Vyaire - CNO - Seal Motion re DIP Fee Letters Order Final — In re Vyaire Medical, Inc., et al.

Source document: Vyaire - CNO - Seal Motion re DIP Fee Letters Order Final — In re Vyaire Medical, Inc., et al.; document type: Certificate of no objection (re: Dockets 45 and 107).

Full text

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 No. 45 & 107
CERTIFICATE OF NO OBJECTION
REGARDING MOTION OF DEBTORS FOR ENTRY
OF AN ORDER AUTHORIZING THE DEBTORS TO FILE
UNDER SEAL THE FEE LETTERS RELATED TO THE DIP FACILITY
The undersigned proposed counsel to Vyaire Medical, Inc. and certain of its affiliates, the
debtors and debtors in possession in the above-captioned cases (collectively, the “Debtors”),
hereby certifies that, as of the date hereof, no answer, objection, or other responsive pleading has
been received to the Motion of Debtors for Entry of an Order Authorizing the Debtors to File
Under Seal the Fee Letters Related to the DIP Facility [Docket No. 45] (the “Motion”) filed with
the United States Bankruptcy Court for the District of Delaware (the “Court”) on June 10, 2024.
Attached thereto as Exhibit A was a proposed form of order granting the relief requested in the
Motion (the “Proposed Order”).  The undersigned further certifies that the Court’s docket has been
reviewed in this case and no answer, objection, or other responsive pleading to the Motion appears
thereon.  Pursuant to the Notice of Motion of Debtors for Entry of an Order Authorizing the Debtors
to File Under Seal the Fee Letters Related to the DIP Facility [Docket No. 107], objections or
responses to the Motion and entry of the Proposed Order were to be filed and served on the
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.
Case 24-11217-BLS    Doc 137    Filed 07/03/24    Page 1 of 2

2
undersigned proposed counsel by July 2, 2024, at 4:00 p.m. (prevailing Eastern Time), except for
the Official Committee of Unsecured Creditors (the “Committee”), whose deadline was extended
to July 5, 2024.  Counsel to the Committee has informed the undersigned proposed counsel it does
not object to the Motion and entry of the Proposed Order.  It is hereby respectfully requested that
the Proposed Order attached to the Motion be entered at the earliest convenience of the Court.
Dated: July 3, 2024
Wilmington, Delaware
/s/ Patrick J. Reilley
COLE SCHOTZ P.C.
KIRKLAND & ELLIS LLP
Patrick J. Reilley, Esq. (No. 4451)
KIRKLAND & ELLIS INTERNATIONAL LLP
500 Delaware Avenue, Suite 1410
Joshua A. Sussberg, P.C. (admitted pro hac vice)
Wilmington, Delaware 19801
601 Lexington Ave
Telephone:
(302) 652-3131
New York, New York 10022
Facsimile:
(302) 652-3117
Telephone:
(212) 446-4800
Email:
preilley@coleschotz.com
Facsimile:
(212) 446-4900
Email:
joshua.sussberg@kirkland.com
- and -
- and -
Michael D. Sirota, Esq. (admitted pro hac vice)
Warren A. Usatine, Esq (admitted pro hac vice)
Spencer A. Winters, P.C. (admitted pro hac vice)
Court Plaza North, 25 Main Street
Yusuf U. Salloum (admitted pro hac vice)
Hackensack, New Jersey 07601
333 West Wolf Point Plaza
Telephone:
(201) 489-3000
Chicago, Illinois 60654
Facsimile:
(201) 489-1536
Telephone:
(312) 862-2000
Email:
msirota@coleschotz.com
Facsimile:
(312) 862-2200
wusatine@coleschotz.com
Email:
spencer.winters@kirkland.com
yusuf.salloum@kirkland.com
Proposed Co-Counsel to the Debtors
Proposed Co-Counsel to the Debtors
and Debtors in Possession
and Debtors in Possession
Case 24-11217-BLS    Doc 137    Filed 07/03/24    Page 2 of 2

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