No-Objection Certificate on Exclusive Periods — Kabbage
Summary
A Certificate of No Objection filed February 14, 2023 as Doc 528 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 Motion of Debtors for Entry of an Order (I) Extending the Debtors' Exclusive Periods and (II) Granting Related Relief, filed January 30, 2023 at Docket No. 503. Counsel certifies that no answer, objection or other responsive pleading was received or appears on the docket, and that the objection deadline was February 13, 2023 at 4:00 p.m. The certificate asks the Court to enter an order substantially in the form attached as Exhibit A. It is signed by Matthew P. Milana of Richards, Layton & Finger, P.A. and carries the signature block of Weil, Gotshal & Manges LLP, as attorneys for the Debtors.
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Case 22-10951-CTG Doc 528 Filed 02/14/23 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. 503
------------------------------------------------------------ x
CERTIFICATE OF NO OBJECTION REGARDING
MOTION OF DEBTORS FOR ENTRY OF AN ORDER (I) EXTENDING THE
DEBTORS’ EXCLUSIVE PERIODS AND (II) GRANTING RELATED RELIEF
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 Motion of Debtors for Entry of an Order (I) Extending the Debtors’ Exclusive
Periods and (II) Granting Related Relief [Docket No. 503] (the “Motion”) filed by the Debtors
with the United States Bankruptcy Court for the District of Delaware (the “Court”) on January
30, 2023. 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 February 13, 2023 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 28598085v.1
Case 22-10951-CTG Doc 528 Filed 02/14/23 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: February 14, 2023
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, Esq. (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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