United States Bankruptcy Court, District of Delaware — Case 22-10951-CTG, Doc 954

Summary

A certificate of no objection dated August 9, 2023 covers the ninth monthly fee application of Greenberg Traurig, LLP, special counsel to the Board of Directors of Kabbage, Inc. d/b/a KServicing, for June 1, 2023 through June 20, 2023. It states that no answer, objection or other responsive pleading was received; the application was filed July 19, 2023 and objections were due August 8, 2023 at 4:00 p.m. (ET). Exhibit A lists $11,896.50 in fees and $0.00 in expenses requested, with $9,517.20 in fees to be paid at 80%. The signature block names Huiqi Liu.

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“United States Bankruptcy Court, District of Delaware — Case 22-10951-CTG, Doc 954.” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-deb-188293-954-0-3c6a17616a/, SHA-256 052fdcb45a1949965365b2af746554cb2766b4c2dfa1c26487bf9037d03010e4.

Full text

Case 22-10951-CTG Doc 954 Filed 08/09/23 Page 1 of 4

UNITED STATES BANKRUPTCY COURT
DISTRICT OF DELAWARE

------------------------------------------------------------ x
In re : Chapter 11
:
KServicing Wind Down Corp., et al., : Case No. 22-10951 (CTG)
:
: (Jointly Administered)
1
Post-Confirmation Debtors. :
------------------------------------------------------------ x Re: Docket No. 908

CERTIFICATE OF NO OBJECTION REGARDING THE NINTH
MONTHLY APPLICATION OF GREENBERG TRAURIG, LLP, AS
SPECIAL COUNSEL TO THE BOARD OF DIRECTORS OF KABBAGE,
INC. D/B/A KSERVICING, FOR ALLOWANCE OF COMPENSATION FOR
SERVICES RENDERED AND REIMBURSEMENT OF EXPENSES FOR
THE PERIOD FROM JUNE 1, 2023 THROUGH
JUNE 20, 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 ninth monthly fee application for

compensation and reimbursement of expenses (the “Monthly Application”) of Greenberg

Traurig, LLP (the “Applicant”). The Monthly Application was filed with the United States

Bankruptcy Court for the District of Delaware (the “Court”) on July 19, 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 August 8, 2023 at 4:00 p.m. (ET).

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: KServicing Wind Down Corp. (f/k/a Kabbage, Inc. d/b/a KServicing) (3937); KServicing
Wind Down Canada Holdings LLC (f/k/a Kabbage Canada Holdings, LLC) (N/A); KServicing Wind Down Asset
Securitization LLC (f/k/a Kabbage Asset Securitization LLC) (N/A); KServicing Wind Down Asset Funding 2017-
A LLC (f/k/a Kabbage Asset Funding 2017-A LLC) (4803); KServicing Wind Down Asset Funding 2019-A LLC
(f/k/a Kabbage Asset Funding 2019-A LLC) (8973); and KServicing Wind Down Diameter LLC (f/k/a Kabbage
Diameter, LLC) (N/A). 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 954 Filed 08/09/23 Page 2 of 4

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

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

October 21, 2022 [Docket No. 136] (the “Interim Compensation Order”). Pursuant to the

Interim Compensation Order, the Applicant is authorized and directed to be paid 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 954 Filed 08/09/23 Page 3 of 4

Dated: August 9, 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

3
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Case 22-10951-CTG Doc 954 Filed 08/09/23 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%
Greenberg 6/1/23 – $11,896.50 $0.00 8/8/23 $9,517.20 $0.00
Traurig, LLP 6/20/23

(Special
Counsel to 7/19/23
the Board of
Directors of
Kabbage, Inc. Docket No.
d/b/a 908
KServicing)

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