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Vyaire - COC - KE Retention App KE Comments 8.2.2024

Date
2024-07-09

Summary

A certification of counsel filed August 2, 2024 as Doc 347 in In re Vyaire Medical, Inc., et al., Case No. 24-11217 (BLS), jointly administered Chapter 11 cases in the U.S. Bankruptcy Court for the District of Delaware. It concerns the debtors' application, filed July 9, 2024 as Docket No. 236, to retain Kirkland & Ellis LLP and Kirkland & Ellis International LLP as attorneys for the debtors effective as of June 9, 2024. The certification states that the objection deadline was July 23, 2024, extended to August 2, 2024 for the U.S. Trustee, and that the debtors received informal comments from the U.S. Trustee but no objections. It reports that the debtors filed a supplemental declaration, attaches a Revised Proposed Order as Exhibit 1 and a blackline as Exhibit 2, and asks the court to enter the revised order. It is signed by Patrick J. Reilley of Cole Schotz P.C.

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Full text

                   Case 24-11217-BLS             Doc 347       Filed 08/02/24         Page 1 of 3




                         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. 236

                      CERTIFICATION OF COUNSEL
                   REGARDING DEBTORS’ APPLICATION
                FOR ENTRY OF AN ORDER AUTHORIZING THE
          RETENTION AND EMPLOYMENT OF KIRKLAND & ELLIS LLP
       AND KIRKLAND & ELLIS INTERNATIONAL LLP AS ATTORNEYS FOR
    THE DEBTORS AND DEBTORS IN POSSESSION EFFECTIVE AS OF JUNE 9, 2024

             The undersigned 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 July 9, 2024, the Debtors’ Application for Entry of an Order Authorizing the

Retention and Employment of Kirkland & Ellis LLP and Kirkland & Ellis International LLP as

Attorneys for the Debtors and Debtors in Possession Effective as of June 9, 2024 [Docket No. 236]

(the “Application”) 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 Application (the “Proposed Order”).

             2.     Pursuant to the Notice of Debtors’ Application for Entry of an Order Authorizing

the Retention and Employment of Kirkland & Ellis LLP and Kirkland & Ellis International LLP


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 347     Filed 08/02/24    Page 2 of 3




as Attorneys for the Debtors and Debtors in Possession Effective as of June 9, 2024 [Docket

No. 236-1], objections or responses to the Application and entry of the Proposed Order were to be

filed and served on the undersigned proposed counsel by July 23, 2024, at 4:00 p.m. (prevailing

Eastern Time) (the “Objection Deadline”), except for the Office of the United States Trustee for

the District of Delaware (the “U.S. Trustee”), whose deadline was extended to August 2, 2024.

       3.      Prior to the U.S. Trustee’s extended Objection Deadline, the Debtors received

informal comments to the Application and Proposed Order from the U.S. Trustee.

       4.      The Debtors have not received any objections or other informal comments to the

Application and Proposed Order.

       5.      The Debtors filed a supplemental declaration in support of the Application to

address certain informal comments received from the U.S. Trustee, 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]




                                                2
                        Case 24-11217-BLS          Doc 347    Filed 08/02/24     Page 3 of 3



Dated: August 2, 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


 Co-Counsel to the Debtors                                   Proposed Co-Counsel to the Debtors
 and Debtors in Possession                                   and Debtors in Possession




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