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Full title: Motion of the Liquidation Trust for Redaction of Certain Personal Date Identifiers Pursuant to Fed. R. Bankr. P. 9037 and Del. Bankr. L.R. 9037-1 Fee Amount $26 (related document(s)879) Filed by Cred Inc. Liquidation Trust. (Attachments: # 1 Notice # 2 Exhibit A # 3 Exhibit B) (Hurst, David) Modified on 8/12/2021 (SH). (Entered: 08/12/2021)

Document posted on Aug 11, 2021 in the bankruptcy, 5 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

The Cred Inc. Liquidation Trust (the “Trust”) established in the above-captioned chapter 11 cases (the “Chapter 11 Cases”) of Cred Inc. and its affiliated debtors (collectively, the “Debtors”) hereby moves (the “Motion”) pursuant to Rule 9037 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”) and Rule 9037-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”) for entry of an order, substantially in the form attached hereto as Exhibit A, directing the Clerk of the Court (the “Clerk”) to substitute the proposed redacted form of the Rule 2004 Motion (as defined herein) attached here as Exhibit B for the version of the Rule 2004 Motion currently filed on the docket in these cases.Cred Inc. (8268), Cred (US) LLC (5799), Cred Capital, Inc. (4064), Cred Merchant Solutions LLC (3150), Cred (Puerto Rico) LLC (3566).The Court has jurisdiction over this Motion pursuant to 28 U.S.C. §§ 157 and1334, and the Amended Standing Order of Reference from the United States District Court for the District of Delaware, dated February 29, 2012.In accordance with Local Rule 9013-1(f), the Trust confirms its consent to the entry of a final order by the Court in connection with this Motion to the extent that it is later determined that the Court, absent consent of the parties, cannot enter final orders or judgments in connection herewith consistent with Article III of the United States Constitution.On March 11, 2021, the Court entered an order [Docket No. 629] confirming theModified First Amended Combined Plan of Liquidation and Disclosure Statement of Cred Inc. and Its Subsidiaries Under Chapter 11 of the Bankruptcy Code

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IN THE UNITED STATES BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE ) Chapter 11 In re: ) ) Case No. 20-12836 (JTD) CRED INC., et al., ) ) (Jointly Administered) Debtors. 1 ) ) Obj. Deadline: 8/19/21 at 4:00 p.m. (ET) Hrg. Date: 8/26/21 at 3:00 p.m. (ET) ) ) Related to Docket No. 879 MOTION OF THE LIQUIDATION TRUST FOR REDACTION OF CERTAIN PERSONAL DATA IDENTIFIERS PURSUANT TO FED. R. BANKR. P. 9037 AND DEL. BANKR. L.R. 9037-1 The Cred Inc. Liquidation Trust (the “Trust”) established in the above-captioned chapter 11 cases (the “Chapter 11 Cases”) of Cred Inc. and its affiliated debtors (collectively, the “Debtors”) hereby moves (the “Motion”) pursuant to Rule 9037 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”) and Rule 9037-1 of the Local Rules of Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of Delaware (the “Local Rules”) for entry of an order, substantially in the form attached hereto as Exhibit A, directing the Clerk of the Court (the “Clerk”) to substitute the proposed redacted form of the Rule 2004 Motion (as defined herein) attached here as Exhibit B for the version of the Rule 2004 Motion currently filed on the docket in these cases. In support of this Motion, the Trust respectfully represents as follows: 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), Cred (Puerto Rico) LLC (3566). The Debtors’ mailing address is 3 East Third Avenue, San Mateo, California 94401.

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JURISDICTION AND VENUE 1. The Court has jurisdiction over this Motion pursuant to 28 U.S.C. §§ 157 and1334, and the Amended Standing Order of Reference from the United States District Court for the District of Delaware, dated February 29, 2012. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). In accordance with Local Rule 9013-1(f), the Trust confirms its consent to the entry of a final order by the Court in connection with this Motion to the extent that it is later determined that the Court, absent consent of the parties, cannot enter final orders or judgments in connection herewith consistent with Article III of the United States Constitution. 2. Venue in this Court is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 3. The legal predicates for the relief sought herein are Bankruptcy Rule 9037 andLocal Rule 9037-1. BACKGROUND 4. On November 7, 2020 (the “Petition Date”), the Debtors commenced the Chapter11 Cases by filing petitions for relief under chapter 11 of the Bankruptcy Code. 5. On March 11, 2021, the Court entered an order [Docket No. 629] confirming theModified First Amended Combined Plan of Liquidation and Disclosure Statement of Cred Inc. and Its Subsidiaries Under Chapter 11 of the Bankruptcy Code [Docket No. 629-1] (as amended, the “Plan”).2 The Plan became effective on April 19, 2021 (the “Effective Date”). See Docket No. 730. On the Effective Date, the Trust was established and the Debtors’ assets were transferred and assigned to the Trust. See Plan, § 12.3. The Trust is being administered by the Liquidation Trustees (as defined in the Plan). See Plan, § 12.3(a). 2 Capitalized terms used but not otherwise defined herein shall have the meanings set forth in the Plan.

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6. To facilitate the recovery of the Debtors’ assets, the Trust filed the Motion of theLiquidation Trust For Entry of an Order Directing Winslow Carter Strong to (I) Sit for a Rule 2004 Examination and (II) Produce Documents in Response to a Rule 2004 Subpoena [Docket No. 879] (the “Rule 2004 Motion”), thereby seeking the production of documents from, and the Bankruptcy Rule 2004 examination of, Mr. Winslow Carter Strong. RELIEF REQUESTED 7. By this Motion, the Trust requests entry of an order, substantially in the formattached hereto as Exhibit A, directing the Clerk to substitute the proposed redacted form of the Rule 2004 Motion attached here as Exhibit B for the version of the Rule 2004 Motion currently filed on the docket in these cases. BASIS FOR RELIEF REQUESTED 8. Local Rule 9037-1(b) provides that “[t]he filer of the document containingpersonal data identifiers shall . . . file a motion to redact that identifies the proposed document for redaction by docket number …. The filer shall submit, with the motion to redact, an exhibit containing the document to be substituted for the original filing.” Del. Bankr. L.R. 9037-1(b). 9. Relatedly, Local Rule 9037-1(c) provides that “[u]pon filing of the motion toredact, the Clerk’s Office will restrict the original image containing the personal data identifiers from public view (except as to the filer, the case trustee, the United States Trustee and the claims agent) on the docket.” Del. Bankr. L.R. 9037-1(c). 10. The Rule 2004 Motion inadvertently included Mr. Strong’s social securitynumber (the “SSN”), which is a personal data identifier within the meaning of Bankruptcy Rule 9037. Accordingly, the Trust requests that the Court direct the Clerk to substitute the proposed redacted form of the Rule 2004 Motion attached here as Exhibit B for the version of the Rule

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2004 Motion currently filed on the docket in these cases, so that only the last four digits of Mr. Strong’s SSN are shown in the pleading. NOTICE 11. Notice of the Motion has been provided to (i) Mr. Strong, (ii) counsel to the Mr. Strong, and (iii) parties that have requested notice pursuant to Local Rule 2002-1(b). In light of the nature of the relief requested herein, the Trust submits that no other or further notice is required. [Remainder of Page Intentionally Left Blank]

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WHEREFORE, the Trust requests entry of an order, substantially in the form attached hereto as Exhibit A, directing the Clerk to substitute the proposed redacted form of the Rule 2004 Motion attached here as Exhibit B for the version of the Rule 2004 Motion currently filed on the docket in these cases. Dated: Wilmington, Delaware August 12, 2021 MCDERMOTT WILL & EMERY LLP /s/ David R. Hurst David R. Hurst (I.D. No. 3743) 1007 North Orange Street, 10th Floor Wilmington, DE 19801 Telephone: (302) 485-3900 Facsimile: (302) 351-8711 -and - Darren Azman (admitted pro hac vice) Joseph B. Evans (admitted pro hac vice) 1 Vanderbilt Avenue New York, NY 10017 Telephone: (212) 547-5400 Facsimile: (212) 547-5444 Counsel to the Cred Inc. Liquidation Trust

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