Certificate of No Objection Regarding the Sixth Monthly Application of Richards, Layton & Finger, P.A.

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 sixth monthly application of Richards, Layton & Finger, P.A. as co-counsel to the debtors for allowance of compensation and reimbursement of expenses for the period from March 1, 2023 through March 31, 2023 (Docket No. 819). 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 Sixth Monthly Application of Richards, Layton & Finger, P.A.” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-deb-188293-851-0-1478f6a64e/, SHA-256 383c8cf157d96868a1098b7d150f72a89f70b5436b0d97b0f9434283f4f4cc9d.

Full text

Case 22-10951-CTG Doc 851 Filed 06/06/23 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. 819

CERTIFICATE OF NO OBJECTION REGARDING THE SIXTH MONTHLY
APPLICATION OF RICHARDS, LAYTON & FINGER, P.A. FOR ALLOWANCE OF
COMPENSATION FOR SERVICES RENDERED AND FOR REIMBURSEMENT OF
EXPENSES AS CO-COUNSEL TO THE DEBTORS FOR THE PERIOD FROM
MARCH 1, 2023 THROUGH MARCH 31, 2023 (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 sixth monthly fee application for

compensation and reimbursement of expenses (the “Monthly Application”) of Richards, Layton

& Finger, P.A. (the “Applicant”). The Monthly Application was filed with the United States

Bankruptcy Court for the District of Delaware (the “Court”) on May 15, 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 June 5, 2023 at 4:00 p.m. (ET).

The Monthly Application was filed and served in accordance with the Order Establishing

Procedures for Interim Compensation and Reimbursement of Expenses of Professionals, entered

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 851 Filed 06/06/23 Page 2 of 4

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 851 Filed 06/06/23 Page 3 of 4

Dated: June 6, 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)
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

3
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Case 22-10951-CTG Doc 851 Filed 06/06/23 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%
Richards, 3/1/23 – $464,174.00 $19,273.78 6/5/23 $371,339.202 $19,273.78
Layton & 3/31/23
Finger, P.A.
5/15/23
(Co-Counsel
to the Docket No.
Debtors) 819

2
Due to an inadvertent clerical error, the amount listed for the 80% of fees incurred by the Applicant was reflected
in the Monthly Application as $371,399.20; however, such amount is actually $371,339.20. For the avoidance of
doubt, the Applicant will be paid $371,339.20 as 80% of the fees sought pursuant to the Monthly Application.

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