Certificate of No Objection Regarding Debtors’ Motion Further Extending the Deadline to Remove Civil Actions

Summary

A Certificate of No Objection regarding the Debtors' Motion for an Order (I) Further Extending the Deadline by Which the Debtors May Remove Civil Actions, and (II) Granting Related Relief (Docket No. 799). It is filed in Case No. 22-10951 (CTG), the jointly administered chapter 11 cases of Kabbage, Inc. d/b/a KServicing, and its debtor affiliates. The certificate states that the debtors have received no answer, objection or any other responsive pleading to the motion. It is Doc 829 on the docket and concerns the debtors' deadline to remove civil actions.

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“Certificate of No Objection Regarding Debtors’ Motion Further Extending the Deadline to Remove Civil Actions.” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-deb-188293-829-0-4c7c0c7132/, SHA-256 3eed23b3fb3ff1c01cf806d2bd72b84e24fac919ded230fd578279ca7c58a37e.

Full text

Case 22-10951-CTG Doc 829 Filed 05/17/23 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. 799
------------------------------------------------------------ x

CERTIFICATE OF NO OBJECTION REGARDING
DEBTORS’ MOTION FOR AN ORDER (I) FURTHER EXTENDING
THE DEADLINE BY WHICH THE DEBTORS MAY REMOVE
CIVIL ACTIONS, 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 Debtors’ Motion for an Order (I) Further Extending the Deadline by Which the

Debtors May Remove Civil Actions, and (II) Granting Related Relief [Docket No. 799] (the

“Motion”) filed by the Debtors with the United States Bankruptcy Court for the District of

Delaware (the “Court”) on May 2, 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

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 29021740v.1

Case 22-10951-CTG Doc 829 Filed 05/17/23 Page 2 of 2

no later than May 16, 2023 at 4:00 p.m. (prevailing Eastern Time).

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: May 17, 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)
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
chase.bentley@weil.com

Attorneys for Debtors
and Debtors in Possession

2
RLF1 29021740v.1

File and source

File: gov.uscourts.deb.188293.829.0.pdf
Size: 163,228 bytes
SHA-256: 3eed23b3fb3ff1c01cf806d2bd72b84e24fac919ded230fd578279ca7c58a37e
Our copy: gov.uscourts.deb.188293.829.0.pdf
Original: archive.org