Objection of American Express to Joint Motion of Cross River Bank and Customers Bank for Rule 2004 Examination — In re Kabbage, Inc. d/b/a KServicing (Dkt. 683)
Summary
An objection filed March 15, 2023, as Doc 683 in Case No. 22-10951 (CTG), by American Express Kabbage Inc. and American Express Travel Related Services Company, Inc., to the joint motion of Cross River Bank and Customers Bank for a Rule 2004 examination order. It states that the motion unnecessarily and prematurely seeks to compel production of loan files that American Express has been willing to produce and has started working on voluntarily. It states that no cause exists for the examination, that neither movant satisfied the conference requirement, and that a mutually agreeable production plan under Local Rule 2004-1 obviates the need for relief. The objection asks the Court to deny the Joint Motion; Morris, Nichols, Arsht & Tunnell LLP signs as counsel to American Express.
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“Objection of American Express to Joint Motion of Cross River Bank and Customers Bank for Rule 2004 Examination — In re Kabbage, Inc. d/b/a KServicing (Dkt. 683).”
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Case 22-10951-CTG Doc 683 Filed 03/15/23 Page 1 of 13
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re Chapter 11
KABBAGE, INC. d/b/a KSERVICING, Case No. 22-10951 (CTG)
et al.,
(Jointly Administered)
Debtors.1
RE: D.I. 622
Objection Deadline:
March 15, 2023, at 4:00 p.m. (ET)
OBJECTION OF AMERICAN EXPRESS TO
JOINT MOTION OF CROSS RIVER BANK AND CUSTOMERS BANK
FOR AN ORDER AUTHORIZING RULE 2004 EXAMINATION
American Express Kabbage Inc. and American Express Travel Related Services
Company, Inc. (collectively, “American Express”) hereby file this objection (the “Objection”)
to the joint motion (the “Joint Motion”) of Cross River Bank (“CRB”) and Customers Bank
(each, a “Movant,” and together, “Movants”), which unnecessarily and prematurely seeks to
compel American Express to produce certain loan files to Movants pursuant to Bankruptcy Rule
2004—a production which American Express always has been willing to make and already has
started working on voluntarily, absent a court order and in coordination with Debtors and
Movants.2 Certain facts supporting this Objection are set forth in the concurrently filed
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”); 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.
2
Capitalized terms not defined herein are defined in the Joint Motion.
Case 22-10951-CTG Doc 683 Filed 03/15/23 Page 2 of 13
Declaration of Regina Sorin (the “Sorin Declaration”) and Declaration of Amanda Flug
Davidoff (the “Davidoff Declaration”). Because there is no cause, much less good cause, to
order a Rule 2004 examination, the Court should deny the Joint Motion.
PRELIMINARY STATEMENT
1. When it acquired certain assets of Kabbage in 2020, American Express
and Kabbage entered into a Transition Services Agreement (“TSA”) under which American
Express gave Kabbage access to a lending platform, data, other support and certain American
Express personnel for a limited period of time, so that Kabbage could service its loan portfolio
and the portfolios owned by Movants and other third parties (the “Partner Banks”). The TSA
contemplated a migration from the services that American Express provided; it would be in
place only until Kabbage had set up the systems and data needed to independently service loans
(either directly or using third-party vendors). Since the TSA took effect, American Express has
complied with its obligations and more, including by extending the original time periods during
which American Express would make its personnel available to Kabbage and providing
additional services not covered by the original TSA to support Kabbage’s servicing activities.
2. Debtors declared bankruptcy on October 3, 2022. In December 2022,
Debtors approached American Express for the first time to discuss seeking assistance from
American Express to transition servicing of Kabbage’s and Partner Banks’ loan portfolios to
third-party servicers (or to the Partner Banks themselves). From that time until February 28,
2023, Debtors told American Express that they were not sure whether American Express would
be asked to (1) continue to host Kabbage’s and the Partner Banks’ loan files (the “Loan Files”)
on its systems and support servicing by new servicers, or (2) extract and transfer the Loan Files
to new servicers so that American Express would no longer be involved. As is likely evident,
the technical and detailed data work needed for each of those projects is very different, and
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Case 22-10951-CTG Doc 683 Filed 03/15/23 Page 3 of 13
either would be time- and resource-consuming. American Express, therefore, told Debtors that
it would wait for further guidance and information from Debtors before proceeding with any
potential path. On a February 28, 2023 call, Debtors informed American Express for the first
time that they had chosen the second path. American Express promptly confirmed that it was
willing to extract the Loan Files and transfer them to the Partner Banks or relevant third-party
servicers, and that work and dialogue should begin to align with the Partner Banks (or third-
party servicers) on the protocol and terms of the transfer.
3. This work is currently in progress. American Express has been
cooperating diligently with Debtors, Movants, and other third parties to ensure that the Loan
Files, including those pertaining to Movants’ loans (the “Partner Bank Files”), are provided
efficiently and in a format usable and sufficient for all parties taking over Debtors’ loan-
servicing activities. For example, on March 6, 2023, American Express proposed times to
Debtors for initial calls with Movants. Nevertheless, two days later, without contacting
American Express or its counsel directly regarding their requests or providing any prior notice,
Movants filed their motion to compel Rule 2004 discovery of American Express to obtain the
Partner Bank Files. The Joint Motion is entirely unnecessary, given American Express’s
ongoing efforts and discussions with Movants to provide the Partner Bank Files voluntarily.
The Joint Motion only serves to waste the time and resources of the Court, American Express,
Debtors and Movants, who should be focused on transitioning Debtors’ loan-servicing activities
rather than creating unnecessary disputes. Moreover, in violation of Local Rule 2004-1,
Movants never conferred with American Express about the Joint Motion before filing it, other
than to ask for agreement on shortened notice. Movants have therefore failed to take the steps
necessary to seek Rule 2004 discovery of American Express, and the Joint Motion is premature.
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Case 22-10951-CTG Doc 683 Filed 03/15/23 Page 4 of 13
4. For these reasons, the Joint Motion should be denied.
JURISDICTION
5. The Court has jurisdiction over this matter pursuant to 28 U.S.C. §§ 1334
and 157. The Joint Motion against which this Objection is directed is a core proceeding
pursuant to 28 U.S.C. § 157(b). Venue is proper in this Court pursuant to 28 U.S.C. §§ 1408
and 1409.
BACKGROUND
6. Kabbage was an online loan-servicing company founded in 2008 that
sold many of its operating assets to affiliates of American Express in October 2020 (the
“Acquisition”). Disclosure Statement at 3 (D.I. 467); Sorin Decl. Ex. 1 at 1. Post-Acquisition,
Kabbage retained servicing obligations for Kabbage’s loan portfolio and the portfolios of the
Partner Banks, which were not included in the Acquisition. See Disclosure Statement at 3, 30;
Sorin Decl. Ex. 1 at 1. Kabbage’s loan portfolio consisted primarily of small business loans
issued under the Paycheck Protection Program (“PPP”) in 2020 (before the Acquisition) with an
aggregate outstanding principal amount of approximately $1.3 billion as of October 3, 2022, as
well as other loans originated by Kabbage prior to the Acquisition. Disclosure Statement at 3.
7. As part of the Acquisition, Kabbage and American Express entered into
the TSA to govern the services and data American Express would make accessible to Kabbage
as Kabbage transitioned servicing to itself or third-party vendors. Sorin Decl. at ¶ 4. The TSA
gave Kabbage the right to access materials, records and legacy software Kabbage needed to
service the loans in Kabbage’s and the Partner Banks’ loan portfolios. Disclosure Statement at
35. American Express has fulfilled all of its obligations under the TSA, and much more.3 For
3
American Express expressly “disagree[d] with the Debtors’ characterization of AmEx” in
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example, American Express agreed to amend the TSA to expand the scope of services so that
Kabbage could originate, process and service second draw PPP loans (including for Movants)
and completed over 20 change orders to either extend the time period for existing services or
provide additional services that were not required under the terms of the original TSA. Sorin
Decl. at ¶ 4. As recently as December 2022, at the request of Movant CRB, and for Debtors to
fulfill their contractual obligations to CRB, American Express expended significant resources to
complete an external audit of the lending platform that Kabbage licenses from American
Express to perform loan servicing. Id. This was done voluntarily in the interest of cooperation.
8. Debtors declared bankruptcy on October 3, 2022. Nearly three months
later, on December 14, 2022, Debtors first approached American Express’s in-house counsel to
raise the issue of how Kabbage’s loan servicing might change as a result of the bankruptcy. See
Sorin Decl. ¶ 5; Ex. 2 at 1. Debtors indicated that they were working with their counsel from
Weil, Gotshal & Manges LLP (“Weil”) to assess how to transition loan servicing to Movants
and other Partner Banks,4 and specifically whether the underlying data would (1) stay with
American Express and be accessible to Movants and others, or (2) be migrated to third-party
servicers’ systems (or directly to the systems of the Partner Banks). See id. ¶ 6. Debtors
indicated that they had not yet decided on their preferred approach. Id. American Express
asked that Debtors prepare a description of the transition options being considered, which
Debtors agreed on December 19, 2023 to provide “to kickstart some discussion about future
servicing options.” Id. ¶¶ 6, 7; Ex. 3 at 1. In response, American Express suggested that further
the Disclosure Statement concerning “lack of cooperation or delay” in providing data
pursuant to the TSA. Disclosure Statement at 35.
4
The Federal Reserve Bank will also be taking over servicing of some of Debtors’ PPP
loans. Disclosure Statement at 5.
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Case 22-10951-CTG Doc 683 Filed 03/15/23 Page 6 of 13
discussions about the servicing transition take place between Debtors’ counsel at Weil and
American Express’s outside counsel, Sullivan & Cromwell (“S&C”). Id. Ex. 3 at 1.
9. On January 4, 2023, S&C emailed Weil to discuss “options for ongoing
loan servicing following bankruptcy.” See Davidoff Decl. ¶ 2; Ex. 1 at 1. During a January 6,
2023 call, Weil indicated that Debtors’ Partner Banks (including Movants) were requesting
information such as “know your customer” (“KYC”) and “know your business” (“KYB”)
records related to their PPP loans. Id. ¶ 3. Weil agreed to provide S&C with a detailed list of
the information requested by the Partner Banks, as well as other information about the options
being considered to transition servicing. Id.
10. Counsel for Movant CRB at Quinn Emanuel Urquhart & Sullivan LLP
(“Quinn”) later reached out to S&C for a direct phone call.5 On January 11, 2023, Quinn
informed S&C that CRB had been unable to obtain information from Debtors needed to service
CRB’s loans. Davidoff Decl. ¶ 4. S&C explained that Weil had recently made S&C aware of a
request for KYC- and KYB-related information, and that S&C had asked Weil to provide a list
of third-party requests. Id. Quinn agreed that it would be most efficient for all requests to
American Express for information to be funneled through Weil, given that multiple parties were
seeking similar information. Id. Quinn and S&C did not discuss any specific CRB requests on
this call or at any time thereafter. Id.
11. Movant Customers Bank has never contacted American Express about
data needed to transition servicing.
5
Just as American Express suggested to Debtors that S&C and Weil should coordinate
communications about requests to American Express related to the transition of servicing,
American Express’s in-house counsel also asked Movant CRB’s in-house counsel to
contact S&C about those topics. Joint Motion ¶ 13.
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Case 22-10951-CTG Doc 683 Filed 03/15/23 Page 7 of 13
12. On January 13, 2023, American Express received from Weil a letter
attaching a set of requests (the “KServicing Requests”) for extensive information about
American Express’s system architecture for storing Debtors’ and the Partner Banks’ loan data
and records, documentation from Debtors’ own PPP program that American Express does not
have, documentation and descriptions of American Express’s systems and processes that
American Express would need to create, and proprietary intellectual property such as all of the
“code from Amex system environment.” Id. Ex. 3 at 1. The KServicing Requests sought data
for thousands of individual loans but did not specify data fields or the format for the data
transfer—basic information needed to move forward. The Requests also asked for extensive
human capital support, such as a “[t]utorial of the full PPP data environment” and access to
multiple experts at American Express, including a “Technical lead” and separate “point[s] of
contact” for “support to database updates,” “3rd-party audit & governance requirements and
deliverables,” “API management” issues, and work with Debtors’ Help Desk on “provisioning
and troubleshooting support” for certain systems. Id. at 2, 3. It was not clear why most of this
information had been requested, particularly if Debtors were considering transitioning servicing
entirely to other parties. Indeed, no party has pursued the most burdensome requests, such as
documentation explaining all application connections among the American Express core
platform processes. The letter accompanying the January 13 KServicing Requests asked
American Express to confirm “by January 19, 2023 . . . that [American Express] is willing to
provide the requested material, and that it will do so by February 17, 2023.” Id. Ex 4 at 1.
13. On January 19, 2023, S&C notified Weil that “American Express is open
to discussing its role in assisting KServicing with its transition plans, including the [KServicing
Requests],” and that American Express “agree[s] that it is in the best interests of the parties to
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work cooperatively and that it would be helpful to meet and confer on the requests.” Id. ¶ 7;
Ex. 5 at 1. S&C explained that “American Express requires more information to understand
what is being requested and the ultimate goal with respect to transitioning servicing,” and
“[s]ome of these requests may require weeks or months of development or other work to
accomplish and so should be discussed” to develop a “more comprehensive transition plan[.]”
Id. Ex. 5 at 1. S&C noted that, “[i]n light of the steps required to scope and respond to the
requests, at this time American Express cannot commit to providing all of the documentation,
access, and resources requested by February 17, 2023 but is willing to discuss a realistic
timeframe for assisting KServicing.” Id.
14. S&C received no response to this email until January 27, 2023, when
Weil asked to schedule a call for February 2, 2023. See id. Ex. 6 at 1. On this call, Weil
informed S&C that Debtors had decided to transition servicing away from Debtors completely,
so that it would be run by Movants and other relevant parties, but Debtors did not know
whether American Express would continue to host the Debtors’ PPP loan data or would need to
extract the data and send it to the new servicers. Id. ¶ 9. Thus, even at this late date, there was
no clear understanding of what was needed from American Express. Id. Weil agreed to
arrange a comprehensive discussion among American Express, Movants, other relevant parties
and their respective servicers about how to transition servicing away from Debtors. Id.
Following the call with Weil, American Express promptly started having internal discussions
about how to efficiently transfer Debtors’ data needed for loan servicing (should Debtors
ultimately choose that path). Sorin Decl. ¶ 12.
15. When Weil still had not scheduled the requested transition calls after two
weeks—and instead sent an email suggesting that American Express was supposed to have been
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Case 22-10951-CTG Doc 683 Filed 03/15/23 Page 9 of 13
providing some data to Movant CRB6—on February 17, 2023, S&C reminded Weil that they
were supposed to be scheduling calls with Movants and other relevant parties to discuss exactly
what was needed from American Express. Davidoff Decl. ¶ 10; Ex. 7 at 1. At the same time,
S&C provided some readily available PPP-related data requested by Debtors.7 Id. Ex. 7 at 1.
16. On a February 28, 2023 call between S&C and Weil, more than a month
after S&C responded to Weil’s January 13 letter, Weil informed S&C for the first time how
Debtors planned to proceed with the servicing transition: Debtors wanted American Express to
extract and transfer Debtors’ PPP loan data to Movants, other relevant parties and their
servicers—who then would not rely on American Express to continue to host such data.
Davidoff Decl. ¶ 11. This was, at last, a clear request that American Express could act upon.
At S&C’s request, Weil again agreed to arrange calls with each of Movants, other relevant
parties, and their respective servicers to discuss the data and information needed by each entity
to transition servicing. Id.
17. On March 6, 2023, American Express proposed times to Weil for calls
with Movants and others to discuss transitioning servicing. Weil coordinated calls with
Movants and others for March 10, 2023. Id. ¶ 12. Additional calls have occurred and been
6
This apparently referred to a separate request from Debtors to American Express’s in-
house counsel made by phone on January 31, 2023. On that call, Debtors asked for
American Express’s permission for Debtors to provide Movant CRB with PPP loan files
and other PPP-related loan data to which Debtors had access. Sorin Decl. ¶ 9. On
February 2, 2023, American Express consented and indicated it would agree to the same
disclosures for Customers Bank. Id. Ex. 5 at 1. S&C reminded Weil of this consent in the
February 17 email: “For the broader data requests [from CRB], American Express gave
signoff to [Debtors] at the beginning of the month to provide CRB with the data dealt with
in [Debtors’] request of January 31.” Davidoff Decl. Ex. 7 at 1; Sorin Decl. ¶ 10.
7
As S&C noted in the email, some of the requested information had already been provided
by American Express to Debtors months earlier. Davidoff Decl. ¶ 10; Ex. 7 at 1.
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Case 22-10951-CTG Doc 683 Filed 03/15/23 Page 10 of 13
scheduled since then, and more will be set among American Express and Movants to discuss
the data transfer. Id.
ARGUMENT
18. Movants’ request for an examination under Bankruptcy Rule 2004 and
Local Rule 2004-1 should be denied because there is absolutely no need for such relief. As
soon as Debtors told American Express what they actually wanted—for American Express to
extract the relevant Loan Files and send them to Movants and other third parties—American
Express started working on that exercise, which is in progress. The Movants themselves
skipped the prerequisite step of conferring with American Express before filing this Motion,
perhaps because they knew American Express was already working to transfer the data they are
seeking. The Movants thus have failed to demonstrate the good cause needed for the Court to
grant this discretionary relief, and the Motion should be denied.
19. Bankruptcy Rule 2004 enables a court to “order the examination of any
entity” when requested by a party in interest. Fed. R. Bankr. P. 2004(a). No party has an
absolute right to invoke the Rule: “[T]he granting of a Rule 2004 examination is dependent on
the discretion of the court.” In re Millennium Lab Holdings II, LLC, 562 B.R. 614, 626 (Bankr.
D. Del. 2016). In exercising its discretion, the court must balance “the competing interests of
the parties, weighing the relevance of and necessity of the information sought by examination.”
Id. (quoting In re Drexel Burnham Lambert Grp., Inc., 123 B.R. 702, 712 (Bankr. S.D.N.Y.
1991)). Rule 2004 cannot be used simply to deal with a litigant’s “special problems.”
Millennium Lab, 562 B.R. at 626–27 (quoting In re J&R Trucking, Inc., 431 B.R. 818, 821
(Bankr. N.D. Ind. 2010)).
20. While the scope of Rule 2004 is “broader than discovery under the
Federal Rules of Civil Procedure,” Joint Motion ¶ 20, it is far from limitless. “The party
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Case 22-10951-CTG Doc 683 Filed 03/15/23 Page 11 of 13
seeking to conduct a 2004 examination has the burden of showing good cause for the
examination.” Millennium Lab, 562 B.R. at 627. “Good cause” generally requires the movant
to demonstrate that “the . . . examination is necessary to establish the claim of the party seeking
the examination, or [that] denial of such request would cause the examiner undue hardship or
injustice.” See id. (quoting In re Metiom, Inc., 318 B.R. 263, 268 (Bankr. S.D.N.Y. 2004)
(emphasis added)).
21. Here, Movants have not met their burden of showing that Rule 2004
examination “is necessary to . . . [avoid] undue hardship or injustice,” not only on the
underlying merits but because American Express has already agreed to provide the information
being sought. While Movants claim to have “been trying to obtain copies of [their] Servicing
Files” from Debtors for “over a year,” Joint Motion ¶ 1, no requests related to the servicing
transition were made by anyone to American Express until January 2023, and no actionable
proposal was presented until February 28, 2023. Davidoff Decl. ¶¶ 6, 9, 11. During an initial
discussion with Debtors on January 6, 2023, American Express asked for a list of specific
requests from Movants and a clear understanding of what assistance Debtors wanted from
American Express to transfer servicing to Movants and other relevant servicers. See Id. ¶ 3.
Specifically, American Express needed to know whether Debtors were asking it to (1) continue
to host the Loan Files and support new servicers, or (2) extract the Loan Files and deliver them
to third parties. As soon as Debtors informed American Express that it was taking the latter
route—which did not occur until February 28 (id. ¶ 11)—American Express sprang into action
and began planning for the data transfer.
22. In light of these facts, Movants do not meet their burden under Rule 2004
to show “good cause.” Rule 2004 examination is not “necessary” to save them from “undue
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Case 22-10951-CTG Doc 683 Filed 03/15/23 Page 12 of 13
hardship or injustice,” including because a voluntary process to deliver the information
Movants seek is already underway. See Millennium Lab, 562 B.R. at 627; see also In the
Matter of Onatah Farms, LLC et al., No. 21-10091, 2021 WL 2809902, at *2 (Bankr. N.D. Ind.
Apr. 29, 2021) (“Resort to Rule 2004 is only necessary where the target of any inquiry will not
voluntarily cooperate.”); J & R Trucking, 431 B.R. at 822 (“Ideally, those with knowledge
[relevant to the bankruptcy proceeding] will voluntarily cooperate,” but because “that is not
always the case . . . Rule 2004 provides a vehicle by which the [movant] can compel that
‘cooperation.’”). Accordingly, “good cause” is missing here.
23. Nor can Movants demonstrate compliance with Local Rule 2004-1. This
Rule requires a movant, “[p]rior to filing a motion for examination . . . under Fed. R. Bankr. P.
2004,” to “attempt to confer . . . with the proposed examinee . . . to arrange for a mutually
agreeable date, time, place and scope of an examination or production.” Movant CRB
approached American Express about obtaining information from Debtors only once, on January
11, 2023. Davidoff Decl. ¶ 4. CRB agreed that its specific requests should go through
Debtors’ counsel—and made no further approach to American Express. Id.; Joint Motion ¶ 13.
Movant Customers Bank has never communicated with American Express about its requests.
Davidoff Decl. ¶ 5. And neither Movant sought to meet and confer with American Express
about the Joint Motion specifically, other than to seek consent for shortened notice. To the
extent CRB asserts that its January 11 phone call with counsel for American Express satisfies
the conference requirement, it plainly does not. That phone call did not include discussion of
any specific requests for production, see Davidoff Decl. ¶ 4, and, in any event, since then,
Movants and American Express have been proceeding with a “mutually agreeable” plan for
production, which, under Local Rule 2004-1, expressly obviates the need for Rule 2004 relief.
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Case 22-10951-CTG Doc 683 Filed 03/15/23 Page 13 of 13
Movants’ surprising response to this ongoing, voluntary process was to file this Joint Motion,
knowing calls were scheduled with American Express for the very week Movants filed it.
Movants have not satisfied a prerequisite to the compulsory process sought by the Joint Motion.
CONCLUSION
For the reasons stated above, American Express respectfully requests that the
Court deny the Joint Motion.
Dated: March 15, 2023 Respectfully, submitted,
Wilmington, Delaware
MORRIS, NICHOLS, ARSHT & TUNNELL
LLP
/s/ Jonathan M. Weyand
Derek C. Abbott (No. 3376)
Jonathan M. Weyand (No. 6959)
1201 North Market Street, 16th Floor
P.O. Box 1347
Wilmington, Delaware 19899-1347
Telephone: (302) 658-9200
Email: dabbott@morrisnichols.com
jweyand@morrisnichols.com
-and-
SULLIVAN & CROMWELL LLP
James L. Bromley (admitted pro hac vice)
125 Broad Street
New York, NY 10004-2498
Telephone: (212) 558-4000
Email: bromleyj@sullcrom.com
Amanda Flug Davidoff (admitted pro hac vice)
1700 New York Avenue, N.W. Suite 700
Washington, D.C. 20006-5215
Telephone: (202) 956-7500
Email: davidoffa@sullcrom.com
Counsel to American Express
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