Certificate of No Objection Regarding the Third Monthly Application of Greenberg Traurig, LLP

Summary

A Certificate of No Objection in Case No. 22-10951 (CTG), the jointly administered chapter 11 cases of Kabbage, Inc. d/b/a KServicing, et al., regarding the third monthly application of Greenberg Traurig, LLP, as special counsel to the Board of Directors of Kabbage, for compensation and reimbursement of expenses for the period from December 1, 2022 through December 31, 2022 (Docket No. 494). The certificate states that the undersigned has received no answer, objection or other responsive pleading to the application. It states that no order is required.

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“Certificate of No Objection Regarding the Third Monthly Application of Greenberg Traurig, LLP.” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-deb-188293-564-0-35e5655d40/, SHA-256 aa5b3fbbdfc27a37a111be86d20bd3474ea0c970dfa54ad4ed65e818cae34c42.

Full text

Case 22-10951-CTG Doc 564 Filed 02/22/23 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. 494

CERTIFICATE OF NO OBJECTION REGARDING THE THIRD
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 DECEMBER 1, 2022 THROUGH
DECEMBER 31, 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 third 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 January 30, 2023. 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 February 20, 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 564 Filed 02/22/23 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 564 Filed 02/22/23 Page 3 of 4

Dated: February 22, 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)
Huiqi Liu, Esq. (No. 6850)
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, 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

3
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Case 22-10951-CTG Doc 564 Filed 02/22/23 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 12/1/22 – $99,826.00 $0.00 2/20/23 $79,860.80 $0.00
Traurig, LLP 12/31/22

(Special 1/30/23
Counsel to
the Board of Docket No.
Directors of 494
Kabbage, Inc.
d/b/a
KServicing)

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