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Full title: Certificate of No Objection Regarding Stipulation Granting Derivative Standing to the Official Committee of Unsecured Creditors to Commence Litigation (related document(s)279, 304, 467) Filed by Cred Inc.. (Attachments: # 1 Proposed Form of Order) (Cousins, Scott) (Entered: 02/24/2021)

Document posted on Feb 23, 2021 in the bankruptcy, 3 pages and 0 tables.

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The undersigned hereby certifies that he has received no answer, objection, or any other responsive pleading to the Notice of Filing of Stipulation Granting DerivativeStanding to the Official Committee of Unsecured Creditors to Commence Litigation [Docket No. 304] (the “Derivative Standing Stipulation”) filed by the above-captioned debtors and debtors-in-possession (collectively, the “Debtors”) with the United States Bankruptcy Court for the District of Delaware (the “Bankruptcy Court”) on December 31, 2020, or the Stipulation Between the Official Committee of Unsecured Creditors and the Debtors [Docket No. 467] (the “Second Derivative Standing Stipulation,” and with the Derivative Standing Stipulation, the “Derivative Standing Stipulations”).The Derivative Standing Stipulations represented an agreement between the Debtors and the Official Committee of Unsecured Creditors (the “Committee”) that was contained in the Debtors’ Motion Pursuant to Bankruptcy Code Sections 363(b) and 105(a) for Authorization to Enter Into and Perform Under a Plan Support Agreement Term Sheet [Docket No. 279] (the 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 undersigned further certifies that no answer, objection, or other responsive pleading to the Derivative Standing Stipulations has appeared on the Bankruptcy Court’s docket in these cases. PAUL HASTINGS LLP 600 Travis Street, Fifty-Eighth Floor Houston, Texas 77002

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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) ) ) ) Docket No. 279, 304 & 467 CERTIFICATE OF NO OBJECTION REGARDING STIPULATION GRANTING DERIVATIVE STANDING TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS TO COMMENCE LITIGATION The undersigned hereby certifies that he has received no answer, objection, or any other responsive pleading to the Notice of Filing of Stipulation Granting Derivative Standing to the Official Committee of Unsecured Creditors to Commence Litigation [Docket No. 304] (the “Derivative Standing Stipulation”) filed by the above-captioned debtors and debtors-in-possession (collectively, the “Debtors”) with the United States Bankruptcy Court for the District of Delaware (the “Bankruptcy Court”) on December 31, 2020, or the Stipulation Between the Official Committee of Unsecured Creditors and the Debtors [Docket No. 467] (the “Second Derivative Standing Stipulation,” and with the Derivative Standing Stipulation, the “Derivative Standing Stipulations”). The Derivative Standing Stipulations represented an agreement between the Debtors and the Official Committee of Unsecured Creditors (the “Committee”) that was contained in the Debtors’ Motion Pursuant to Bankruptcy Code Sections 363(b) and 105(a) for Authorization to Enter Into and Perform Under a Plan Support Agreement Term Sheet [Docket No. 279] (the 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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“PSA Motion”). The PSA Motion was approved by the Bankruptcy Court on February 5, 2021. The undersigned further certifies that no answer, objection, or other responsive pleading to the Derivative Standing Stipulations has appeared on the Bankruptcy Court’s docket in these cases.

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WHEREFORE, the Debtors respectfully request that an order, substantially in the form attached hereto as Exhibit A, be entered at the earliest convenience of the Bankruptcy Court. Dated: February 24, 2021 Wilmington, Delaware /s/ Scott D. Cousins Scott D. Cousins (No. 3079) Scott D. Jones (No. 6672) COUSINS LAW LLC Brandywine Plaza West 1521 Concord Pike, Suite 301 Wilmington, Delaware 19803 Telephone: (302) 824-7081 Facsimile: (302) 295-0331 Email: scott.cousins@cousins-law.com - and - James T. Grogan (admitted pro hac vice) Mack Wilson (admitted pro hac vice) PAUL HASTINGS LLP 600 Travis Street, Fifty-Eighth Floor Houston, Texas 77002 Telephone: (713) 860-7300 Facsimile: (713) 353-3100 Email: jamesgrogan@paulhastings.com 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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