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Vyaire - Notice of Filing of Revised Mettawa Stipulation

Date
2024-06-09

Summary

A Notice of Filing of Amended Joint Stipulation Between the Debtors and Dell-Mettawa, LLC Regarding Rejection of Lease in Connection with Zoll Sale, filed December 12, 2024 as Doc 837 in In re Vyaire Medical, Inc., et al., Case No. 24-11217 (BLS), in the United States Bankruptcy Court for the District of Delaware. The notice recites that the Debtors filed a certification of counsel on the Joint Stipulation on November 25, 2024 [Docket No. 798] and that the Court approved it on December 2, 2024 [Docket No. 813]. It states that paragraph 19 made the stipulation void if its Effective Date did not occur by November 30, 2024, and that the parties wish to amend that outside date. The revised stipulation is attached as Exhibit 1 and a redline as Exhibit 2. It is signed by Cole Schotz P.C., with Kirkland & Ellis LLP also in the signature block, as co-counsel to the Plan Administrator.

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Full text

                   Case 24-11217-BLS              Doc 837       Filed 12/12/24         Page 1 of 3




                          IN THE UNITED STATES BANKRUPTCY COURT
                               FOR THE DISTRICT OF DELAWARE

                                                                )
    In re:                                                      )    Chapter 11
                                                                )
    VYAIRE MEDICAL, INC., et al.,1                              )    Case No. 24-11217 (BLS)
                                                                )
                              Debtors.                          )    (Jointly Administered)
                                                                )
                                                                )    Re: Docket Nos. 798 & 813
                                                                )

      NOTICE OF FILING OF AMENDED JOINT STIPULATION BETWEEN THE
    DEBTORS AND DELL-METTAWA, LLC REGARDING REJECTION OF LEASE IN
                      CONNECTION WITH ZOLL SALE

        PLEASE TAKE NOTICE that, on June 9, 2024, each of the above-captioned debtors and
certain of its subsidiaries (collectively, the “Debtors”)2 filed a petition with this Court under
chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”).

        PLEASE TAKE FURTHER NOTICE that, on November 25, 2024, the Debtors filed the
Certification of Counsel Regarding Joint Stipulation Between the Debtors and DellMettawa, LLC
Regarding Rejection of Lease in Connection With Zoll Sale [Docket No. 798] seeking entry of an
Order approving the Joint Stipulation Between the Debtors and DellMettawa, LLC Regarding
Rejection of Lease in Connection With Zoll Sale (the “Joint Stipulation”).

        PLEASE TAKE FURTHER NOTICE that, paragraph 19 of the Joint Stipulation
provided that if the Effective Date of the Joint Stipulation does not occur by November 30, 2024,
the Joint Stipulation shall be considered null and void.

        PLEASE TAKE FURTHER NOTICE that on December 2, 2024, the United States
Bankruptcy Court for the District of Delaware (the “Court”) entered the Order Approving Joint
Stipulation Between the Debtors and DellMettawa, LLC Regarding Rejection of Lease in
Connection With Zoll Sale [Docket No. 813] (the “Order”) at which time the Effective Date of the
Joint Stipulation occurred.




1
      The last four digits of Debtor Vyaire Medical, Inc.’s federal tax identification number are 6495. A complete list
      of each of the Debtors in these chapter 11 cases and each such Debtor’s federal tax identification number may be
      obtained on the website of the Debtors’ claims and noticing agent at https://omniagentsolutions.com/Vyaire. The
      location of Debtor Vyaire Medical, Inc.’s principal place of business and the Debtors’ service address in these
      chapter 11 cases is 26125 North Riverwoods Boulevard, Mettawa, Illinois, USA 60045.
2
      Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Joint Stipulation.
              Case 24-11217-BLS        Doc 837     Filed 12/12/24    Page 2 of 3




        PLEASE TAKE FURTHER NOTICE that the parties desire to amend the Joint
Stipulation approved by the Order to amend the outside Effective Date set forth in paragraph 19
of the Joint Stipulation to ensure the effectiveness of the Joint Stipulation.

        PLEASE TAKE FURTHER NOTICE that a copy of the revised Joint Stipulation (the
“Revised Joint Stipulation”) is attached hereto as Exhibit 1 and a redline comparing the Revised
Joint Stipulation against the Joint Stipulation is attached hereto as Exhibit 2.

       PLEASE TAKE FURTHER NOTICE that the parties to the Joint Stipulation agree that
the Revised Joint Stipulation shall replace and supersede the Joint Stipulation.


                         [Remainder of Page Intentionally Left Blank]




                                               2
                        Case 24-11217-BLS          Doc 837      Filed 12/12/24     Page 3 of 3




Dated: December 12, 2024
Wilmington, Delaware

 /s/ Patrick J. Reilley
 COLE SCHOTZ P.C.                                              KIRKLAND & ELLIS LLP
 Patrick J. Reilley (No. 4451)                                 KIRKLAND & ELLIS INTERNATIONAL LLP
 Stacy L. Newman (No. 5044)                                    Joshua A. Sussberg, P.C. (admitted pro hac vice)
 500 Delaware Avenue, Suite 1410                               601 Lexington Ave
 Wilmington, Delaware 19801                                    New York, New York 10022
 Telephone:        (302) 652-3131                              Telephone:    (212) 446-4800
 Facsimile:        (302) 652-3117                              Facsimile:    (212) 446-4900
 Email:            preilley@coleschotz.com                     Email:        joshua.sussberg@kirkland.com
                   snewman@coleschotz.com

 - and -                                                       - and -

 Michael D. Sirota, Esq. (admitted pro hac vice)               Spencer A. Winters, P.C. (admitted pro hac vice)
 Warren A. Usatine, Esq (admitted pro hac vice)                Yusuf U. Salloum (admitted pro hac vice)
 Court Plaza North, 25 Main Street                             333 West Wolf Point Plaza
 Hackensack, New Jersey 07601                                  Chicago, Illinois 60654
 Telephone:     (201) 489-3000                                 Telephone:      (312) 862-2000
 Facsimile:     (201) 489-1536                                 Facsimile:      (312) 862-2200
 Email:         msirota@coleschotz.com                         Email:          spencer.winters@kirkland.com
                wusatine@coleschotz.com                                        yusuf.salloum@kirkland.com

 Co-Counsel to David M. Barse, Plan Administrator to the       Co-Counsel to David M. Barse, Plan Administrator to the
 Wind Down Debtors                                             Wind Down Debtors




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