Notice of Agenda of Matters Scheduled for Hearing on March 10, 2025 — In re KServicing Wind Down Corp., Case 22-10951-CTG, Doc. 1118 (Filed 03/06/25)
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Notice of Agenda of Matters Scheduled for Hearing on MARCH 10, 2025 AT 2:30 P.M. (ET), Doc 1118, filed 03/06/25 in Case No. 22-10951 (CTG) in the United States Bankruptcy Court for the District of Delaware, in the case of KServicing Wind Down Corp., et al., Post-Confirmation Debtors. The hearing has been cancelled with permission of the Court because no matters are scheduled to go forward. The adjourned matters are KServicing Wind Down Corporation's Third and Fourth (Substantive) Omnibus Objections to Proofs of Claim [PPP Borrower Claims], both filed September 30, 2024, with informal responses and several filed responses listed. The status says orders sustaining the Third and Fourth Omnibus Objections were entered on November 1, 2024 other than continued matters, and that the hearing on two responses is adjourned to April 1, 2025 at 10:00 a.m. (ET).
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“Notice of Agenda of Matters Scheduled for Hearing on March 10, 2025 — In re KServicing Wind Down Corp., Case 22-10951-CTG, Doc. 1118 (Filed 03/06/25).”
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Case 22-10951-CTG Doc 1118 Filed 03/06/25 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 MARCH 10, 2025 AT 2:30 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.
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Case 22-10951-CTG Doc 1118 Filed 03/06/25 Page 2 of 5
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].
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 April 1, 2025 at 10:00 a.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).
2
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Case 22-10951-CTG Doc 1118 Filed 03/06/25 Page 3 of 5
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].
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].
3
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Case 22-10951-CTG Doc 1118 Filed 03/06/25 Page 4 of 5
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].
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 April 1, 2025 at 10:00 a.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]
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Case 22-10951-CTG Doc 1118 Filed 03/06/25 Page 5 of 5
Dated: March 6, 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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