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Vyaire - COC - Customer Program Motion Final Order FINAL

Date
2024-07-03

Summary

Exhibit 2, a blackline of the Final Order authorizing the debtors to maintain and administer their existing Customer Programs and honor certain related prepetition obligations, filed July 3, 2024 as Doc 146-2 in In re: Vyaire Medical, Inc., et al., Case No. 24-11217, in the U.S. Bankruptcy Court for the District of Delaware. The blackline shows changes against an earlier form of the order. The order grants the debtors' motion on a final basis, authorizing but not directing them to continue Customer Programs and to modify or terminate them on no fewer than five (5) days' written notice to the official committee of unsecured creditors and the Ad Hoc Group. It authorizes banks to honor related checks, preserves parties' rights on claims, and makes payments subject to any DIP Order.

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Full text

Case 24-11217-BLS   Doc 146-2   Filed 07/03/24   Page 1 of 5




                        Exhibit 2

                        Blackline
                 Case 24-11217-BLS              Doc 146-2           Filed 07/03/24      Page 2 of 5




                         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             Administerationed
                                                                         Requested)

                                                                )        Re: Docket NoNos. __8, 87

                       FINAL ORDER (I) AUTHORIZING
              THE DEBTORS TO MAINTAIN AND ADMINISTER THEIR
       EXISTING CUSTOMER PROGRAMS AND HONOR CERTAIN PREPETITION
      OBLIGATIONS RELATED THERETO AND (II) GRANTING RELATED RELIEF

             Upon the motion (the “Motion”)2 of the above-captioned debtors and debtors in

possession (collectively, the “Debtors”) for the entry of a final order (this “Final Order”),

(a) authorizing, but not directing, the Debtors to maintain and administer the Customer Programs

and honor certain prepetition obligations related thereto, 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 that this Court may enter a final order consistent with


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
      Capitalized terms used but not otherwise defined herein have the meanings ascribed to them in the Motion.
             Case 24-11217-BLS          Doc 146-2      Filed 07/03/24      Page 3 of 5




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

under the circumstances and no other notice need be provided; and this Court having reviewed

the Motion; and this Court having determined that the legal and factual bases set forth in the

Motion 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.      1. The Debtors are authorized, but not directed, to continue to administer the

Customer Programs (including, but not limited to, those discussed in the Motion) currently in

effect and honor any undisputed prepetition obligations related to the Customer Programs, in

each case in the ordinary course of business, on a final basis, consistent with prepetition

practices, and to modify, replace, or terminate any Customer Program in the ordinary course of

business, provided that the Debtors shall provide no fewer than five (5) days’ written notice of

any modification, replacement, or termination of any Customer Program to the official

committee of unsecured creditors and the Ad Hoc Group.

       3.      2. 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




                                                  2
               Case 24-11217-BLS        Doc 146-2      Filed 07/03/24      Page 4 of 5




Debtors’ designation of any particular check or electronic payment request as approved by this

Final Order.

       4.       3. 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.

       5.       4. 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.

       6.       5. Nothing in the Motion or this Final Order waives or modifies the requirements

of the Restructuring Support Agreement, including, without limitation, the consent and




                                                  3
             Case 24-11217-BLS         Doc 146-2      Filed 07/03/24     Page 5 of 5




consultation rights contained therein; provided, however, that nothing in the Motion or this Final

Order constitutes Court approval of the Restructuring Support Agreement.

       7.      6. Notwithstanding anything to the contrary contained 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 or proposed to be taken hereunder, the terms of the DIP Order shall control.

       8.      7. 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.

       9.      8. Notwithstanding Bankruptcy Rule 6004(h), the terms and conditions of this

Final Order are immediately effective and enforceable upon its entry.

       10.     9. The Debtors are authorized to take all actions necessary to effectuate the relief

granted in this Final Order in accordance with the Motion.

       11.     10. This Court retains jurisdiction with respect to all matters arising from or

related to the implementation, interpretation, and enforcement of this Final Order.




                                                 4


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