Certification of Counsel — Procedures for Interim Compensation and Reimbursement of Expenses for Professionals — Vyaire Medical

Summary

In Case No. 24-11217 (BLS), the Debtors' proposed counsel certifies that the Debtors' motion for an order establishing procedures for interim compensation and reimbursement of expenses for professionals [Docket No. 118] was filed on June 25, 2024. The certification states that objections were due by July 2, 2024, at 4:00 p.m. (prevailing Eastern Time), except for the Official Committee of Unsecured Creditors, whose deadline was extended to July 5, 2024. It states that the Debtors revised the proposed order to address informal comments from counsel to the Committee, attaches the revised proposed order as Exhibit 1 and a blackline as Exhibit 2, and asks the Court to enter the revised order. It is dated July 3, 2024 and signed /s/ Patrick J. Reilley.

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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. 118
CERTIFICATION OF COUNSEL REGARDING
MOTION OF DEBTORS FOR ENTRY OF AN ORDER (I) ESTABLISHING
PROCEDURES FOR INTERIM COMPENSATION AND REIMBURSEMENT
OF EXPENSES FOR PROFESSIONALS AND (II) GRANTING RELATED RELIEF
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 as follows:
1.
On June 25, 2024, the Motion of Debtors for Entry of an Order (I) Establishing
Procedures for Interim Compensation and Reimbursement of Expenses for Professionals and
(II) Granting Related Relief [Docket No. 118] (the “Motion”) was filed with the United States
Bankruptcy Court for the District of Delaware (the “Court”).  Attached thereto as Exhibit A was a
proposed form of order granting the relief requested in the Motion (the “Proposed Order”).
2.
Pursuant to the Notice of Motion of Debtors for Entry of an Order (I) Establishing
Procedures for Interim Compensation and Reimbursement of Expenses for Professionals and (II)
Granting Related Relief, objections or responses to the Motion and entry of the Proposed Order
were to be filed and served on the undersigned proposed counsel by July 2, 2024, at 4:00 p.m.
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 139    Filed 07/03/24    Page 1 of 3

2
(prevailing Eastern Time) (the “Objection Deadline”), except for the Official Committee of
Unsecured Creditors (the “Committee”), whose deadline was extended to July 5, 2024.
3.
Prior to the Committee’s extended Objection Deadline, the Debtors received
informal comments to the Motion and Proposed Order from counsel to the Committee.
4.
The Debtors have not received any objections or other informal comments to the
Motion and Proposed Order.
5.
The Debtors revised the Proposed Order to address the informal comments received
from counsel to the Committee and the parties agreed to a revised Proposed Order, a copy of which
is attached hereto as Exhibit 1 (the “Revised Proposed Order”).
6.
A blackline comparing the Revised Proposed Order against the Proposed Order is
attached hereto as Exhibit 2.
7.
The Debtors respectfully request that the Court enter the Revised Proposed Order
at its earliest convenience.
[Remainder of Page Intentionally Left Blank]
Case 24-11217-BLS    Doc 139    Filed 07/03/24    Page 2 of 3

3
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 139    Filed 07/03/24    Page 3 of 3

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