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Notice Of Agenda Of Matters Scheduled

Summary

In the United States Bankruptcy Court for the District of Delaware, In re KServicing Wind Down Corp., et al., Post-Confirmation Debtors, Case No. 22-10951 (CTG), Doc 1115 filed 02/14/25 is a Notice of Agenda of Matters Scheduled for Hearing on February 19, 2025 at 10:00 a.m. (ET), stating the hearing has been cancelled with permission of the Court because no matters are going forward. The agenda lists adjourned matters concerning KServicing Wind Down Corporation's Third and Fourth (Substantive) Omnibus Objections to Proofs of Claim [PPP Borrower Claims], filed September 30, 2024, with the informal responses and related orders. It states that the Third Omnibus Objection was sustained by order at Docket No. 1073 other than continued matters, and that hearings on two responses are adjourned to March 10, 2025 at 2:30 p.m. (ET).

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“Notice Of Agenda Of Matters Scheduled.” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-deb-188293-1115-0-0438a13f76/, SHA-256 80df2b78d599d659ab89d9d9b2d581fb2caf119ddde5771cb60383e19d380855.

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               Case 22-10951-CTG              Doc 1115        Filed 02/14/25        Page 1 of 5




                       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)


                    NOTICE OF AGENDA OF MATTERS SCHEDULED
                 FOR HEARING ON FEBRUARY 19, 2025 AT 10:00 A.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).

             F. Response of Creative Property Preservation Inc. to Third Omnibus Objection to

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.



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                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].

         Status: The informal responses of Build by Brenda, Inc., Margaret Kokah, and Christine
         Hare are resolved. The response of Creative Property Preservation has been resolved by
         stipulation. The hearing on the responses of Clutter Control, LLC and Bais Medrash
         L'Torah are adjourned to March 10, 2025 at 2:30 p.m. (ET). An Order has been entered by
         the Court sustaining the Third Omnibus Objection [Docket No. 1073], other than those
         continued matters.

    2. 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).



                                                2
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             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].

             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].

         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].


                                               3
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             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].

         Status: The response of Michael Rischer is resolved. The responses of Neuro Connections
         Occupational Therapy LLC, Ina McGuinness, and Thweatt Management Consultants have
         been resolved by stipulation. The hearing on the responses of R & G Springs Co. Inc.,
         Prime Painting and Finishing LLC, Tinton Falls Limousine, LLC, and Pia Hoyt LLC are
         adjourned to March 10, 2025 at 2:30 p.m. (ET). An Order has been entered by the Court
         sustaining the Fourth Omnibus Objection [Docket No. 1074], other than those continued
         matters.

                                   [Signature Page to Follow]




                                                4
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Dated: February 14, 2025             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, Delaware 19801
                                     Telephone: (302) 888-6800
                                     Facsimile: (302) 571-1750
                                     E-mail: 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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