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Certificate of No Objection re Greenberg Traurig First Monthly Application — In re Kabbage (Bankr. D. Del.)

Summary

A certificate of no objection filed December 27, 2022 as Doc 377 in In re Kabbage, Inc. d/b/a KServicing, et al., Case No. 22-10951 (CTG), jointly administered Chapter 11 cases in the U.S. Bankruptcy Court for the District of Delaware. It concerns the first monthly fee application of Greenberg Traurig, LLP, special counsel to the board of directors of Kabbage, Inc. d/b/a KServicing, for October 3, 2022 through October 31, 2022 [Docket No. 326]. Debtors' counsel certifies that no objection was received by the December 22, 2022 deadline and that, under the Interim Compensation Order, the Debtors may pay 80% of fees and 100% of expenses without a further order. Exhibit A lists requested fees of $84,604.00 and expenses of $411.25, with $67,683.20 in fees authorized to be paid. It is signed by Richards, Layton & Finger, P.A., listed with Weil, Gotshal & Manges LLP as Debtors' attorneys.

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                   Case 22-10951-CTG             Doc 377         Filed 12/27/22       Page 1 of 4




                               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)
                                                             :
                                                             :         (Jointly Administered)
                             1
                  Debtors.                                   :
------------------------------------------------------------ x         Re: Docket No. 326

               CERTIFICATE OF NO OBJECTION REGARDING THE FIRST
              MONTHLY APPLICATION OF GREENBERG TRAURIG, LLP, AS
           SPECIAL COUNSEL TO THE BOARD OF DIRECTORS OF KABBAGE,
          INC. D/B/A KSERVICING, FOR ALLOWANCE OF COMPENSATION FOR
            SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES FOR
                    THE PERIOD FROM OCTOBER 3, 2022 THROUGH
                       OCTOBER 31, 2022 (NO ORDER REQUIRED)

          The undersigned hereby certifies that, as of the date hereof, he has received no answer,

objection or other responsive pleading with respect to the first monthly fee application for

compensation and reimbursement of expenses (the “Monthly Application”) of Greenberg

Traurig, LLP (the “Applicant”). The Monthly Application was filed with the United States

Bankruptcy Court for the District of Delaware (the “Court”) on December 2, 2022.                                 The

undersigned further certifies that he has reviewed the Court’s docket in these cases and no answer,

objection or other responsive pleading to the Monthly Application appears thereon. Pursuant to

the Notice of Fee Application that was attached to the Monthly Application, objections to the

Monthly Application were to be filed and served no later than December 22, 2022 at 4:00 p.m.

(ET).


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 377     Filed 12/27/22     Page 2 of 4




        The Monthly Application was filed and served in accordance with the Order Establishing

Procedures for Interim Compensation and Reimbursement of Expenses of Professionals, entered

October 21, 2022 [Docket No. 136] (the “Interim Compensation Order”). Pursuant to the

Interim Compensation Order, the above-captioned debtors and debtors in possession are

authorized to pay the Applicant eighty percent (80%) of the fees and one hundred percent (100%)

of the expenses requested in the Monthly Application upon the filing of this certification without

the need for a further order of the Court. A summary of the fees and expenses sought by the

Applicant is annexed hereto as Exhibit A.




                                                2
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                   Case 22-10951-CTG   Doc 377     Filed 12/27/22   Page 3 of 4




 Dated: December 27, 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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                   Case 22-10951-CTG          Doc 377     Filed 12/27/22     Page 4 of 4




                                                EXHIBIT A

                                       Professional Fees and Expenses
                                          Monthly Fee Application

       Applicant           Fee          Total Fees     Total     Objection   Amount of    Amount of
                       Application      Requested    Expenses    Deadline       Fees       Expenses
                      Period, Filing                 Requested               Authorized   Authorized
                      Date, Docket                                           to be Paid   to be Paid
                           No.                                                @ 80%        @ 100%
       Greenberg        10/3/22 –       $84,604.00    $411.25    12/22/22    $67,683.20    $411.25
      Traurig, LLP      10/31/22

        (Special         12/2/22
       Counsel to
      the Board of     Docket No.
       Directors of       326
      Kabbage, Inc.
          d/b/a
      KServicing)




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