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Notice Of Blackline Of Amended Joint Chapter 11 Plan

Summary

A notice of blackline of the Amended Joint Chapter 11 Plan of Liquidation of Kabbage, Inc. (d/b/a KServicing) and its Affiliated Debtors, filed March 9, 2023 as Doc 628 in Case No. 22-10951 (CTG), jointly administered Chapter 11 cases in the U.S. Bankruptcy Court for the District of Delaware. It states that the Debtors filed the solicitation version of the plan on January 19, 2023 (Docket No. 466) and a revised plan on March 9, 2023 (Docket No. 627) reflecting technical modifications and comments from certain parties. A blackline comparing the two is attached as Exhibit 1. The notice states that a confirmation hearing is scheduled for March 13, 2023 before the Honorable Craig T. Goldblatt, United States Bankruptcy Judge, and that the Debtors intend to seek confirmation. The 3-page notice is signed by Matthew P. Milana for the Debtors.

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Full text

                   Case 22-10951-CTG             Doc 628         Filed 03/09/23       Page 1 of 3




                               UNITED STATES BANKRUPTCY COURT
                                    DISTRICT OF DELAWARE

------------------------------------------------------------ x
                                                             :         Chapter 11
In re                                                        :
                                                             :         Case No. 22-10951 (CTG)
KABBAGE, INC. d/b/a KSERVICING, et al., :
                                                             :         (Jointly Administered)
                             1
                  Debtors.                                   :
                                                             :
                                                             :         Re: Docket Nos. 466 & 627
------------------------------------------------------------ x
             NOTICE OF BLACKLINE OF AMENDED JOINT CHAPTER 11 PLAN
                OF LIQUIDATION OF KABBAGE, INC. (d/b/a KSERVICING)
                          AND ITS AFFILIATED DEBTORS

                    PLEASE TAKE NOTICE THAT, on January 19, 2023, 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”), filed the solicitation version of the Amended Joint

Chapter 11 Plan of Liquidation of Kabbage, Inc. (d/b/a KServicing) and its Affiliated Debtors

[Docket No. 466] (the “Solicitation Plan”) with the United States Bankruptcy Court for the

District of Delaware (the “Court”).

                    PLEASE TAKE FURTHER NOTICE THAT, on March 9, 2023, the Debtors

filed the Amended Joint Chapter 11 Plan of Liquidation of Kabbage, Inc. (d/b/a KServicing) and

its Affiliated Debtors [Docket No. 627] (as may be further amended, modified and/or

supplemented, the “Revised Plan”), reflecting certain technical modifications and comments

received from certain parties.



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.



RLF1 28651375v.2

                   Case 22-10951-CTG     Doc 628     Filed 03/09/23    Page 2 of 3




                   PLEASE TAKE FURTHER NOTICE THAT, for the convenience of the Court

and all parties in interest, a blackline comparison of the Revised Plan marked against the

Solicitation Plan is attached hereto as Exhibit 1.

                   PLEASE TAKE FURTHER NOTICE that a hearing to consider confirmation of

the Revised Plan has been scheduled for March 13, 2023 at 10:00 a.m. (ET) (the “Hearing”)

before the Honorable Craig T. Goldblatt, United States Bankruptcy Judge for the District of

Delaware, 824 North Market Street, Third Floor, Courtroom 7, Wilmington, Delaware 19801.

                   PLEASE TAKE FURTHER NOTICE that the Debtors intend to seek

confirmation of the Revised Plan at the Hearing. To the extent the Debtors make any modifications

to the Revised Plan, the Debtors intend to submit a revised version of such document and a

blackline comparison to the Court prior to or at the Hearing.



                            [Remainder of page intentionally left blank]




                                                 2
RLF1 28651375v.2

                   Case 22-10951-CTG   Doc 628     Filed 03/09/23   Page 3 of 3




 Dated: March 9, 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




                                               3
RLF1 28651375v.2

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