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Motion Of Debtors For Entry Of Order (I) Approving Debtors’

Summary

A certificate of no objection filed November 30, 2022 as Doc 308 in In re Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), a jointly administered Chapter 11 case in the U.S. Bankruptcy Court for the District of Delaware. It concerns the Motion of Debtors for Entry of Order (I) Approving Debtors' Retention Program for Certain Non-Executive Employees and (II) Granting Related Relief, Docket No. 253, filed November 15, 2022. The certificate states that the Debtors received no answer, objection or other responsive pleading by the November 29, 2022 deadline and that none appears on the docket. It asks 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.; the signature block also lists Weil, Gotshal & Manges LLP, as attorneys for the Debtors, and the certificate runs three pages.

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Full text

                   Case 22-10951-CTG             Doc 308         Filed 11/30/22       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)
                                                             :
                                                             :
                  Debtors.   1                               :         (Jointly Administered)
                                                             :
                                                             :         Re: Docket No. 253
------------------------------------------------------------ x

                 CERTIFICATE OF NO OBJECTION REGARDING
       MOTION OF DEBTORS FOR ENTRY OF ORDER (I) APPROVING DEBTORS’
             RETENTION PROGRAM FOR CERTAIN NON-EXECUTIVE
               EMPLOYEES AND (II) GRANTING RELATED RELIEF

           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 Order (I) Approving Debtors’ Retention

Program for Certain Non-Executive Employees and (II) Granting Related Relief [Docket No. 253]

(the “Motion”) filed by the Debtors with the United States Bankruptcy Court for the District of

Delaware (the “Court”) on November 15, 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 Notice of Motion and Hearing filed with the

Motion, any objection or response to the relief requested in the Motion was to be filed and served




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 308     Filed 11/30/22     Page 2 of 3




no later than November 29, 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 308     Filed 11/30/22   Page 3 of 3




 Dated: November 30, 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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