Vyaire RSN Oracle DE\(83730369.1\)

What This Document Is

A 2-page Request for Notice filed by Buchalter, A Professional Corporation on behalf of Oracle America, Inc., requesting that all notices, papers, and pleadings required to be served in the case — including Rule 2002, 3017, and 9007 notices — be served on Shawn M. Christianson, Esq. at Buchalter's San Francisco office. Standard rights-reservation boilerplate preserves Oracle's Article III jury-trial, de novo review, and reference-withdrawal rights without waiver.

Factual Summary

Oracle America, Inc., through counsel Shawn M. Christianson of Buchalter, filed a routine request to be added to the case's formal notice list, entitling it to receive all bankruptcy notices and pleadings going forward. The filing does not itself object to anything, assert a claim amount, or identify the nature of Oracle's relationship to the Debtors (e.g., software licensing, cloud services, or another vendor arrangement); it is purely a service-list enrollment. The source PDF's internal DMS filename ("Vyaire RSN Oracle DE (83730369.1)") does not match the document's actual caption or subject matter.

Key Facts

Docket 302, filed and dated 2024-07-23; 2-page Request for Notice under Bankruptcy Rules 2002, 3017, and 9007.
Filed by Shawn M. Christianson, Esq., Buchalter, A Professional Corporation (San Francisco), for Oracle America, Inc.
Establishes Oracle America, Inc. as a party requesting formal notice in the case, alongside the Cigna (301) and Data-Modul (299) filings opening the sale-objection window — though this filing is a routine service-list request, not an objection.
No cure amount, contract identification, or objection stated; the document is silent on the substance of any Oracle-Debtor relationship.

Source Caveats

The source PDF's internal DMS filename ("Vyaire RSN Oracle DE (83730369.1)") is not a document caption. The canonical URL slug reproduces the same filename.
The filing is silent on the nature of Oracle's commercial relationship with the Debtors (e.g., licensing, cloud, or hardware); not an objection or claim.

Date: 2024-07-23

Full text

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BN 83730369V1
UNITED STATES BANKRUPTCY COURT
DISTRICT OF DELAWARE

In re

Vyaire Medical, Inc. et al.,

                                                      Debtor(s).

Case No. 24-11217 (BLS)

Chapter 11

  (Jointly Administered)

REQUEST FOR NOTICE
PLEASE TAKE NOTICE that Oracle America, Inc. (“Oracle”), hereby requests that all
notices given or required to be given in the above-captioned case, and all papers served or required
to be served in this bankruptcy proceeding including, without limitation, all notices pursuant to
Federal Rules of Bankruptcy Procedure 2002, 3017 and 9007, be given and served upon:
Shawn M. Christianson, Esq.
Buchalter, A Professional Corporation
425 Market Street, Suite 2900
San Francisco, California  94105-3493
Telephone:
(415) 227-0900
schristianson@buchalter.com
Neither this Request for Notice nor any subsequent appearance, pleading, claim or suit is
intended or shall be deemed to waive Oracle’s: (i) right(s) to have all core matters subject to
Article III jurisdiction heard and decided by a district judge; (ii) right(s) to have final orders in
non-core matters entered only after de novo review by a district judge; (iii) right(s) to trial by jury
in any proceeding so triable herein or in any case, controversy or proceeding related hereto; (iv)
right(s) to have the reference withdrawn by the United States District Court in any matter subject
to mandatory or discretionary withdrawal; or (v) other rights, claims, actions, defenses, setoffs or

Case 24-11217-BLS    Doc 302    Filed 07/23/24    Page 1 of 2

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BN 83730369V1
recoupments to which Oracle is, or may be, entitled under agreements, in law, or in equity, all of
which rights, claims, actions, defenses, setoffs, and recoupments expressly are reserved.

BUCHALTER, A Professional Corporation

Dated: July 23, 2024
By:   _/s/ Shawn M. Christianson__________

Shawn M. Christianson, Esq.

425 Market Street, Suite 2900

San Francisco, CA 94105

Telephone:  (415) 227-0900

Attorneys for Oracle America, Inc.

Case 24-11217-BLS    Doc 302    Filed 07/23/24    Page 2 of 2

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