Certificate Of No Objection Regarding Debtors’ Motion For Entry
Summary
A Certificate of No Objection filed December 27, 2022 as Doc 380 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 Debtors' Motion for Entry of an Order Authorizing the Debtors to File Under Seal Certain Exhibits to the Declarations in Support of Motion to Enforce [Docket No. 351], filed December 9, 2022. The certificate states that no answer, objection or other responsive pleading was received or appeared on the docket by the December 23, 2022 deadline. It asks the court to enter an order substantially in the form attached as Exhibit A. The two-page filing is signed by Matthew P. Milana of Richards, Layton & Finger, P.A., with Weil, Gotshal & Manges LLP also listed as attorneys for the debtors.
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Case 22-10951-CTG Doc 380 Filed 12/27/22 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)
:
:
1
Debtors. : (Jointly Administered)
:
: Re: Docket No. 351
------------------------------------------------------------ x
CERTIFICATE OF NO OBJECTION REGARDING DEBTORS’ MOTION FOR ENTRY
OF AN ORDER AUTHORIZING THE DEBTORS TO FILE UNDER SEAL CERTAIN
EXHIBITS TO THE DECLARATIONS IN SUPPORT OF MOTION TO ENFORCE
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 Entry of an Order Authorizing the Debtors to File Under
Seal Certain Exhibits to the Declarations in Support of Motion to Enforce [Docket No. 351] (the
“Motion”) filed by the Debtors with the United States Bankruptcy Court for the District of
Delaware (the “Court”) on December 9, 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 December 23, 2022 at 4:00 p.m. (prevailing Eastern Time).
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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.
RLF1 28396092v.1
Case 22-10951-CTG Doc 380 Filed 12/27/22 Page 2 of 2
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 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
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