In re: Vyaire Medical, Inc., Case No. 24-11217 (BLS) — United States Bankruptcy Court, District of Delaware (Doc 73)

Summary

Counsel file a Notice of Appearance and Request for Notices (Doc 73, filed 06/10/24, Case No. 24-11217 (BLS)) as counsel for SunMed Group Holdings, LLC (d/b/a AirLife), asking that all notices and papers in the cases be served on the listed attorneys. The signature block names Potter Anderson & Corroon LLP and Goodwin Procter LLP as counsel. The request cites Rules 2002 and 9010(b) of the Federal Rules of Bankruptcy Procedures and 11 U.S.C. § 1109(b). It states that the filing does not waive any substantive or procedural right of AirLife, including the right to have final orders in non-core matters entered only after de novo review by the District Court and the right to trial by jury.

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                    Case 24-11217-BLS   Doc 73    Filed 06/10/24     Page 1 of 3




                       IN THE UNITED STATES BANKRUPTCY COURT
                            FOR THE DISTRICT OF DELAWARE


 In re:                                            Chapter 11

 Vyaire Medical, Inc.,                             Case No. 24-11217 (BLS)

                          Debtors.                 (Joint Administration Requested)


                    NOTICE OF APPEARANCE AND REQUEST FOR NOTICES

          PLEASE TAKE NOTICE that, pursuant to Rules 2002 and 9010(b) of the Federal Rules

of Bankruptcy Procedures (the “Bankruptcy Rules”), the undersigned counsel enter their

appearance as counsel for SunMed Group Holdings, LLC (d/b/a AirLife) (“AirLife”) and request

that all notices and other papers filed or served in the above-captioned cases be served upon the

following attorneys:

 Kizzy L. Jarashow, Esq.                         L. Katherine Good (No. 5101)
 Alexander J. Nicas, Esq.                        Aaron H. Stulman (No. 5807)
 Liza Burton, Esq.                               POTTER ANDERSON & CORROON LLP
 Amanda Schaefer, Esq.                           1313 N. Market Street, 6th Floor
 GOODWIN PROCTER LLP                             Wilmington, Delaware 19801
 The New York Times Building                     Telephone: (302) 984-6000
 620 Eighth Avenue                               Facsimile: (302) 658-1192
 New York, New York 10018                        Email: kgood@potteranderson.com
 Telephone: (212) 459-7338                              astulman@potteranderson.com
 Facsimile: (646) 558-4183
 Email: kjarashow@goodwinlaw.com
        anicas@goodwinlaw.com
        lburton@goodwinlaw.com
        aschaefer@goodwinlaw.com




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                    Case 24-11217-BLS     Doc 73      Filed 06/10/24     Page 2 of 3




        PLEASE TAKE FURTHER NOTICE that, pursuant to 11 U.S.C. § 1109(b), the

foregoing request includes not only the notices and papers referred to in the Bankruptcy Rules

specified above, but also includes, without limitation, any notice, application, complaint, demand,

motion, petition, pleading, or request, whether formal or informal, written or oral, and whether

transmitted or conveyed by mail, delivery, telephone, electronic filing, facsimile, or otherwise filed

or made with regard to the referenced case and proceedings herein.

        PLEASE TAKE FURTHER NOTICE that filing of this Notice of Appearance and

Request for Notices shall not be deemed or construed to constitute a waiver of any substantive or

procedural right of AirLife including, without limitation: (i) the right to have final orders in non-

core matters entered only after de novo review by the United States District Court for the District

of Delaware (the “District Court”), (ii) the right to trial by jury in any proceeding related to this

case or any case, controversy, or proceeding related to this case, (iii) the right to have the District

Court withdraw the reference in any matter subject to mandatory or discretionary withdrawal,

(iv) the right to have any matter in which this Court, absent consent of the parties, cannot enter

final orders or judgments consistent with Article III of the United States Constitution heard by the

District Court; or (v) any other rights, claims, actions, defenses, setoffs, or recoupments to which

AirLife is or may be entitled, in law or in equity, all of which rights, claims, actions, defenses,

setoffs and recoupments are expressly reserved.         Unless and until AirLife expressly states

otherwise, AirLife does not consent to the entry of final orders or judgments by this Court if it is

determined that this Court, absent consent of the parties, cannot enter final orders or judgments

consistent with Article III of the United States Constitution.




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                    Case 24-11217-BLS   Doc 73    Filed 06/10/24     Page 3 of 3




Dated: June 10, 2024                       Respectfully submitted,
       Wilmington, Delaware

                                           /s/ L. Katherine Good
                                           L. Katherine Good (No. 5101)
                                           Aaron H. Stulman (No. 5807)
                                           POTTER ANDERSON & CORROON LLP
                                           1313 N. Market Street, 6th Floor
                                           Wilmington, Delaware 19801
                                           Telephone: (302) 984-6000
                                           Facsimile: (302) 658-1192
                                           Email: kgood@potteranderson.com
                                                   astulman@potterson.com

                                           – and –

                                           Kizzy L. Jarashow, Esq.
                                           Alex Nicas, Esq.
                                           Liza Burton, Esq.
                                           Amanda Schaefer, Esq.
                                           GOODWIN PROCTER LLP
                                           The New York Times Building
                                           620 Eighth Avenue
                                           New York, New York 10018
                                           Telephone: (212) 459-7338
                                           Facsimile: (646) 558-4183
                                           Email: kjarashow@goodwinlaw.com
                                                  anicas@goodwinlaw.com
                                                  lburton@goodwinlaw.com
                                                  aschaefer@goodwinlaw.com


                                           Counsel for SunMed Group Holdings, LLC (d/b/a AirLife)




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