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Full title: Certification of Counsel Regarding Motion to File Under Seal Compendium of Exhibits to Report of Robert J. Stark, Examiner (related document(s)717) Filed by Robert J. Stark. (Attachments: # 1 Exhibit A: Revised Proposed Order # 2 Exhibit B: Blackline) (Taylor, Gregory) (Entered: 06/02/2021)

Document posted on Jun 1, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

On April 16, 2021, Robert J. Stark, in his capacity as the Court-appointed examiner (the “Examiner”) in the above-captioned Chapter 11 cases of Cred, Inc. and its affiliated debtors and debtors-in-possession (collectively, the “Debtors”), filed the Motion to File Under Seal Compendium of Exhibits to Report of Robert J. Stark, Examiner [D.I. 717] (the “Motion”).2 2. Pursuant to the Notice of Motion to File Under Seal Compendium of Exhibits to Report of Robert J. Stark, Examiner filed with the Motion, objections to the Motion were to be filed by no later than April 30, 2021 at 4:00 p.m.Prior to the Objection Deadline, the Examiner received informal comments to the relief requested in the Motion from the United States Trustee for the District of Delaware (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 Examiner resolved the comments by revising the Proposed Order, and such revised order is attached hereto as Exhibit A (the “Revised Order”).For the convenience of the Court and all parties in interest, a blackline of the Revised Order against the Proposed Order is attached here to as Exhibit B. WHEREFORE, the Examiner respectfully requests that the Court enter the Revised Order, attached hereto as Exhibit A, at its earliest convenience.

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE In re: Chapter 11 Case No. 20-12836 (JTD) CRED INC., et al.,1 (Jointly Administered) Debtors. Re: D.I. 717 CERTIFICATION OF COUNSEL REGARDING MOTION TO FILE UNDER SEAL COMPENDIUM OF EXHIBITS TO REPORT OF ROBERT J. STARK, EXAMINER The undersigned counsel hereby certifies and states as follows: 1. On April 16, 2021, Robert J. Stark, in his capacity as the Court-appointed examiner (the “Examiner”) in the above-captioned Chapter 11 cases of Cred, Inc. and its affiliated debtors and debtors-in-possession (collectively, the “Debtors”), filed the Motion to File Under Seal Compendium of Exhibits to Report of Robert J. Stark, Examiner [D.I. 717] (the “Motion”).2 2. Pursuant to the Notice of Motion to File Under Seal Compendium of Exhibits to Report of Robert J. Stark, Examiner filed with the Motion, objections to the Motion were to be filed by no later than April 30, 2021 at 4:00 p.m. (ET) (the “Objection Deadline”). 3. Prior to the Objection Deadline, the Examiner received informal comments to the relief requested in the Motion from the United States Trustee for the District of Delaware (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. 2 Capitalized terms used but not otherwise defined herein shall have the meaning ascribed to such terms in the Motion.

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“UST”). The Examiner resolved the comments by revising the Proposed Order, and such revised order is attached hereto as Exhibit A (the “Revised Order”). 4. Other than the informal comments received by the UST, the Examiner received no other informal responses to the Motion, and no other objection or responsive pleading to the Motion has appeared on the Court’s docket in these chapter 11 cases. 5. The Revised Order has been circulated to the UST, counsel to the Official Committee of Unsecured Creditors, and counsel to the Debtors, and the aforementioned parties do not object to the entry of the Revised Order. For the convenience of the Court and all parties in interest, a blackline of the Revised Order against the Proposed Order is attached here to as Exhibit B. WHEREFORE, the Examiner respectfully requests that the Court enter the Revised Order, attached hereto as Exhibit A, at its earliest convenience. [Signature Page to Follow]

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Dated: June 2, 2021 Respectfully submitted, Wilmington, Delaware ASHBY & GEDDES, P.A. /s/ Gregory A. Taylor Gregory A. Taylor (DE Bar No. 4008) Katharina Earle (DE Bar No. 6348) 500 Delaware Avenue, 8th Floor P.O. Box 1150 Wilmington, DE 19899 Tel: (302) 654-1888 Email: gtaylor@ashbygeddes.com kearle@ashbygeddes.com -and- BROWN RUDNICK LLP Andrew M. Carty (admitted pro hac vice) Michael W. Reining (admitted pro hac vice) Seven Times Square New York, NY 10036 Tel: (212) 209-4800 Email: acarty@brownrudnick.com mreining@brownrudnick.com Counsel to Robert J. Stark, in his capacity as Chapter 11 Examiner for Debtors

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