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Full title: Certification of Counsel Regarding Order Approving Emergency Motion of Official Committee of Unsecured Creditors for Entry of an Order Granting (I) Temporary Restraining Order and Preliminary Injunction Against James Alexander and (II) Related Relief Filed by Cred Inc.. (Cousins, Scott) (Entered: 02/05/2021)

Document posted on Feb 4, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

INC., CRED CAPITAL, INC., and ) CRED (US) LLC ) Plaintiffs, ) On February 5, 2021, this Court held a hearing (the “Hearing”) with respect to the Emergency Motion of the Official Committee of Unsecured Creditors for Entry of an Order Granting (I)Cred Inc. (8268), Cred (US) LLC (5799), Cred Capital Inc. (4064), Cred Merchant Solutions LLC (3150), and Cred (Puerto Rico) LLC (3566).The above-captioned debtors and debtors-in-possession (collectively, the “Debtors”) and the Official Committee of Unsecured Creditors (the “Committee”) have prepared a form of order reflecting the Court’s rulings on the record of the Hearing, which is attached hereto as Exhibit A (the “Proposed Order”).[Remainder of page intentionally left blank] WHEREFORE, the Debtors and the Committee respectfully request that the Court enter the Proposed Order, attached hereto as Exhibit A, at its earliest convenience.

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UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) In re: ) Chapter 11 ) CRED INC., et al., ) Case No. 20-12836 (JTD) ) Debtors.1 ) (Jointly Administered) ) ) CRED INC., CRED CAPITAL, INC., and ) CRED (US) LLC ) Plaintiffs, ) Adversary Proceeding No. 20-51006 (JTD) ) v. ) ) JAMES ALEXANDER ) Re: Adversary Docket No. 6 Defendant ) ) CERTIFICATION OF COUNSEL REGARDING ORDER APPROVING EMERGENCY MOTION OF OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR ENTRY OF AN ORDER GRANTING (I) TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION AGAINST JAMES ALEXANDER AND (II) RELATED RELIEF The undersigned hereby certifies as follows: 1. On February 5, 2021, this Court held a hearing (the “Hearing”) with respect to the Emergency Motion of the Official Committee of Unsecured Creditors for Entry of an Order Granting (I) Temporary Restraining Order and Preliminary Injunction Against James Alexander and (II) Related Relief [Adv. Docket No. 6] (the “Emergency Motion”) and made certain rulings on the record with respect to such Emergency Motion.   1 The Debtors in these chapter 11 cases, along with the last four digits of each debtor’s tax identification number, as applicable, are as follows: Cred Inc. (8268), Cred (US) LLC (5799), Cred Capital Inc. (4064), Cred Merchant Solutions LLC (3150), and Cred (Puerto Rico) LLC (3566). The Debtors’ mailing address is 3 East Third Avenue, Suite 200, San Mateo, California 94401.

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2. The above-captioned debtors and debtors-in-possession (collectively, the “Debtors”) and the Official Committee of Unsecured Creditors (the “Committee”) have prepared a form of order reflecting the Court’s rulings on the record of the Hearing, which is attached hereto as Exhibit A (the “Proposed Order”). 3. The Proposed Order has been circulated to counsel to James Alexander, the U.S. Trustee and counsel to the Examiner, all of whom have indicated that they do not object to the entry of the Proposed Order. [Remainder of page intentionally left blank]

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WHEREFORE, the Debtors and the Committee respectfully request that the Court enter the Proposed Order, attached hereto as Exhibit A, at its earliest convenience. Dated: February 5, 2021 Wilmington, Delaware McDERMOTT WILL & EMERY, LLP COUSINS LAW LLC By: /s/ David R. Hurst B y: /s/ Scott D. Cousins David R. Hurst Scott D. Cousins (No. 3079) The Nemours Building Brandywine Plaza West 1007 North Orange Street, 10th Floor 1521 Concord Pike, Suite 301 Wilmington, DE 19801 Wilmington, Delaware 19803 Telephone: (302) 485-3900 Telephone: (302) 824-7081 Facsimile: (302) 351-8711 Facsimile: (302) 295-0331 Email: scott.cousins@cousins-law.com -and- - and - Timothy W. Walsh James T. Grogan (admitted pro hac vice) Darren Azman Mack Wilson (admitted pro hac vice) 340 Madison Avenue PAUL HASTINGS LLP New York, NY 10173-1922 600 Travis Street, Fifty-Eighth Floor Telephone: (212) 547-5400 Houston, Texas 77002 Facsimile: (212) 547-5444 Telephone: (713) 860-7300 Facsimile: (713) 353-3100 Counsel to the Official Email: jamesgrogan@paulhastings.com Committee of Unsecured Creditors mackwilson@paulhastings.com - and - Pedro A. Jimenez (admitted pro hac vice) Avram Emmanuel Luft (admitted pro hac vice) PAUL HASTINGS LLP 200 Park Avenue New York, New York 10166 Telephone: (212) 318-6000 Facsimile: (212) 319-4090 Email: pedrojimenez@paulhastings.com aviluft@paulhastings.com Co-Counsel to the Debtors

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