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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