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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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
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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.
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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
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