debtors. Jointly Administered
NOTICE OF APPEARANCE AND REQUEST FOR SERVICE
PLEASE TAKE NOTICE that Quinn Emanuel Urquhart & Sullivan, LLP and Benesch,
Friedlander, Coplan & Aronoff, LLP hereby enter their appearance (the “Notice of Appearance”)
in the above-captioned jointly administered cases as counsel for Cross River Bank (“CRB”),
pursuant to sections 342 and 1109(b) of title 11 of the United States Code, 11 U.S.C §§ 101-1532
(as amended, the “Bankruptcy Code”), and Rules 2002, 3017, 9007 and 9010 of the Federal Rules
of Bankruptcy Procedure (as amended, the “Bankruptcy Rules”), and request that copies of any
and all notices and papers filed or entered in these cases be given to and served upon the following:
Susheel Kirpalani, Esq. Gregory W. Werkheiser, Esq.
QUINN EMANUEL URQUHART & SULLIVAN, LLP BENESCH, FRIEDLANDER, COPLAN
51 Madison Avenue, 22nd Floor & ARONOFF LLP
New York, NY 10010 1313 N. Market St., Suite 1201
Telephone: (212) 849-7000 Wilmington, DE 19801
Email: susheelkirpalani@quinnemanuel.com Telephone: (302) 442-7010
Facsimile: (302) 442-7012
-and- Email: gwerkheiser@beneschlaw.com
Matthew R. Scheck, Esq.
QUINN EMANUEL URQUHART & SULLIVAN, LLP
300 West 6th St, Suite 2010
Austin, TX 78701
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). Kabbage is a trademark of American Express used under license;
Kabbage, Inc. d/b/a KServicing is not affiliated with American Express. The Debtors’ mailing and service address is
925B Peachtree Street NE, Suite 383, Atlanta, GA 30309.
Case 22-10951-CTG Doc 111 Filed 10/18/22 Page 2 of 3
Telephone: (737) 667-6100
Email: matthewscheck@quinnemanuel.com
PLEASE TAKE FURTHER NOTICE that this constitutes not only a request for service
of the notices and papers referred to in the Bankruptcy Rules specified above, but also includes,
without limitation, a request for service of all orders and notices of any application, motion,
petition, pleading, request, complaint, or demand, whether formal or informal, whether written or
oral, and whether transmitted or conveyed by mail, courier service, hand delivery, telephone,
facsimile transmission, telegraph, telex, e-mail, or otherwise.
PLEASE TAKE FURTHER NOTICE that this Notice of Appearance and any
subsequent appearance, pleading, claim, or suit is not intended nor shall be deemed to waive the
rights of CRB: (1) to have an Article III judge adjudicate in the first instance any case, proceeding,
matter, or controversy as to which a bankruptcy judge may not enter a final order or judgment
consistent with Article III of the United States Constitution; (2) to have final orders in a non-core
case, proceeding, matter, or controversy entered only after an opportunity to object to proposed
findings of fact and conclusions of law and a de novo review by a district court judge; (3) to trial
by jury in any case, proceeding, matter, or controversy so triable; (4) to have the reference
withdrawn by the United States District Court in any case, proceeding, matter, or controversy
subject to mandatory or discretionary withdrawal; or (5) any other rights, claims, actions, defenses,
setoffs, or recoupments to which CRB is or may be entitled under agreements, in law, or in equity,
all of which rights, claims, actions, defenses, setoffs, and recoupments expressly are hereby
reserved.
2
Case 22-10951-CTG Doc 111 Filed 10/18/22 Page 3 of 3
Dated: October 18, 2022 BENESCH, FRIEDLANDER, COPLAN & ARONOFF LLP
Wilmington, Delaware
/s/ Gregory W. Werkheiser
Gregory W. Werkheiser (DE #3553)
1313 N. Market Street, Suite 1201
Wilmington, DE 19801
Telephone: (302) 442-7010
Email: gwerkheiser@beneschlaw.com
-and-
QUINN EMANUEL URQUHART & SULLIVAN, LLP
Susheel Kirpalani, Esq.
51 Madison Avenue, 22nd Floor
New York, NY 10010
Telephone: (212) 849-7000
Email: susheelkirpalani@quinnemanuel.com
Matthew R. Scheck, Esq.
300 West 6th St, Suite 2010
Austin, TX 78701
Telephone: (737) 667-6100
Email: matthewscheck@quinnemanuel.com
Counsel for Cross River Bank
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