Notice of Withdrawal — In re Vyaire Medical, Inc (Dkt. 675)

Summary

Kuehne + Nagel Inc. (K+N), through counsel, gives notice that it withdraws three objections in the Vyaire Medical, Inc., et al. case. The objections are the Limited Objection and Reservation of Rights to the Debtors' motion for approval of bidding procedures [Docket No. 133], filed July 2, 2024; the Objection to the Debtors' First Notice to Contract Parties of Potentially Assumed and Assigned Executory Contracts and Unexpired Leases [Docket No. 315], filed July 25, 2024; and the Supplemental Objection [Docket No. 498], filed September 5, 2024. The notice is dated October 23, 2024, and the signature block names David M. Klauder of Bielli & Klauder, LLC with /s/.

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Full text

IN UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE

In re:

VYAIRE MEDICAL, INC, et al.,

Debtors.

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Chapter 11

Case No. 24-11217 (BLS)

(Jointly Administered)

Re: Docket Nos. 133, 315, 498

NOTICE OF WITHDRAWAL

Kuehne + Nagel Inc. (“K+N”), by and through its undersigned counsel, hereby withdraws
the following objections in the above-captioned case:
1.
Limited Objection and Reservation of Rights of Kuehne + Nagel Inc. to Motion of
Debtors for Entry of an Order (I) Approving Bidding Procedures in Connection with the Sale of
Substantially all of the Debtors’ Assets, (II) Authorizing the Debtors to Enter Into a Stalking Horse
Agreement and Provide Bid Protections, (III) Approving the Form and Manner of Notice Thereof,
(IV) Scheduling an Auction and Sale Hearing, (V) Approving Procedures for the Assumption and
Assignment of Contracts, (VI) Approving the Sale of the Debtors’ Assets Free and Clear, and (VII)
Granting Related Relief [Docket No. 133], filed on July 2, 2024;
2.
Objection to Debtors’ First Notice to Contract Parties of Potentially Assumed and
Assigned Executory Contracts and Unexpired Leases [Docket No. 315] filed on July 25, 2024; and
3.
Supplemental Objection to First Supplemental Notice to Contract Parties of
Potentially Assumed and Assigned Executory Contracts and Unexpired Leases First Notice to
Contract Parties of Potentially Assumed and Assigned Executory Contracts and Unexpired Leases
[Docket No. 498], filed on September 5, 2024.

Case 24-11217-BLS    Doc 675    Filed 10/23/24    Page 1 of 2

QB\179239.00001\92358194.1
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Date:  October 23, 2024

BIELLI & KLAUDER, LLC
Wilmington, Delaware

/s/ David M. Klauder

David M. Klauder, Esquire (No. 5769)

1204 N. King Street

Wilmington, DE 19801

Phone:  (302) 803-4600

dklauder@bk-legal.com

-and-

HALPERIN BATTAGLIA BENZIJA, LLP

Walter Benzija, Esquire (pro hac vice)
40 Wall Street, 37th Floor
New York, NY 10005
Telephone (212) 765-9100
wbenzija@halperinlaw.net

Co-counsel for Kuehne + Nagel Inc.

Case 24-11217-BLS    Doc 675    Filed 10/23/24    Page 2 of 2

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