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Notice Of Filing Of Proposed Redacted Version Of Exhibits A And C

Summary

A Notice of Filing of Proposed Redacted Version of Exhibits A and C, filed December 7, 2022 as Doc 339 by Customers Bank 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. The notice relates to the Customers Bank motion for an order compelling compliance with a court-approved settlement agreement and order, requiring additional adequate protection in its favor, and granting related relief, with related Docket Nos. 337, 338. It states that Customers Bank filed Exhibits A and C of a declaration relating to that motion under seal at Docket No. 337 and now files a proposed redacted version as Exhibit 1. It lists a hearing date of January 6, 2023 and is signed by William A. Hazeltine of Sullivan Hazeltine Allinson LLC, with Holland & Knight LLP as co-counsel.

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               Case 22-10951-CTG           Doc 339     Filed 12/07/22     Page 1 of 2




                     IN THE UNITED STATES BANKRUPTCY COURT
                          FOR THE DISTRICT OF DELAWARE

 In re:                                                )   Chapter 11
                                                       )
 KABBAGE, INC. d/b/a KSERVICING, et al.,1              )   Case No. 22-10951 (CTG)
                                                       )
                                Debtors.               )   (Jointly Administered)
                                                       )
                                                       )   Hearing Date: January 6, 2023 at 10:00 a.m.
                                                       )   Obj. Deadline: December 21, 2023 at 4:00 p.m.
                                                       )
                                                       )   Related Docket Nos. 337, 338

NOTICE OF FILING OF PROPOSED REDACTED VERSION OF EXHIBITS A AND C
 TO DECLARATION OF ALYSSA WHITE MOTION OF CUSTOMERS BANK FOR
    ENTRY OF AN ORDER (I) COMPELLING COMPLIANCE WITH COURT
    APPROVED SETTLEMENT AGREEMENT AND ORDER; (II) REQUIRING
  ADDITIONAL ADEQUATE PROTECTION IN FAVOR OF CUSTOMERS BANK;
                 AND (III) GRANTING RELATED RELIEF

          PLEASE TAKE NOTICE that, on December 7, 2022, Customers Bank (the “Movant”)

filed under seal Exhibits A and C of the Declaration of Alyssa White Motion of Customers Bank

for Entry of an Order (I) Compelling Compliance With Court Approved Settlement Agreement and

Order; (II) Requiring Additional Adequate Protection In Favor of Customers Bank; and (III)

Granting Related Relief (the “White Declaration”) [Docket No. 337].

          PLEASE TAKE FURTHER NOTICE that Movant hereby files the attached proposed

redacted version of the White Declaration, attached hereto as Exhibit 1.




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.

            Case 22-10951-CTG   Doc 339   Filed 12/07/22   Page 2 of 2




Date: December 7, 2022             SULLIVAN ∙ HAZELTINE ∙ ALLINSON LLC
      Wilmington, Delaware

                                   /s/ William A. Hazeltine
                                   William A. Hazeltine (No. 3294)
                                   919 North Market Street, Suite 420
                                   Wilmington, DE 19801
                                   Tel: (302) 428-8191
                                   Fax: (302) 428-8195
                                   Email: whazeltine@sha-llc.com

                                          and

                                   HOLLAND & KNIGHT LLP
                                   John J. Monaghan (admitted pro hac vice)
                                   Jeremy M. Sternberg (admitted pro hac vice)
                                   Lynne B. Xerras (pro hac vice forthcoming)
                                   10 St. James Avenue
                                   Boston, MA 02116
                                   Telephone: 617-523-2700
                                   Facsimile: 617-523-685
                                   john.monaghan@hklaw.com
                                   jeremy.sternberg@hkaw.com
                                   lynne.xerras@hklaw.com

                                   Counsel to Customers Bank




                                      2

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