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Certificate of No Objection re Transfer Restrictions — In re Kabbage, Inc. d/b/a KServicing (Bankr. D. Del.)

Summary

A Certificate of No Objection filed November 1, 2022 as Doc 187 in the jointly administered Chapter 11 cases of Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), in the U.S. Bankruptcy Court for the District of Delaware. It certifies that the Debtors received no answer, objection or other responsive pleading to their motion filed October 3, 2022 at Docket No. 6 seeking orders establishing notification procedures and approving restrictions on certain transfers of interests in the Debtors. It states that under the interim order at Docket No. 71 the deadline for objections to final relief was October 31, 2022 at 4:00 p.m. (prevailing Eastern Time). The Debtors ask that an order substantially in the form of Exhibit A be entered. It is signed by Matthew P. Milana of Richards, Layton & Finger, P.A., with Weil, Gotshal & Manges LLP also listed as attorneys for the Debtors.

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                   Case 22-10951-CTG             Doc 187         Filed 11/01/22       Page 1 of 3




                               UNITED STATES BANKRUPTCY COURT
                                    DISTRICT OF DELAWARE

------------------------------------------------------------ x
In re                                                        :         Chapter 11
                                                             :
KABBAGE, INC. d/b/a KSERVICING, et al., :                              Case No. 22-10951 (CTG)
                                                             :
                                                             :
                             1
                  Debtors.                                   :         (Jointly Administered)
                                                             :
                                                             :         Re: Docket Nos. 6, 71 & 83
------------------------------------------------------------ x

                CERTIFICATE OF NO OBJECTION REGARDING
       MOTION OF DEBTORS FOR ENTRY OF INTERIM AND FINAL ORDERS
         ESTABLISHING NOTIFICATION PROCEDURES AND APPROVING
     RESTRICTIONS ON CERTAIN TRANSFERS OF INTERESTS IN THE DEBTORS

           The undersigned hereby certifies that Kabbage, Inc. d/b/a KServicing and its debtor

affiliates, as debtors and debtors in possession in the above-captioned chapter 11 cases

(collectively, the “Debtors”), have received no answer, objection or any other responsive pleading

with respect to the Motion of Debtors for Entry of Interim and Final Orders Establishing

Notification Procedures and Approving Restrictions on Certain Transfers of Interests in the

Debtors [Docket No. 6] (the “Motion”) filed by the Debtors with the United States Bankruptcy

Court for the District of Delaware (the “Court”) on October 3, 2022. The undersigned further

certifies that no answer, objection or other responsive pleading to the Motion has appeared on the

Court’s docket in the above-captioned chapter 11 cases.                       Pursuant to the Interim Order

Establishing Notification Procedures and Approving Restrictions on Certain Transfers of Interests




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.



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                   Case 22-10951-CTG    Doc 187     Filed 11/01/22     Page 2 of 3




in the Debtors [Docket No. 71] and the Notice of (A) Entry of Interim Order Establishing

Notification Procedures and Approving Restrictions on Certain Transfers of Interests in the

Debtors; and (B) Final Hearing Thereon, any objection or response to the final relief requested in

the Motion was to be filed and served no later than October 31, 2022 at 4:00 p.m. (prevailing

Eastern Time).

         WHEREFORE, the Debtors respectfully request that an order, substantially in the form

attached hereto as Exhibit A, be entered at the earliest convenience of the Court.




                                                2
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                   Case 22-10951-CTG   Doc 187     Filed 11/01/22   Page 3 of 3




 Dated: November 1, 2022
        Wilmington, Delaware
                                       /s/ Matthew P. Milana
                                       RICHARDS, LAYTON & FINGER, P.A.
                                       Daniel J. DeFranceschi, Esq. (No. 2732)
                                       Amanda R. Steele, Esq. (No. 5530)
                                       Zachary I. Shapiro, Esq. (No. 5103)
                                       Matthew P. Milana, Esq. (No. 6681)
                                       One Rodney Square
                                       920 North King Street
                                       Wilmington, Delaware 19801
                                       Telephone: (302) 651-7700
                                       E-mail: defranceschi@rlf.com
                                               steele@rlf.com
                                               shapiro@rlf.com
                                               milana@rlf.com

                                       -and-

                                       WEIL, GOTSHAL & MANGES LLP
                                       Ray C. Schrock, P.C. (admitted pro hac vice)
                                       Candace M. Arthur, Esq. (admitted pro hac vice)
                                       Natasha S. Hwangpo, Esq. (admitted pro hac vice)
                                       Chase A. Bentley, Esq. (admitted pro hac vice)
                                       767 Fifth Avenue
                                       New York, New York 10153
                                       Telephone: (212) 310-8000
                                       E-mail:       ray.schrock@weil.com
                                                     candace.arthur@weil.com
                                                     natasha.hwangpo@weil.com
                                                     chase.bentley@weil.com

                                       Attorneys for Debtors
                                       and Debtors in Possession




                                               3
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