Motion of Debtors for Entry of Interim — In re Vyaire Medical, Inc., et al., Case No. 24-11217 (Bankr. D. Del.) (joint administration requested) (2024-06-10, 1)

Date: 2024-06-10

Source document: Motion Of Debtors For Entry Of Interim; document type: First-day motion, with proposed interim and final orders and exhibits attached (29 pp.).

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 (___)

)

Debtors.
)
(Joint Administration Requested)

)

MOTION OF DEBTORS FOR ENTRY OF INTERIM
AND FINAL ORDERS (I) AUTHORIZING THE DEBTORS
TO (A) MAINTAIN INSURANCE AND SURETY COVERAGE
ENTERED INTO PREPETITION AND PAY RELATED PREPETITION
OBLIGATIONS, AND (B) RENEW, SUPPLEMENT, MODIFY OR PURCHASE
INSURANCE AND SURETY COVERAGE, AND (II) GRANTING RELATED RELIEF
The above-captioned debtors and debtors in possession (collectively, the “Debtors” and,
each, a “Debtor”) state as follows in support of this motion:2
Relief Requested
1.
The Debtors seek entry of interim and final orders, substantially in the forms
attached hereto as Exhibit A and Exhibit B (respectively, the “Interim Order” and the “Final
Order”) (a) authorizing, but not directing, the Debtors to (i) maintain coverage under the Insurance
Policies and the Surety Bonds (each as defined herein) and pay any related obligations and
(ii) renew, supplement, modify or purchase insurance and surety coverage in the ordinary course

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’
proposed
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
A detailed description of the Debtors and their business, including the facts and circumstances giving rise to the
Debtors’ chapter 11 cases, is set forth in the Declaration of John Bibb, Group Chief Executive Officer of Vyaire
Medical, Inc., in Support of Chapter 11 Filing and First Day Motions (the “First Day Declaration”), filed
contemporaneously herewith and incorporated by reference herein. Capitalized terms used but not otherwise
defined herein shall have the meanings ascribed to them in the First Day Declaration.
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 1 of 29

2
of business, and (b) granting related relief. In addition, the Debtors request that the Court schedule
a final hearing approximately 21 days from the Petition Date.
Jurisdiction and Venue
2.
The United States District Court for the District of Delaware has jurisdiction over
this matter pursuant to 28 U.S.C. §1334, which was referred to the United States Bankruptcy Court
for the District of Delaware (the “Court”) under 28 U.S.C. § 157 and the Amended Standing Order
of Reference from the United States District Court for the District of Delaware, dated February 29,
2012. The Debtors confirm their consent, pursuant to rule 9013-1(f) of the Local Rules of
Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of
Delaware (the “Local Rules”), 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.
3.
Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.
4.
The statutory bases for the relief requested herein are sections 105(a) and 363(b) of
title 11 of the United States Code, 11 U.S.C. §§ 101–1532 (the “Bankruptcy Code”), rules 2002,
6003, and 6004 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and
Local Rules 2002-1 and 9013-1.
Background
5.
Vyaire Medical, Inc., together with its direct and indirect subsidiaries (collectively,
“Vyaire” or the “Company”), is a global company focused on developing products and providing
related services for the diagnosis, treatment, and monitoring of various cardiology, pulmonology,
and respiratory health conditions. With a 70-year history of pioneering breathing technology, the
integrated solutions offered by the Company help enable, enhance, and extend
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 2 of 29

3
lives. Headquartered in Mettawa, Illinois, Vyaire operates approximately 27 offices and
manufacturing facilities, and employs approximately 950 individuals around the world. The
Company has a global reach, and Vyaire products are available in more than 100 countries. Its
customers are the hospitals, health centers, and private practice facilities delivering life-enhancing
products and services to patients every day.
6.
On June 9, 2024 (the “Petition Date”), Vyaire Medical, Inc. and certain of its
subsidiaries filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code. The
Debtors are operating their business and managing their property as debtors in possession pursuant
to sections 1107(a) and 1108 of the Bankruptcy Code. Concurrently with the filing of this motion,
the Debtors filed a motion requesting procedural consolidation and joint administration of these
chapter 11 cases pursuant to Bankruptcy Rule 1015(b). No request for the appointment of a trustee
or examiner has been made in these chapter 11 cases, and no official committees have been
appointed or designated.
The Insurance Policies, the Surety Bonds, and Related Payment Obligations
7.
In the ordinary course of business, the Debtors maintain approximately
40 insurance policies listed on Exhibit C attached hereto (collectively, the “Insurance Policies”)3
that are administered by various third-party insurance carriers (collectively, the “Insurance
Carriers”), as well as four surety bonds listed on Exhibit D attached hereto (collectively,
the “Surety Bonds”) issued by Hartford Fire Insurance Company and Hartford Insurance Company

3
The descriptions of the Insurance Policies set forth in this motion constitute a summary only. The actual terms
of the Insurance Policies and related agreements will govern in the event of any inconsistency with the
descriptions in this motion. Although Exhibit C is intended to be comprehensive, the Debtors may have
inadvertently omitted Insurance Policies from Exhibit C. The Debtors request authority, but not direction, to
honor existing Insurance Policies and renew Insurance Policies, as applicable, regardless of whether the Debtors
inadvertently failed to include a particular Insurance Policy on Exhibit C, and any such omitted Insurance Policy
is hereby included in the defined term “Insurance Policies” as used herein and in the Interim Order and Final
Order.
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 3 of 29

4
of the Midwest (collectively, the “Sureties”). The Insurance Policies provide the Debtors and
non-Debtor entities4 coverage for, among other things, the Debtors’ product liability, marine cargo
liability, property, general liability, employment benefits liability, employment practices liability,
earthquake, flood, automobile liability, cyber liability, workers’ compensation,5 umbrella
coverage, pollution legal liability, crime, kidnap & ransom, business travel accident, and directors’
and officers’ liability. The Surety Bonds are issued in favor of various federal, state, and industry
regulatory agencies to guarantee certain obligations related to various state licenses, permits, and
custom duties. The Debtors are required to maintain the Surety Bonds under certain state and
federal law in order to lawfully conduct their business and operations in the applicable
jurisdictions. As such, failing to provide, maintain or timely replace the Surety Bonds may prevent
the Debtors from lawfully continuing to conduct their business in the applicable state.
8.
The Insurance Policies and the Surety Bonds are essential to the ongoing operation
of the Debtors’ business. The Insurance Policies generally are one year in length, with no
affirmative obligation to renew upon expiration. The total annual premiums for the Insurance
Policies were approximately $5.1 million in the aggregate for the 2023-24 term, not including

4
In some instances, the Debtors are insured under an insurance policy that also provides coverage to a certain
non-Debtor too. For example, certain Insurance Policies related to director and officer liability also provide
coverage to non-Debtor subsidiaries. Intercompany transactions are described, and relief is requested, in the
Motion of Debtors for Entry of an Order (I) Authorizing the Debtors to (A) Continue to Operate the Cash
Management System (B) Honor Certain Prepetition Obligations Related Thereto, (C) Maintain Existing Business
Forms, (D) Continue to Perform Intercompany Transactions, and (II) Granting Related Relief, filed
contemporaneously herewith.
5
For the avoidance of doubt, the Debtors’ workers’ compensation policies are reflected on Exhibit C and
throughout this motion to the extent the relief requested in the Motion of Debtors for Entry of Interim and Final
Orders (I) Authorizing the Debtors To (A) Pay Prepetition Wages, Salaries, Other Compensation, and
Reimbursable Expenses and (B) Continue Employee Benefits Programs, and (II) Granting Related Relief
(the “Wages Motion”), filed contemporaneously herewith, is not coextensive with the relief sought herein. This
motion asks the Court to authorize, but not direct, the Debtors’ payment of any prepetition obligations on account
of the related Insurance Policies.
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 4 of 29

5
applicable deductibles or self-insured retentions.6 The total annual premiums for the Surety Bonds
are approximately $7,000 in the aggregate. The premiums for the Insurance Policies are financed
pursuant to certain payment arrangements with IPFS Corporation (the “Premium Financing
Arrangements”). The Premium Financing Arrangements allow the Debtors to spread their
insurance premium payment over the term of the policy rather than paying the entire payment up
front. As of the Petition Date, approximately $1.7 million remains outstanding under the Premium
Financing Arrangements, with no amount in arears. The Debtors will pay the remaining amounts
due under the Premium Financing Arrangements in monthly installments of approximately
$440,000. The premiums associated with the Debtors’ workers’ compensation policy are subject
to adjustments at the end of the term. The Debtors seek authority, but not direction, to pay any
prepetition obligations owing on account of the Insurance Policies and the Surety Bonds in the
ordinary course of business as they become due to ensure uninterrupted coverage thereunder.
9.
The Debtors’ ability to maintain the Insurance Policies and the Surety Bonds, to
renew, supplement, and modify the same as needed, and to enter into new insurance policies and
surety bonds as needed in the ordinary course of business, is essential to preserving the value of
the Debtors’ estates. Moreover, in many instances, insurance or surety coverage is required by
statutes, rules, regulations, and contracts that govern the Debtors’ commercial activities, including

6
Some of the Insurance Policies require the Debtors to pay a per-incident deductible (collectively, “Deductibles”).
Generally, if a claim is made against such Insurance Policies, the applicable Insurance Carrier will administer the
claim and make payments in connection therewith in accordance with the terms of such policy, and the Insurance
Carrier will have a claim against the Debtors in the amount of the applicable Deductible. Alternatively, certain
of the Insurance Policies use self-insured retentions on a per˗claim basis (collectively, the “SIRs”) instead of
Deductibles. If a claim is made under such Insurance Policies, the Debtors must make payments in the first
instance (whether related to defense costs or on account of the underlying liability) up to the amount of the SIR
and, once the Debtors have made payments to satisfy such amount, the carrier becomes obligated to cover
remaining costs in accordance with the terms of such policy. Out of an abundance of caution, the Debtors seek
authority, but not direction, to pay all prepetition amounts that may be due and owing on account of the
Deductibles and to continue honoring all payment obligations under the Deductibles in the ordinary course of
business to ensure uninterrupted coverage thereunder.
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 5 of 29

6
the requirements of the United States Trustee for the District of Delaware (the “U.S. Trustee”) that
a debtor maintain adequate coverage given the circumstances of its chapter 11 case. Accordingly,
the Debtors seek authorization, but not direction, to maintain the Insurance Policies and the Surety
Bonds, to pay related prepetition obligations, to renew, supplement or modify the Insurance
Policies and the Surety Bonds as needed, and to enter into new insurance policies and surety bonds
in the ordinary course of business.
The Debtors’ Insurance and Surety Brokers
10.
The Debtors obtain most of their Insurance Policies and all of their Surety Bonds
through Marsh USA Inc. (the “Broker”).7 The Broker, among other things: (a) assists the Debtors
in obtaining comprehensive insurance and surety coverage for their operations in a cost effective
manner; (b) manages renewal data; and (c) provides ongoing support throughout the applicable
policy periods for the Insurance Policies and the Surety Bonds. In exchange for these services, the
Debtors pay broker commissions and brokerage fees (collectively, the “Broker Fees”), usually at the
same time the Debtors pay their premiums.
11.
As of the Petition Date, the Debtors do not believe that they owe any amounts to
the Broker on account of Broker Fees. Out of an abundance of caution, however, the Debtors seek
authority, but not direction, to pay any prepetition obligations owed to the Broker and to continue
to pay the Broker for services rendered in the ordinary course of business to ensure uninterrupted
coverage under their Insurance Policies and Surety Bonds.

7
For the avoidance of doubt, Marsh USA LLC, is the broker for the Debtors’ workers’ compensation policy, for
which relief is requested in the Wages Motion.
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 6 of 29

7
Basis for Relief
12.
The relief requested herein is essential to the Debtors’ continuation of
ordinary-course operations and, as such, is warranted under sections 105(a) and 363(b) of the
Bankruptcy Code. Courts have recognized that it is appropriate to authorize the payment of
prepetition obligations where necessary to protect and preserve the estate, including an operating
business’s going-concern value. See, e.g., In re Just for Feet, Inc., 242 B.R. 821, 825–26 (D. Del.
1999); see also In re CoServ, L.L.C., 273 B.R. 487, 497 (Bankr. N.D. Tex. 2002); In re Ionosphere
Clubs, Inc., 98 B.R. 174, 175–76 (Bankr. S.D.N.Y. 1989); Armstrong World Indus., Inc. v. James
A. Phillips, Inc., 29 B.R. 391, 398 (S.D.N.Y. 1983). In so doing, these courts acknowledge that
several legal theories rooted in sections 105(a) and 363(b) of the Bankruptcy Code support the
payment of prepetition claims.
13.
Section 363(b) of the Bankruptcy Code permits a bankruptcy court, after notice and
a hearing, to authorize a debtor to “use, sell, or lease, other than in the ordinary course of business,
property of the estate.” 11 U.S.C. § 363(b)(1). “In determining whether to authorize the use, sale
or lease of property of the estate under this section, courts require the debtor to show that a sound
business purpose justifies such actions.” Dai-Ichi Kangyo Bank, Ltd. v. Montgomery Ward
Holding Corp. (In re Montgomery Ward Holding Corp.), 242 B.R. 147, 153 (D. Del. 1999)
(collecting cases); see also Armstrong World, 29 B.R. at 397 (relying on section 363 to allow
contractor to pay prepetition claims of suppliers who were potential lien claimants because the
payments were necessary for general contractors to release funds owed to debtors); Ionosphere
Clubs, 98 B.R. at 175 (finding that a sound business justification existed to justify payment of
certain prepetition wages); In re Phx. Steel Corp., 82 B.R. 334, 335–36 (Bankr. D. Del. 1987)
(requiring the debtor to show a “good business reason” for a proposed transaction under
section 363(b)).
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 7 of 29

8
14.
Courts also authorize payment of prepetition claims in appropriate circumstances
based on section 105(a) of the Bankruptcy Code, which codifies a bankruptcy court’s inherent
equitable powers to “issue any order, process, or judgment that is necessary or appropriate to carry
out the provisions of this title.” 11 U.S.C. § 105(a). Under section 105(a) of the Bankruptcy Code,
courts may authorize pre-plan payments of prepetition obligations when essential to the continued
operation of a debtor’s business. See Just for Feet, 242 B.R. at 825–26 (“The Supreme Court, the
Third Circuit and the District of Delaware all recognize the court’s power to authorize payment of
pre-petition claims when such payment is necessary for the debtor's survival during chapter 11.”).
Specifically, a court may use its power under section 105(a) of the Bankruptcy Code to authorize
payment of prepetition obligations pursuant to the “necessity of payment” rule (also referred to as
the “doctrine of necessity”). See, e.g., Ionosphere Clubs, 98 B.R. at 176; In re Lehigh & New
England Ry Co., 657 F.2d 570, 581 (3d Cir. 1981) (stating that courts may authorize payment of
prepetition claims when there “is the possibility that the creditor will employ an immediate
economic sanction, failing such payment”); see also In re Columbia Gas Sys., Inc., 171 B.R. 189,
191–92 (Bankr. D. Del. 1994) (noting that, in the Third Circuit, debtors may pay prepetition claims
that are essential to the continued operation of the business). A bankruptcy court’s use of its
equitable powers to “authorize the payment of prepetition debt when such payment is needed to
facilitate the rehabilitation of the debtor is not a novel concept.” See Ionosphere Clubs, 98 B.R.
at 175–76 (citing Miltenberger v. Logansport, C. & S.W. Ry. Co., 106 U.S. 286 (1882)). Indeed,
at least one court has recognized that there are instances when a debtor’s fiduciary duty can “only
be fulfilled by the preplan satisfaction of a prepetition claim.” See CoServ, 273 B.R. at 497.
15.
The relief requested herein is necessary to allow the Debtors to maintain
appropriate insurance and surety coverage to maximize the value of their estates during these
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 8 of 29

9
chapter 11 cases. Section 1112(b) of the Bankruptcy Code provides that “failure to maintain
appropriate insurance that poses a risk to the estate or to the public” is “cause” for mandatory
conversion or dismissal of a chapter 11 case. 11 U.S.C. § 1112(b)(4)(C). In addition, failure to
maintain appropriate insurance coverage could, among other things, expose the Debtors to
significant economic risk and also violate applicable legal requirements, including the
U.S. Trustee’s Operating Guidelines for chapter 11 cases (the “U.S. Trustee Operating
Guidelines”). Given this backdrop, the Debtors believe it is essential to their estates, and consistent
with the Bankruptcy Code and the U.S. Trustee Operating Guidelines, that they maintain and
continue to make all payments required under their Insurance Policies and Surety Bonds and have
the authority to renew, supplement, modify, purchase or replace their Insurance Policies and Surety
Bonds as needed without further order of the Court.
16.
Courts in this district have granted relief similar to the relief requested herein under
sections 105(a) and 363(b) of the Bankruptcy Code. See, e.g., In re Appgate, Inc., No. 24-10956
(CTG) (Bankr. D. Del. May 28, 2024) (authorizing debtors on an interim basis to continue their
current insurance policies, pay related prepetition obligations, renew, supplement, modify or
purchase insurance and surety coverage); In re Express, Inc., No. 24-10831 (KBO) (Bankr. D. Del.
May 15, 2024) (same); In re MVK FarmCo LLC, et al., No. 23-11721 (LSS) (Bankr. D. Del.
Oct. 17, 2023); In re Yellow Corporation, No. 23-11069 (CTG) (Bankr. D. Del. Sept. 13, 2023)
(same); In re PGX Holdings, Inc., No. 23-10718 (CTG) (Bankr. D. Del. Jul. 21, 2023) (same);
In re Lannett Co., Inc., No. 23-10559 (KJS) (Bankr. D. Del. May 5, 2023) (same).
Processing of Checks and Electronic Fund Transfers Should Be Authorized
17.
The Debtors have sufficient funds to pay the amounts described in this motion in
the ordinary course of business by virtue of access to cash on hand and anticipated access to cash
collateral and debtor-in-possession financing. In addition, under the Debtors’ existing cash
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 9 of 29

10
management system, the Debtors can readily identify checks or wire transfer requests as relating
to any authorized payment in respect of the relief requested herein. Accordingly, the Debtors do
not believe that checks or wire transfer requests, other than those relating to authorized payments,
will be inadvertently honored. Therefore, the Debtors request authority, but not direction, to
authorize all applicable financial institutions, when requested by the Debtors, to receive, process,
honor, and pay any and all checks or wire transfer requests in respect of the relief requested in this
motion.
The Requirements of Bankruptcy Rule 6003(b) Are Satisfied
18.
Bankruptcy Rule 6003 empowers a court to grant certain relief within the first
twenty-one days after the petition date only “to the extent that relief is necessary to avoid
immediate and irreparable harm.” For the reasons discussed above, the Debtors believe an
immediate and orderly transition into chapter 11 is critical, and the failure to receive the requested
relief during the first twenty-one days of these chapter 11 cases could impact the Debtors’
operations at this important juncture. The requested relief is necessary for the Debtors to operate
their businesses in the ordinary course, preserve the ongoing value of their operations, and
maximize value of their estates for the benefit of all stakeholders. The Debtors have demonstrated
that the requested relief is “necessary to avoid immediate and irreparable harm,” as contemplated
by Bankruptcy Rule 6003, and the Court should grant the requested relief.
Reservation of Rights
19.
Nothing contained in this motion or any order granting the relief requested in this
motion, and no action taken by the Debtors pursuant to the relief requested or granted (including
any payment made in accordance with any such order), is intended as or shall be construed or
deemed to be: (a) an admission as to the amount of, basis for, priority or validity of any claim
against the Debtors under the Bankruptcy Code or other applicable nonbankruptcy law;
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 10 of 29

11
(b) a waiver of the Debtors’ or any other party in interest’s rights to dispute any claim on any
grounds; (c) a promise or requirement to pay any particular claim; (d) an implication, admission
or finding that any particular claim is an administrative expense claim, other priority claim or
otherwise of a type specified or defined in this motion or any order granting the relief requested
by this motion; (e) a request or authorization to assume, adopt or reject any agreement, contract,
or lease pursuant to section 365 of the Bankruptcy Code; (f) an admission as to the validity, priority
enforceability or perfection of any lien on, security interest in or other encumbrance on property
of the Debtors’ estates; or (g) a waiver or limitation of any claims, causes of action or other rights
of the Debtors or any other party in interest against any person or entity under the Bankruptcy
Code or any other applicable law. If the Court grants the relief sought herein, any payment made
pursuant to the Court’s order is not intended and should not be construed as an admission as to the
validity, priority or amount of any particular claim or a waiver of the Debtors’ rights to
subsequently dispute such claim.
Waiver of Bankruptcy Rule 6004(a) and 6004(h)
20.
To implement the foregoing successfully, the Debtors seek a waiver of the notice
requirements under Bankruptcy Rule 6004(a) and the 14-day stay of an order authorizing the use,
sale or lease of property under Bankruptcy Rule 6004(h).
Notice
21.
The Debtors will provide notice of this motion to: (a) the United States Trustee for
the District of Delaware; (b) the holders of the 30 largest unsecured claims against the Debtors
(on a consolidated basis); (c) the office of the attorney general for each of the states in which the
Debtors operate; (d) the United States Attorney’s Office for the District of Delaware;
(e) the Internal Revenue Service; (f) the United States Securities and Exchange Commission;
(g) counsel to the 1L Ad Hoc Group; (h) the agent of the DIP Facility and counsel thereto;
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 11 of 29

12
(i) the agent of the First Lien Credit Agreement and counsel thereto; (j) the Second Lien Credit
Agreement Agent and counsel thereto; (k) the agent of the First Lien Notes and counsel thereto;
(l) the Insurance Carriers; (m) the Sureties; (n) the Brokers; (o) IPFS Corporation; and (p) any
party that has requested notice pursuant to Bankruptcy Rule 2002. As this motion is seeking “first
day” relief, the Debtors will serve copies of this motion and any order entered in respect to this
motion as required by Local Rule 9013-1(m). The Debtors submit that, in light of the nature of
the relief requested, no other or further notice need be given.
[Remainder of page intentionally left blank]

Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 12 of 29

WHEREFORE, the Debtors request entry of the Interim Order and Final Order,
substantially in the forms attached hereto as Exhibit A and Exhibit B, (a) granting the relief
requested herein and (b) granting such other relief as the Court deems appropriate under the
circumstances.
Dated: June 10, 2024

Wilmington, Delaware

/s/ Patrick J. Reilley

COLE SCHOTZ P.C.

KIRKLAND & ELLIS LLP
Patrick J. Reilley, Esq. (DE Bar No. 4451)

KIRKLAND & ELLIS INTERNATIONAL LLP
500 Delaware Avenue, Suite 1410

Joshua A. Sussberg, P.C. (pro hac vice admission pending)
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. (pro hac vice admission pending)

Warren A. Usatine, Esq (pro hac vice admission pending)
Spencer A. Winters, P.C. (pro hac vice admission pending)
Court Plaza North, 25 Main Street

Yusuf U. Salloum (pro hac vice admission pending)
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 9 Filed 06/10/24 Page 13 of 29

Exhibit A
Proposed Interim Order
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 14 of 29

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 (___)

)

Debtors.
)
(Joint Administration Requested)

)
Re: Docket No. __

INTERIM ORDER (I) AUTHORIZING THE DEBTORS
TO (A) MAINTAIN INSURANCE AND SURETY COVERAGE
ENTERED INTO PREPETITION AND PAY RELATED PREPETITION
OBLIGATIONS, AND (B) RENEW, SUPPLEMENT, MODIFY OR PURCHASE
INSURANCE AND SURETY COVERAGE, AND (II) GRANTING RELATED RELIEF
Upon the motion (the “Motion”)2 of the above-captioned debtors and debtors in possession
(collectively, the “Debtors”) for entry of an interim order (this “Interim Order”), (a) authorizing,
but not directing, the Debtors to (i) maintain coverage under the Insurance Policies and the Surety
Bonds and pay related obligations and (ii) renew, supplement, modify or purchase insurance and
surety coverage in the ordinary course, (b) scheduling a final hearing to consider approval of the
Motion on a final basis, and (c) granting related relief, all as more fully set forth in the Motion;
and upon the First Day Declaration; and the United States District Court for the District of
Delaware has jurisdiction over this matter pursuant to 28 U.S.C. § 1334, which was referred to the
Court under 28 U.S.C. § 157 and the Amended Standing Order of Reference from the United States
District Court for the District of Delaware, dated February 29, 2012; and this Court having found

2
that this is a core proceeding pursuant to 28 U.S.C. § 157(b)(2); and this Court having found that
venue of this proceeding and the Motion in this district is proper pursuant to 28 U.S.C. §§ 1408
and 1409; and this Court having found that the relief requested in the Motion is in the best interests
of the Debtors’ estates, their creditors, and other parties in interest; and this Court having found
that the Debtors’ notice of the Motion and opportunity for a hearing on the Motion were
appropriate under the circumstances and no other notice need be provided; and this Court having
reviewed the Motion and having heard the statements in support of the relief requested therein at
a hearing before this Court (the “Hearing”); and this Court having determined that the legal and
factual bases set forth in the Motion and at the Hearing establish just cause for the relief granted
herein; and upon all of the proceedings had before this Court; and after due deliberation and
sufficient cause appearing therefor, it is HEREBY ORDERED THAT:
1.
The Motion is granted on an interim basis as set forth herein.
2.
The final hearing (the “Final Hearing”) on the Motion shall be held on _________,
2024, at__:__ _.m., prevailing Eastern Time. Any objections or responses to entry of a final order
on the Motion shall be filed on or before 4:00 p.m., prevailing Eastern Time, on _________, 2024
and shall be served on: (a) the Debtors, 26125 North Riverwoods Boulevard, Mettawa, Illinois,
USA 60045, Attn.: Charles Braley (cbraley@alixpartners.com); (b) proposed co-counsel to the
Debtors (i) Kirkland & Ellis LLP, 601 Lexington Avenue, New York, New York 10022,
Attn.: Joshua
A.
Sussberg,
P.C.
(joshua.sussberg@kirkland.com),
Chris
Ceresa
(chris.ceresa@kirkland.com), and Tiffani Chanroo (tiffani.chanroo@kirkland.com) (ii) Kirkland
& Ellis LLP, 333 West Wolf Point Plaza, Chicago, Illinois, 60654, Attn.: Spencer A. Winters
(spencer.winters@kirkland.com) and Yusuf U. Salloum (yusuf.salloum@kirkland.com), (iii) Cole
Schotz
P.C.,
500
Delaware
Avenue,
Suite
1410,
Wilmington,
Delaware
19801,
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 16 of 29

3
Attn.:
Patrick
J.
Reilley,
Esq.
(preilley@coleschotz.com),
Stacy
L.
Newman
(snewman@coleschotz.com), Michael E. Fitzpatrick, Esq. (mfitzpatrick@coleschotz.com),
and Jack M. Dougherty, Esq. (jdougherty@coleschotz.com), and (iv) Cole Schotz P.C., Court
Plaza North, 25 Main Street, Hackensack, New Jersey 07601, Attn.: Michael D. Sirota, Esq.
(msirota@coleschotz.com) and Warren A. Usatine, Esq. (wusatine@coleschotz.com);
(c) counsel to the 1L Ad Hoc Group, (i) Gibson, Dunn & Crutcher LLP, 200 Park Avenue,
New York, NY 10166-0193, Attn.: Scott J. Greenberg (SGreenberg@gibsondunn.com),
Jason
Zachary
Goldstein
(JGoldstein@gibsondunn.com),
Joshua
Brody
(JBrody@gibsondunn.com), and Kevin Liang (KLiang@gibsondunn.com) and (ii) Pachulski
Stang Ziehl & Jones LLP, 919 North Market Street, 17th Floor, Wilmington, DE 19801,
Attn.: Laura Davis Jones (ljones@pszjlaw.com); (d) the United States Trustee, 844 King Street,
Suite 2207, Lockbox 35, Wilmington, Delaware 19801, Attn.: Benjamin A. Hackman
(Benjamin.A.Hackman@usdoj.gov); and (e) any statutory committee appointed in these
chapter 11 cases.
3.
The Debtors shall serve a copy of the Motion and this Interim Order on each
Insurance Carrier and the Surety listed in Exhibit C and Exhibit D to the Motion within two
business days after entry of this Interim Order.
4.
The Debtors are authorized, but not directed, to: (a) continue and maintain the
Insurance Policies3 and the Surety Bonds and pay any related prepetition or postpetition amounts
or obligations in the ordinary course of business, including any amounts or obligations that may
be owed to the Broker; and (b) renew, amend, supplement, extend or purchase insurance policies

3
For the avoidance of doubt, the term Insurance Policies shall include all insurance policies issued or providing
coverage at any time to the Debtors or their predecessors and any agreements related thereto, whether or not listed
on Exhibit C attached to the Motion.
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 17 of 29

4
and surety bonds, in each case, to the extent that the Debtors determine that such action is in the
best interest of their estates, provided, that such payments shall not exceed $900,000 in the
aggregate pending entry of a final order.
5.
The banks and financial institutions on which checks were drawn or electronic
payment requests made in payment of the prepetition obligations approved herein are authorized
to receive, process, honor, and pay all such checks and electronic payment requests when presented
for payment, and all such banks and financial institutions are authorized to rely on the Debtors’
designation of any particular check or electronic payment request as approved by this Interim
Order.
6.
Nothing contained in the Motion or this Interim Order, and no action taken pursuant
to the relief requested or granted (including any payment made in accordance with this Interim
Order), is intended as or shall be construed or deemed to be: (a) an admission as to the amount,
validity or priority of or basis for any claim against the Debtors under the Bankruptcy Code or
other applicable nonbankruptcy law; (b) a waiver of the Debtors’ or any other party in interest’s
right to dispute any claim on any grounds; (c) a promise or requirement to pay any particular claim;
(d) an implication, admission or finding that any particular claim is an administrative expense
claim, other priority claim or otherwise of a type specified or defined in the Motion or this Interim
Order; (e) a request or authorization to assume, adopt or reject any agreement, contract or lease
pursuant to section 365 of the Bankruptcy Code; (f) an admission as to the validity, priority,
enforceability or perfection of any lien on, security interest in or other encumbrance on property
of the Debtors’ estates; or (g) a waiver or limitation of any claims, causes of action or other rights
of the Debtors or any other party in interest against any person or entity under the Bankruptcy
Code or any other applicable law.
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 18 of 29

5
7.
The Debtors are authorized, but not directed, to issue postpetition checks or to effect
postpetition fund transfer requests, in replacement of any checks or fund transfer requests that are
dishonored as a consequence of these chapter 11 cases with respect to prepetition amounts owed
in connection with the relief granted herein.
8.
Nothing in the Motion or this Interim Order waives or modifies the requirements
of the Restructuring Support Agreement, including, without limitation, the consent and
consultation rights contained therein.
9.
Notwithstanding anything to the contrary contained in the Motion or this Interim
Order herein, any payment to be made hereunder, and any authorization contained herein, shall be
subject to any interim and final orders, as applicable, approving the use of such cash collateral
and/or the Debtors’ entry into any postpetition financing facilities or credit agreement, and any
budgets in connection therewith governing any such postpetition financing and/or use of cash
collateral (each such order, a “DIP Order”). To the extent there is any inconsistency between the
terms of the DIP Order and any action taken or proposed to be taken hereunder, the terms of the
DIP Order shall control.
10.
The Debtors have demonstrated that the requested relief is “necessary to avoid
immediate and irreparable harm,” as contemplated by Bankruptcy Rule 6003.
11.
Nothing in this Interim Order authorizes the Debtors to accelerate any payments
not otherwise due prior to the date of the Final Hearing.
12.
The contents of the Motion satisfy the requirements of Bankruptcy Rule 6003(b).
13.
Notice of the Motion as provided therein shall be deemed good and sufficient notice
of such Motion, and the requirements of Bankruptcy Rule 6004(a) and the Local Rules are satisfied
by such notice.
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 19 of 29

6
14.
Notwithstanding Bankruptcy Rule 6004(h), the terms and conditions of this Interim
Order are immediately effective and enforceable upon its entry.
15.
The Debtors are authorized, but not directed, to take all actions necessary to
effectuate the relief granted in this Interim Order in accordance with the Motion.
16.
This Court retains jurisdiction with respect to all matters arising from or related to
the implementation, interpretation, and enforcement of this Interim Order.
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 20 of 29

Exhibit B
Proposed Final Order
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 21 of 29

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 (___)

)

Debtors.
)
(Joint Administration Requested)

)
Re: Docket No. __
FINAL ORDER (I) AUTHORIZING THE DEBTORS
TO (A) MAINTAIN INSURANCE AND SURETY COVERAGE
ENTERED INTO PREPETITION AND PAY RELATED PREPETITION
OBLIGATIONS, AND (B) RENEW, SUPPLEMENT, MODIFY OR PURCHASE
INSURANCE AND SURETY COVERAGE, AND (II) GRANTING RELATED RELIEF
Upon the motion (the “Motion”)2 of the above-captioned debtors and debtors in possession
(collectively, the “Debtors”) for entry of a final order (this “Final Order”), (a) authorizing, but not
directing, the Debtors to (i) maintain coverage under the Insurance Policies and the Surety Bonds
and pay related obligations and (ii) renew, supplement, modify or purchase insurance and surety
coverage in the ordinary course and (b) granting related relief; all as more fully set forth in the
Motion; and upon the First Day Declaration; and the United States District Court for the District
of Delaware has jurisdiction over this matter pursuant to 28 U.S.C. § 1334, which was referred to
the Court under 28 U.S.C. § 157 and the Amended Standing Order of Reference from the United
States District Court for the District of Delaware, dated February 29, 2012; and this Court having
found that this is a core proceeding pursuant to 28 U.S.C. § 157(b)(2); and this Court having found

2
that this Court may enter a final order consistent with Article III of the United States Constitution;
and this Court having found that venue of this proceeding and the Motion in this district is proper
pursuant to 28 U.S.C. §§ 1408 and 1409; and this Court having found that the relief requested in
the Motion is in the best interests of the Debtors’ estates, their creditors, and other parties in
interest; and this Court having found that the Debtors’ notice of the Motion and opportunity for a
hearing on the Motion were appropriate and no other notice need be provided; and this Court
having reviewed the Motion and having heard the statements in support of the relief requested
therein at a hearing before this Court (the “Hearing”); and this Court having determined that the
legal and factual bases set forth in the Motion and at the Hearing establish just cause for the relief
granted herein; and upon all of the proceedings had before this Court; and after due deliberation
and sufficient cause appearing therefor, it is HEREBY ORDERED THAT:
1.
The Motion is granted on a final basis as set forth herein.
2.
The Debtors shall serve a copy of the Motion and this Final Order on each
Insurance Carrier and Surety listed in Exhibit C and Exhibit D attached to the Motion within
two (2) business days after entry of this Final Order.
3.
The Debtors are authorized, but not directed, to: (a) continue and maintain the
Insurance Policies3 and the Surety Bonds and pay any related prepetition or postpetition amounts
or obligations in the ordinary course of business, including any amounts or obligations that may
be owed to the Broker; and (b) renew, amend, supplement, extend or purchase Insurance Policies
and Surety Bonds, in each case, to the extent that the Debtors determine that such action is in the
best interest of their estates.

3
4.
The banks and financial institutions on which checks were drawn or electronic
payment requests made in payment of the prepetition obligations approved herein are authorized
to receive, process, honor, and pay all such checks and electronic payment requests when presented
for payment, and all such banks and financial institutions are authorized to rely on the Debtors’
designation of any particular check or electronic payment request as approved by this Final Order.
5.
Nothing contained in the Motion or this Final Order, and no action taken pursuant
to the relief requested or granted (including any payment made in accordance with this Final
Order), is intended as or shall be construed or deemed to be: (a) an admission as to the amount,
validity or priority of or basis for any claim against the Debtors under the Bankruptcy Code or
other applicable nonbankruptcy law; (b) a waiver of the Debtors’ or any other party in interest’s
right to dispute any claim on any grounds; (c) a promise or requirement to pay any particular claim;
(d) an implication, admission or finding that any particular claim is an administrative expense
claim, other priority claim or otherwise of a type specified or defined in the Motion or this Final
Order; (e) a request or authorization to assume, adopt or reject any agreement, contract or lease
pursuant to section 365 of the Bankruptcy Code; (f) an admission as to the validity, priority,
enforceability or perfection of any lien on, security interest in or other encumbrance on property
of the Debtors’ estates; or (g) a waiver or limitation of any claims, causes of action or other rights
of the Debtors or any other party in interest against any person or entity under the Bankruptcy
Code or any other applicable law.
6.
The Debtors are authorized, but not directed, to issue postpetition checks or to effect
postpetition fund transfer requests, in replacement of any checks or fund transfer requests that are
dishonored as a consequence of these chapter 11 cases with respect to prepetition amounts owed
in connection with the relief granted herein.
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 24 of 29

4
7.
Nothing in the Motion or this Interim Order waives or modifies the requirements
of the Restructuring Support Agreement, including, without limitation, the consent and
consultation rights contained therein.
8.
Notwithstanding anything to the contrary contained in the Motion or this Interim
Order herein, any payment to be made hereunder, and any authorization contained herein, shall be
subject to any interim and final orders, as applicable, approving the use of such cash collateral
and/or the Debtors’ entry into any postpetition financing facilities or credit agreement, and any
budgets in connection therewith governing any such postpetition financing and/or use of cash
collateral (each such order, a “DIP Order”). To the extent there is any inconsistency between the
terms of the DIP Order and any action taken or proposed to be taken hereunder, the terms of the
DIP Order shall control.
9.
Notice of the Motion as provided therein shall be deemed good and sufficient notice
of such Motion and the requirements of Bankruptcy Rule 6004(a) and the Local Rules are satisfied
by such notice.
10.
Notwithstanding Bankruptcy Rule 6004(h), the terms and conditions of this Final
Order are immediately effective and enforceable upon its entry.
11.
The Debtors are authorized, but not directed, to take all actions necessary to
effectuate the relief granted in this Final Order in accordance with the Motion.
12.
This Court retains jurisdiction with respect to all matters arising from or related to
the implementation, interpretation, and enforcement of this Final Order.
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 25 of 29

Exhibit C
Insurance Policies
Legal Entity
Insurance Carrier
Policy Type
Policy Number
Policy
Term
Approximate
Annual
Premium
Vyaire Holding
Company
Federal Insurance
Company
General Liability
3606-61-89
Annual
$10,155
Vyaire Holding
Company
Federal Insurance
Company
US Auto Liability
(24) 7363-96-04
Annual
$119,974
Vyaire Holding
Company
Chubb National
Insurance Company
Workers’
Compensation
(25) 7183-97-95
Annual
$84,850
Vyaire Holding
Company
Federal Insurance
Company
Commercial
Umbrella
5672-07-51
Annual
$53,785
Vyaire Holding
Company
ACE American
Insurance Company
Foreign Auto
PHFD38688571 001
Annual
$975
Vyaire Holding
Company
ACE American
Insurance Company
Foreign General
Liability
PHFD38688571 001
Annual
$25,050
Vyaire Holding
Company
ACE American
Insurance Company
Foreign Voluntary
Workers’
Compensation
PHFD38688571 001
Annual
$11,848
Vyaire Holding
Company
LifeScience Risk
Products Liability
LSR-PCO-00539-24
Annual
$400,000
Vyaire Holding
Company
Illinois Union
Insurance Company
Products Liability
XSP G47393942 002
Annual
$190,000
Vyaire Holding
Company
Euclid Life Science
Specialty, LLC
Products Liability
LSS2000275
Annual
$100,000
Vyaire Holding
Company
ProAssurance
Specialty Insurance
Company
Products Liability
EX24IL380003
Annual
$72,500
Vyaire Holding
Company
Ironshore Specialty
Insurance Company
Products Liability
HC7TAB7TUL004
Annual
$70,000
Vyaire Medical
Products Ltd
HDI Global SE – UK
Foreign Products
Liability
110-01164144-14072
Annual
$418,526
Vyaire Holding
Company
Beazley Group
Cyber Liability
W1EFF2220701
Annual
$285,126
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 26 of 29

Legal Entity
Insurance Carrier
Policy Type
Policy Number
Policy
Term
Approximate
Annual
Premium
Vyaire Holding
Company
Indian Harbor
Insurance Company
Cyber Liability
MTE904194703
Annual
$114,050
Vyaire Holding
Company
National Union Fire
Insurance Company
of Pittsburgh, PA
Crime
1-544-18-54
Annual
$22,516
Vyaire Holding
Company
Great American
Insurance Company
Crime Excess
XSC E776448 02 00
Annual
$15,000
Vyaire Holding
Company
Berkshire Hathaway
Specialty Insurance
Director & Officer
Side A Liability
47-EMC-312437-04
Annual
$200,000
Vyaire Holding
Company
Illinois National
Insurance Co.
Director & Officer
Side A Liability
01-545-03-57
Annual
$126,000
Vyaire Holding
Company
Twin City Fire
Insurance Co.
Director & Officer
Side A Liability
83 PE 0401876-23
Annual
$74,643
Vyaire Holding
Company
Axis Insurance
Company
Director & Officer
Side A Liability
P-001-000712001-03
Annual
$27,621
Vyaire Holding
Company.
ACE American
Insurance Company
Director & Officer
Side A Liability
G71089022 003
Annual
$31,880
Vyaire Holding
Company
Old Republic
Professional
Liability, Inc.
Director & Officer
Side A Liability
ORPRO 13 101883
Annual
$25,500
Vyaire Holding
Company
Midvale Indemnity
Company
Director & Officer
Side A Liability
ACL-144453387-02
Annual
$23,910
Vyaire Holding
Company
Federal Insurance
Company
Fiduciary Liability
J06349456
Annual
$10,335
Vyaire Holding
Company
Federal Insurance
Company
Employment
Practices Liability
J06349456
Annual
$46,471
Vyaire Holding
Company
Illinois National
Insurance Co.
Fiduciary Liability
01-545-03-53
Annual
$38,060
Vyaire Holding
Company
Great American
Insurance Co.
Special Risk
SCI273611442
Annual
$10,427
Vyaire Holding
Company
Allied World
Assurance Company
(U.S.) Inc.
Pollution Liability
0310-3558
Annual
$65,148
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 27 of 29

Legal Entity
Insurance Carrier
Policy Type
Policy Number
Policy
Term
Approximate
Annual
Premium
Vyaire Holding
Company
Lloyd’s Syndicate
1036 COF
Marine Cargo
Liability
B0509MARCW2351091
Annual
$330,000
Vyaire Holding
Company
Lloyd’s Syndicate
No.4472 LIB.
Marine Cargo
Liability
B0509MARCW2351092
Annual
$103,125
Vyaire Holding
Company
Federal Insurance
Company
Global Property
3606-61-72 DTO
Annual
$884,197
Vyaire Holding
Company
Starr Surplus Lines
Insurance Company
Global Property
23SSLDOND316061
Annual
$230,000
Vyaire Holding
Company
Princeton Excess and
Surplus Lines
Insurance Company
Global Property
78-A3-XP-0001068-00
Annual
$140,000
Vyaire Holding
Company
Mt. Hawley
Insurance Company
Global Property
MPC0606018
Annual
$50,000
Vyaire Holding
Company
Endurance American
Specialty Insurance
Global Property
ARP30048538600
Annual
$120,000
Vyaire Holding
Company
Lloyd’s of London
Global Property
B0509BOWPN2352774
B0509BOWPN2352775
B0509BOWPN2352776
B0509BOWPN2352777
Annual
$117,043
Vyaire Holding
Company
Lloyd’s of London
Global Property
B0509BOWPN2352776
Annual
$106,667
Vyaire Holding
Company
Ascot Specialty
Insurance Company
Property DIC
UB211270B00463
Annual
$140,961
Vyaire Holding
Company
Princeton Excess and
Surplus Lines
Insurance Company
Property DIC
B2A3IM0003894-00
Annual
$281,965
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 28 of 29

Exhibit D
Surety Bonds1
Principal
Bond No.
Obligee
Nature of Bond
Expiration
Date
Bond
Amount
Vyaire Medical,
Inc. and Vyaire
Medical 211,
Inc.
20BSBAA2688
California State Board
of Pharmacy
Pharmaceutical
Bond
04/30/2025
$100,000
Vyaire Medical,
Inc. and Vyaire
Medical 211,
Inc.
20BSBIL8800
Nevada State Board of
Pharmacy
Pharmaceutical
Bond
10/21/2024
$100,000
Vyaire Medical,
Inc.
20BSBAA2687
Maryland Board of
Pharmacy
Pharmaceutical
Bond
04/30/2025
$100,000
Vyaire Medical,
Inc.
22C000T8M
Bureau of Customs and
Border Protection
Custom Duty
06/07/2025
$400,000

1
The Surety for the Custom Duty Surety Bond is Hartford Insurance Company of the Midwest. The Surety for all
other Surety Bonds herein is Hartford Fire Insurance Company.
Case 24-11217-BLS Doc 9 Filed 06/10/24 Page 29 of 29

File and source

File: gov.uscourts.deb.193283.9.0.pdf
Size: 738,389 bytes
SHA-256: c214de49d3dbfe398b98adc7a141999d459983fbf08f1db4515049aa3391a3db
Our copy: gov.uscourts.deb.193283.9.0.pdf
Original: PACER (login required)

Motion of Debtors for Entry of Interim — In re Vyaire Medical, Inc., et al., Case No. 24-11217 (Bankr. D. Del.) (joint administration requested) (2024-06-10, 1)

Full text

File and source

Related records