United States Bankruptcy Court for the District of Delaware — Case 22-10951-CTG, Doc 90

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A Notice of Entry of Appearance and Request for Notices and Papers (Doc 90) in Case No. 22-10951 (CTG), the jointly administered chapter 11 cases of Kabbage, Inc. d/b/a KServicing, and its debtor affiliates. It states that the firms of Sullivan Hazeltine Allinson LLC and Holland & Knight LLP enter their appearance as counsel for Customers Bank under section 1109(b) of the Bankruptcy Code. It requests that copies of all notices and pleadings given or filed in the case be served on them.

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                   Case 22-10951-CTG       Doc 90     Filed 10/07/22     Page 1 of 3




                       IN THE UNITED STATES BANKRUPTCY COURT
                            FOR THE DISTRICT OF DELAWARE

    In re:                                             )   Chapter 11
                                                       )
    KABBAGE, INC. d/b/a KSERVICING, et al.,1           )   Case No. 22-10951 (CTG)
                                                       )
                                Debtors.               )   (Jointly Administered)

                           NOTICE OF ENTRY OF APPEARNCE
                         AND REQUEST FOR NOTICES AND PAPERS

             PLEASE TAKE NOTICE THAT the undersigned firms of Sullivan Hazeltine Allinson

LLC and Holland & Knight LLP hereby enter their appearance as counsel for Customers Bank

(“Customers Bank”) in the above-captioned case, pursuant to section 1109(b) of Title 11 of the

United States Code (the “Bankruptcy Code”); and Rule 9010(b) of the Federal Rules of

Bankruptcy Procedure (the “Bankruptcy Rules”); such counsel hereby requests, pursuant to

Bankruptcy Rules 2002, 3017 and 9007 and sections 342 and 1109(b) of the bankruptcy Code, that

hard copies of all notices and pleadings given or filed in the above-captioned case be given and

served upon the following persons at the following addresses, telephone and telecopy numbers:

         William A. Hazeltine, Esq.                        John J. Monaghan, Esq.
         SULLIVAN ∙ HAZELTINE ∙ ALLINSON LLC               Holland & Knight LLP
         919 North Market Street, Suite 420                10 St. James Avenue,11th Floor
         Wilmington, DE 19801                              Boston, MA 02116
         Tel: (302) 428-8191                               Tel: 617.523.2700
         Fax: (302) 428-8195                               Fax: 617.523.6850




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.

               Case 22-10951-CTG          Doc 90      Filed 10/07/22     Page 2 of 3




       Please take further notice that pursuant to section 1109(b) of the Bankruptcy Code, the

foregoing demand includes not only the notices and papers referred to in the bankruptcy rules and

sections of the Bankruptcy Code specified above, but also includes, without limitation, any notice,

application, complaint, demand, motion, petition, pleading or request, whether formal or informal,

written or oral, and whether transmitted or conveyed by mail, delivery, telephone, telegraph, telex,

or otherwise filed or made with regard to the above-captioned cases and proceedings therein.

       This Notice of Appearance and Demand for Notices and Papers shall not be deemed or

construed to be a waiver of (a) Customers Bank’s rights (i) to have final orders in non-core matters

and/or matters entitled to adjudication by a judge authorized under Article III of the U.S.

Constitution entered only after de novo review by a District Court Judge, (ii) to trial by jury in any

proceeding so triable in these cases or in any case, controversy, or proceeding related to these

cases, and (iii) to have the District Court withdraw the reference in any matter subject to mandatory

or discretionary withdrawal, or (b) any other rights, claims, actions, setoffs, or recoupments to

which Customers Bank is or may be entitled, in law or in equity, all of which rights, claims, actions,

defenses, setoffs, and recoupments Customers Bank expressly reserves.

Dated: October 7, 2022                                SULLIVAN ∙ HAZELTINE ∙ ALLINSON LLC
       Wilmington, Delaware

                                                      /s/ William A. Hazeltine
                                                      William A. Hazeltine (No. 3294)
                                                      919 North Market Street, Suite 420
                                                      Wilmington, DE 19801
                                                      Tel: (302) 428-8191
                                                      Fax: (302) 428-8195
                                                      Email: whazeltine@sha-llc.com

                                                      and




                                                  2

Case 22-10951-CTG   Doc 90   Filed 10/07/22   Page 3 of 3




                             John J. Monaghan, Esq.
                             Holland & Knight LLP
                             10 St. James Avenue, 11th Floor
                             Boston, MA 02116
                             Tel: 617.523.2700
                             Fax: 617.523.6850
                             Email: john.monaghan@hklaw.com

                             Attorneys for Customers Bank




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