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Declaration Of Disinterestedness

Date
2024-08-08

Summary

A declaration of disinterestedness of Morgan, Lewis & Bockius LLP, filed August 8, 2024 as Doc 364 in In re Vyaire Medical, Inc., et al., Case No. 24-11217 (BLS), jointly administered Chapter 11 cases in the United States Bankruptcy Court for the District of Delaware. It is made by a partner of the firm under the order authorizing the debtors to retain and compensate professionals used in the ordinary course of business, and relates to Docket No. 225. The declarant states that the debtors asked the firm to provide legal services on intellectual property matters and patent prosecution, and that, insofar as the declarant has been able to ascertain, the firm holds no interest adverse to the debtors on those matters. It states that the debtors owe the firm $309,268.76 for prepetition services and costs, subject to 11 U.S.C. §§ 101–1532. The declaration is made under 28 U.S.C. § 1746.

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Full text

                   Case 24-11217-BLS              Doc 364        Filed 08/08/24         Page 1 of 4




                           IN THE UNITED STATES BANKRUPTCY COURT
                                FOR THE DISTRICT OF DELAWARE

                                                                 )        Chapter 11
   In re:                                                        )
                                                                 )        Case No. 24-11217 (BLS)
   VYAIRE MEDICAL, INC., et al.,1                                )
                                                                 )        (Jointly Administered)
                               Debtors.                          )
                                                                 )        Re: Docket No. 225

                    DECLARATION OF DISINTERESTEDNESS
                     OF MORGAN, LEWIS & BOCKIUS LLP
                          PURSUANT TO THE ORDER
            AUTHORIZING THE DEBTORS TO RETAIN AND COMPENSATE
         PROFESSIONALS UTILIZED IN THE ORDINARY COURSE OF BUSINESS

  I, M. Todd Hales, declare under penalty of perjury:

             1.     I am a partner of Morgan, Lewis & Bockius LLP, located at 600 Anton

  Boulevard, Suite 1800, Costa Mesa, CA 92626 (the “Firm”).

             2.     Vyaire Medical, Inc. and certain of its affiliates, as debtors and debtors in

  possession (collectively, the “Debtors”), have requested that the Firm provide legal services to

  the Debtors in connection with intellectual property matters and patent prosecution, and the Firm

  has consented to provide such services.

             3.     The Firm may have performed services in the past, may currently perform services,

  and may perform services in the future in matters unrelated to these chapter 11 cases for persons

  that are parties in interest in the Debtors’ chapter 11 cases. The Firm does not, however, perform

  services for any such person relating to these chapter 11 cases, or have any relationship with any

  such person, their attorneys, or their accountants that would be adverse to the Debtors or their

  estates.



    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
                  Case 24-11217-BLS           Doc 364      Filed 08/08/24   Page 2 of 4



26125 North Riverwoods Boulevard, Mettawa, Illinois, USA 60045.
              Case 24-11217-BLS          Doc 364      Filed 08/08/24     Page 3 of 4




       4.      As part of its customary practice, the Firm is retained in cases, proceedings, and

transactions involving many different parties, some of whom may represent or be employed by the

Debtors, claimants, and parties in interest in these chapter 11 cases.

       5.      Neither I nor any principal, partner, director, or officer of, or professional employed

by, the Firm has agreed to share or will share any portion of the compensation to be received from

the Debtors with any other person other than the partners and regular employees of the Firm.

       6.      Neither I nor any principal, partner, director, or officer of, or professional employed

by, the Firm, insofar as I have been able to ascertain, holds or represents any interest adverse to

the Debtors or their estates with respect to the matter(s) upon which the Firm is to be employed.

       7.      The Debtors owe the Firm $309,268.76 for prepetition services and costs, the

payment of which is subject to the limitations contained in title 11 of the United States Code, 11

U.S.C. §§ 101–1532.

       8.      As of the Petition Date, which was the date on which the Debtors commenced these

chapter 11 cases, the Firm was retained to provide professional services to the Debtors.

       9.      As of the Petition Date, the Firm was not party to an agreement for indemnification

with certain of the Debtors.

       10.     The Firm is conducting further inquiries regarding its retention by any creditors of

the Debtors, and upon conclusion of that inquiry, or at any time during the period of its

employment, if the Firm should discover any facts bearing on the matters described herein, the

Firm will supplement the information contained in this Declaration.




                                                  2
               Case 24-11217-BLS       Doc 364      Filed 08/08/24     Page 4 of 4




       Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true

and correct.

 Date: August 8, 2024
      Costa Mesa, California

                                            /s/ M. Todd Hales
                                                M. Todd Hales




                                                3


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