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Vyaire - COC -Omni Admin Agent App KE Comments 7.25.2024

Date
2024-07-26

Summary

Exhibit 1, a revised proposed order filed July 26, 2024 as Doc 319-1 in the jointly administered Chapter 11 cases of Vyaire Medical, Inc., et al., Case No. 24-11217 (BLS), in the U.S. Bankruptcy Court for the District of Delaware. The proposed order, relating to Docket No. 237, would authorize the debtors to employ and retain Omni Agent Solutions, Inc. as administrative agent effective as of the petition date under sections 327(a) and 328(a) of the Bankruptcy Code. It provides that Omni must apply to the Court for compensation, will not be compensated for defending its fee applications, and that Section XI of the Engagement Agreement has no force during the cases. It also limits the debtors' indemnification obligations, citing In re United Artists Theatre Co., 315 F.3d 217 (3d Cir. 2003). The document is 6 pages.

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Case 24-11217-BLS   Doc 319-1   Filed 07/26/24   Page 1 of 6




                        Exhibit 1

                Revised Proposed Order
                 Case 24-11217-BLS             Doc 319-1        Filed 07/26/24       Page 2 of 6




                         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. 237

                    ORDER AUTHORIZING DEBTORS TO
         EMPLOY AND RETAIN OMNI AGENT SOLUTIONS, INC. AS
      ADMINISTRATIVE AGENT EFFECTIVE AS OF THE PETITION DATE

          Upon the application (the “Application”)2 of the Debtors in the Chapter 11 Cases for

entry of an order, pursuant to sections 327(a) and 328(a) of the Bankruptcy Code, Bankruptcy

Rules 2014(a) and 2016, and Local Rule 2014-1, (a) authorizing the Debtors to employ and

retain Omni Agent Solutions as the Administrative Agent in the Chapter 11 Cases effective as of

the Petition Date pursuant to the Engagement Agreement; and (b) granting related relief; and the

United States District Court for the District of Delaware having 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 the Court having authority to hear the matters raised in

the Application pursuant to 28 U.S.C. § 157; and venue being proper before this Court pursuant

to 28 U.S.C. §§ 1408 and 1409; and consideration of the Application and the requested relief


1
            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.

2
          Capitalized terms not otherwise defined herein shall have the meanings ascribed to such terms in the
     Application.
             Case 24-11217-BLS          Doc 319-1      Filed 07/26/24     Page 3 of 6




being a core proceeding that the Court can determine pursuant to 28 U.S.C. § 157(b)(2); and due

and proper notice of the Application and opportunity for a hearing on the Application having

been given to the Notice Parties, and it appearing that no other or further notice need be

provided; and the Court having reviewed and considered the Application, the Deutch Declaration

and the First Day Declaration; and the Court having held, if necessary, a hearing on the

Application (the “Hearing”); and the Court having found that the legal and factual bases set forth

in the Application establish just cause for the relief granted herein; and the Court having found

that the terms and conditions of Omni’s employment are reasonable as required by section 328(a)

of the Bankruptcy Code; and the Court having found that Omni is a “disinterested person” as that

term is defined in section 101(14) of the Bankruptcy Code; and the Court having found that the

relief requested in the Application being in the best interests of the Debtors, their creditors, their

estates, and all other parties in interest; and upon all of the proceedings had before the Court; and

after due deliberation and sufficient cause appearing therefor, it is hereby

       ORDERED, ADJUDGED AND DECREED THAT:

       1.      The Application is approved as set forth in this Order.

       2.      The Debtors are authorized to retain Omni as Administrative Agent effective as of

the Petition Date under the terms of the Engagement Agreement, and Omni is authorized to

perform the bankruptcy administration services described in the Application and set forth in the

Engagement Agreement.

       3.      Omni is authorized to take such other action to comply with all duties set forth in

the Application.

       4.      Omni shall apply to the Court for allowance of compensation and reimbursement

of expenses incurred after the Petition Date in accordance with the applicable provisions of the
             Case 24-11217-BLS         Doc 319-1     Filed 07/26/24     Page 4 of 6




Bankruptcy Code, the Bankruptcy Rules, the Local Rules, and any orders entered in these cases

regarding professional compensation and reimbursement of expenses.

       5.      Section XI of the Engagement Agreement is of no force or effect during these

Chapter 11 Cases.

       6.      Notwithstanding anything contained in the Application, the Engagement

Agreement, or any document ancillary thereto, absent a change in controlling law, Omni shall

not be compensated or reimbursed for, or in connection with, the defense of its fee applications.

       7.      The Debtors shall indemnify Omni (or the “Indemnified Parties”) under the terms

of the Engagement Agreement, as modified pursuant to this Order.

       8.      The Indemnified Parties shall not be entitled to indemnification, contribution, or

reimbursement pursuant to the Engagement Agreement for services other than the services

provided under the Engagement Agreement, unless such services and the indemnification,

contribution or reimbursement therefor are approved by the Court.

       9.      Notwithstanding anything to the contrary in the Engagement Agreement, the

Debtors shall have no obligation to indemnify the Indemnified Parties, or provide contribution or

reimbursement to the Indemnified Parties, for any claim or expense that is either: (i) judicially

determined (the determination having become final) to have arisen from the Indemnified Parties’

bad faith, self-dealing, breach of fiduciary duty (if any), gross negligence, willful misconduct or

fraud; (ii) for a contractual dispute in which the Debtors allege the breach of the Indemnified

Parties’ contractual obligations if the Court determines that indemnification, contribution or

reimbursement would not be permissible pursuant to In re United Artists Theatre Co., 315 F.3d

217 (3d Cir. 2003); or (iii) settled prior to a judicial determination under (i) or (ii), but

determined by this Court, after notice and a hearing, to be a claim or expense for which the
             Case 24-11217-BLS           Doc 319-1      Filed 07/26/24      Page 5 of 6




Indemnified Parties should not receive indemnity, contribution or reimbursement under the terms

of the Engagement Agreement as modified by this Order.

       10.       If, before the earlier of (i) the entry of an order confirming a chapter 11 plan in the

Chapter 11 Cases (that order having become a final order no longer subject to appeal), or (ii) the

entry of an order closing the Chapter 11 Cases, the Indemnified Parties believe they are entitled

to the payment of any amounts by the Debtors on account of the Debtors’ indemnification,

contribution and/or reimbursement obligations under the Engagement Agreement (as modified

by this Order), including the advancement of defense costs, the Indemnified Parties must file an

application therefore in this Court, and the Debtors may not pay any such amounts to the

Indemnified Parties before the entry of an order by this Court approving the payment requested

therein. This paragraph is intended only to specify the period of time under which the Court

shall have jurisdiction over any request for fees and expenses by the Indemnified Parties for

indemnification, contribution or reimbursement, and not a provision limiting the duration of the

Debtors’ obligation to indemnify the Indemnified Parties. All parties in interest shall retain the

right to object to any demand by the Indemnified Parties for indemnification, contribution, or

reimbursement.

       11.       The Debtors and Omni are authorized to take all actions necessary to effectuate

the relief granted pursuant to this Order in accordance with the Application.

       12.       Notwithstanding any term in the Engagement Agreement to the contrary, the

Court retains jurisdiction with respect to all matters arising from or related to the implementation

of this Order.

       13.       Notwithstanding any provision in the Bankruptcy Rules to the contrary, this Order

shall be immediately effective and enforceable upon its entry.
             Case 24-11217-BLS        Doc 319-1       Filed 07/26/24   Page 6 of 6




       14.    In the event of any inconsistency between the Engagement Agreement, the

Application, and the Order, the Order shall govern.


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