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Certificate of No Objection Regarding the Ninth Monthly Application of Jones Day

Summary

A Certificate of No Objection in Case No. 22-10951 (CTG), the jointly administered chapter 11 cases of KServicing Wind Down Corp., et al., regarding the ninth monthly application of Jones Day, special counsel to the debtors, for allowance of compensation and reimbursement of expenses for the period from June 1, 2023 through June 20, 2023 (Docket No. 909). The certificate states that the undersigned has received no answer, objection or other responsive pleading to the application. It states that the application was filed with the Court on July 19, 2023 and that no order is required.

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Cite this document

“Certificate of No Objection Regarding the Ninth Monthly Application of Jones Day.” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-deb-188293-955-0-566580e956/, SHA-256 b49f3c41b8ecb2df30a9113dc7ecc5bf521b13403161b1691ebc876053f372eb.

Full text

                   Case 22-10951-CTG             Doc 955         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. 909

            CERTIFICATE OF NO OBJECTION REGARDING THE NINTH
        MONTHLY APPLICATION OF JONES DAY, SPECIAL COUNSEL TO THE
         DEBTORS, FOR ALLOWANCE OF COMPENSATION FOR SERVICES
      RENDERED AND FOR REIMBURSEMENT OF EXPENSES FOR 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 Jones Day (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 955     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 955     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 955     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%
        Jones Day        6/1/23 –       $3,950.00    $9,797.54    8/8/23     $3,160.00    $9,797.54
                         6/20/23
        (Special
       Counsel to        7/19/23
      the Debtors)
                       Docket No.
                          909




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