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

Summary

A certificate of no objection filed January 20, 2023 as Doc 476 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 second monthly fee application of Greenberg Traurig, LLP, special counsel to the board of directors of Kabbage, Inc. d/b/a KServicing, for November 1, 2022 through November 30, 2022 [Docket No. 392]. Debtors' counsel certifies that no objection was received by the January 19, 2023 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 $38,666.50, expenses of $0.00 and $30,933.20 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 476         Filed 01/20/23       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. 392

              CERTIFICATE OF NO OBJECTION REGARDING THE SECOND
              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 NOVEMBER 1, 2022 THROUGH
                      NOVEMBER 30, 2022 (NO ORDER REQUIRED)

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

objection or other responsive pleading with respect to the second 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 29, 2022. The

undersigned further certifies that she 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 January 19, 2023 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 476     Filed 01/20/23     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 476     Filed 01/20/23   Page 3 of 4




 Dated: January 20, 2023
        Wilmington, Delaware
                                       /s/ Huiqi Liu
                                       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
                                               liu@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 476     Filed 01/20/23     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        11/1/22 –       $38,666.50     $0.00      1/19/23    $30,933.20     $0.00
      Traurig, LLP      11/30/22

        (Special        12/29/22
       Counsel to
      the Board of     Docket No.
       Directors of       392
      Kabbage, Inc.
          d/b/a
      KServicing)




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