Motion of Continuance (The Juneau Group, LLC)

Summary

A Motion of Continuance filed by The Juneau Group, LLC in Case No. 22-10951 (CTG), the jointly administered chapter 11 cases of Kabbage, Inc. d/b/a KServicing, et al. The motion requests a continuance of the motion at Docket No. 345 to the February 27, 2023, 10 a.m. hearing date. It cites the local rule that any response deadline to an objection is due no later than seven days before the hearing date, and states that there has been no objection to Docket No. 345. It states that the time between the January 12th objection deadline and the January 19th omnibus hearing is exactly 7 days, and the movant asks for the accommodation as a precaution.

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Case 22-10951-CTG Doc82z Filed 1406323 Page 1 of 1

UNITED STATES BANKRUPTCY COURT - i
DISTRICT OF DELAWARE = =
: Chapter 11 = °°
In re : —_ ww
: Case No. 22-10951(CTG) =
KABBAGE, INC. d/b/a KSERVICING, et al, : ”
: (Jointly Administered)
Debtors. :
x

MOTION OF CONTINUANCE

The Juneau Group, LLC, hereby respectfully request for Continuance of the motion at Docket No.

[345] to the February 27, 2023, at 10 a.m. hearing date. The Juneau Group, LLC cites court local
rule book Part IIT — Rule 3007 -, (h): “Responses and Replies to Objection. (1) Response Deadline.
Any response deadline to an objection shall be due no later than seven (7) days before the hearing
date.” There has been no objection to Docket No. [345]. However, the time between the objection
deadline: January 12" and January 19" omnibus hearing is exactly 7 days. Local rules stipulate a
response to an objection must occur 7 days prior to the hearing. The court is not allowing ample

time for response. As a precaution, The Juneau Group, LLC kindly request this accommodation.

Jacob Juneau

1/6/2023

©, 7 |__
>

' 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 3030

RLF1 28271248v.1

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