Certificate of No Objection — In re Kabbage, Inc. d/b/a KServicing (Case No. 22-10951, Doc 310)

Summary

In the United States Bankruptcy Court District of Delaware, In re Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), Doc 310 filed 12/01/22, regarding Docket No. 284, is a Certificate of No Objection regarding the Debtors' Motion for an Order Extending the Deadline by Which the Debtors May Remove Civil Actions. It certifies that no answer, objection or other responsive pleading was received to the motion filed November 23, 2022, with the objection deadline of November 30, 2022 at 4:00 p.m. (prevailing Eastern Time). The Debtors request that an order substantially in the form of Exhibit A be entered. It is dated December 1, 2022 and signed /s/ Matthew P. Milana of Richards, Layton & Finger, P.A.

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“Certificate of No Objection — In re Kabbage, Inc. d/b/a KServicing (Case No. 22-10951, Doc 310).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-deb-188293-310-0-3e9a79d30d/, SHA-256 bd61f4c1f432ec09e4150217f178aaaa23f56e8f935687190f2bfd71c2c1fd6e.

Full text

Case 22-10951-CTG Doc 310 Filed 12/01/22 Page 1 of 2

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. 284
------------------------------------------------------------ x

CERTIFICATE OF NO OBJECTION REGARDING
DEBTORS’ MOTION FOR AN ORDER (I) EXTENDING THE
DEADLINE BY WHICH THE DEBTORS MAY REMOVE
CIVIL ACTIONS, 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 Debtors’ Motion for an Order (I) Extending the Deadline by Which the Debtors

May Remove Civil Actions, and (II) Granting Related Relief [Docket No. 284] (the “Motion”)

filed by the Debtors with the United States Bankruptcy Court for the District of Delaware (the

“Court”) on November 23, 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 no later than

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.

RLF1 28278505v.1

Case 22-10951-CTG Doc 310 Filed 12/01/22 Page 2 of 2

November 30, 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.

Dated: December 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

2
RLF1 28278505v.1

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