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Vyaire - COC -PJT Retention App KE Comments 7.25.2024

Date
2024-07-09

Summary

A Certification of Counsel filed July 26, 2024 as Doc 320 in In re Vyaire Medical, Inc., et al., Case No. 24-11217 (BLS), in the U.S. Bankruptcy Court for the District of Delaware, regarding the Debtors' application to retain PJT Partners LP as investment banker and to waive certain information requirements under Local Rule 2016-2. It states that the application was filed July 9, 2024 as Docket No. 240, with an objection deadline of July 23, 2024, extended to July 24, 2024 for the U.S. Trustee. It reports that the Debtors received informal comments only from the U.S. Trustee and revised the proposed order to address them. The certification refers to the revised proposed order as Exhibit 1 and a blackline as Exhibit 2, and asks the Court to enter the revised order.

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                   Case 24-11217-BLS             Doc 320       Filed 07/26/24         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. 240

                  CERTIFICATION OF COUNSEL REGARDING
      APPLICATION OF DEBTORS FOR ENTRY OF AN ORDER (I) AUTHORIZING
     THE RETENTION AND EMPLOYMENT OF PJT PARTNERS LP AS INVESTMENT
     BANKER TO THE DEBTORS AND DEBTORS IN POSSESSION EFFECTIVE AS OF
    THE PETITION DATE, (II) WAIVING CERTAIN INFORMATION REQUIREMENTS
    PURSUANT TO LOCAL RULE 2016-2, AND (III) 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 July 9, 2024, the Application of Debtors for Entry of an Order (I) Authorizing

the Retention and Employment of PJT Partners LP as Investment Banker to the Debtors and

Debtors in Possession Effective as of the Petition Date, (II) Waiving Certain Information

Requirements Pursuant to Local Rule 2016-2, and (III) Granting Related Relief [Docket No. 240]

(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”).




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 320      Filed 07/26/24   Page 2 of 3




       2.        Pursuant to the Notice of Application of Debtors for Entry of an Order (I)

Authorizing the Retention and Employment of PJT Partners LP as Investment Banker to the

Debtors and Debtors in Possession Effective as of the Petition Date, (II) Waiving Certain

Information Requirements Pursuant to Local Rule 2016-2, and (III) Granting Related Relief,

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

July 24, 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 revised the Proposed Order to address the 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 320    Filed 07/26/24     Page 3 of 3



Dated: July 26, 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




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