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Full title: Certification of Counsel Regarding Order Denying Amended Application of Invictus Global Management, LLC for Allowance and Payment of Fees Pursuant to Bankruptcy Code Sections 503(b)(1)(A), 503(b)(3)(d) and 503(b)(4) (related document(s)686) Filed by Cred Inc. Liquidation Trust. (Attachments: # 1 Exhibit A) (Hurst, David) (Entered: 04/22/2021)

Document posted on Apr 21, 2021 in the bankruptcy, 3 pages and 0 tables.

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On March 26, 2021, Invictus Global Management, LLC (“Invictus”) filed the Amended Application of Invictus Global Management, LLC for Allowance and Payment of Fees Pursuant to Bankruptcy Code Sections 503(b)(1)(A), 503(b)(3)(D) and 503(b)(4)Cred Inc. (8268), Cred (US) LLC (5799), Cred Capital, Inc. (4064), Cred Merchant Solutions LLC (3150), and Cred (Puerto Rico) LLC (3566).Management, LLC for Allowance and Payment of Fees Pursuant to Bankruptcy Code Sections 503(b)(1)(A), 503(b)(3)(D), and 503(b)(4)On April 14, 2021, the Official Committee of Unsecured Creditors filed under seal the Objection of the Official Committee of Unsecured Creditors to Amended Application of Invictus Global Management LLC for Allowance and Payment of Fees Pursuant to Bankruptcy Code Sections 503(b)(1)(A), 503(b)(3)(D) and 503(b)(4)The Liquidation Trust has prepared a proposed form of order (the “Proposed Order”), a copy of which is attached hereto as Exhibit A, which reflects the Court’s ruling on the record at the Hearing.

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IN THE 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 ) ) Related to Docket No. 686 CERTIFICATION OF COUNSEL REGARDING ORDER DENYING AMENDED APPLICATION OF INVICTUS GLOBAL MANAGEMENT, LLC FOR ALLOWANCE AND PAYMENT OF FEES PURSUANT TO BANKRUPTCY CODE SECTIONS 503(b)(1)(A), 503(b)(3)(d) AND 503(b)(4) The undersigned, counsel to the Cred Inc. Liquidation Trust (the “Liquidation Trust”), hereby certifies as follows: 1. On March 26, 2021, Invictus Global Management, LLC (“Invictus”) filed the Amended Application of Invictus Global Management, LLC for Allowance and Payment of Fees Pursuant to Bankruptcy Code Sections 503(b)(1)(A), 503(b)(3)(D) and 503(b)(4) [Docket No. 686] (the “Application”) with the United States Bankruptcy Court for the District of Delaware (the “Court”), seeking allowance and payment of fees constituting (i) a substantial contribution to the Debtors’ estates or, (ii) in the alternative, an administrative expense of the Debtors’ estates. 2. On April 9, 2021, the Office of the United States Trustee (the “U.S. Trustee”) filed the Objection of the United States Trustee to the Amended Application of Invictus Global 1 The Debtors in these chapter 11 cases, together with the last four digits of each Debtor’s federal tax identification number, 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, San Mateo, California 94401.

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Management, LLC for Allowance and Payment of Fees Pursuant to Bankruptcy Code Sections 503(b)(1)(A), 503(b)(3)(D), and 503(b)(4) [Docket No. 701]. 3. On April 14, 2021, the Official Committee of Unsecured Creditors filed under seal the Objection of the Official Committee of Unsecured Creditors to Amended Application of Invictus Global Management LLC for Allowance and Payment of Fees Pursuant to Bankruptcy Code Sections 503(b)(1)(A), 503(b)(3)(D) and 503(b)(4) [Docket No. 704]. 4. On April 21, 2021, the Court conducted a hearing (the “Hearing”) to consider the relief requested in the Application. At the Hearing, the Court indicated that it would deny the relief requested in the Application based upon the record of the Hearing. 5. The Liquidation Trust has prepared a proposed form of order (the “Proposed Order”), a copy of which is attached hereto as Exhibit A, which reflects the Court’s ruling on the record at the Hearing. The U.S. Trustee and counsel to Invictus have reviewed the Proposed Order and do not object to entry of such order. [Remainder of Page Intentionally Left Blank]

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6. Accordingly, the Liquidation Trust respectfully requests that the Court enter the Revised Proposed Order at the convenience of the Court. Dated: Wilmington, Delaware April 22, 2021 MCDERMOTT WILL & EMERY LLP /s/ David R. Hurst David R. Hurst (I.D. No. 3743) The Nemours Building 1007 North Orange Street, 10th Floor Wilmington, DE 19801 Telephone: (302) 485-3900 Fax: (302) 351-8711 - and - Timothy W. Walsh (admitted pro hac vice) Darren Azman (admitted pro hac vice) 340 Madison Avenue New York, NY 10173-1922 Telephone: (212) 547-5400 Fax: (212) 547-5444 Counsel to Cred Inc. Liquidation Trust

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