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Vyaire - COC - Dell-Mettawa Stipulation

Date
2024-08-15

Summary

A Certification of Counsel Regarding Joint Stipulation Between the Debtors and Dell-Mettawa, LLC Regarding Rejection of Lease in Connection With Zoll Sale, filed November 25, 2024 as Doc 798 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 recounts the Debtors' August 15, 2024 notice of the successful bidder for their Ventilation Assets [Docket No. 388] and the Court's September 4, 2024 Zoll Sale Order [Docket No. 496]. The Debtors, Dell-Mettawa and Zoll agreed to negotiate a new lease guaranteed by Zoll, to reject the original lease effective as of October 31, 2024, and to allow Dell-Mettawa's administrative claim for stub rent. Counsel states the creditors' committee and lenders do not object and asks the Court to enter the order.

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Full text

                   Case 24-11217-BLS             Doc 798       Filed 11/25/24         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 Nos. 256, 309, and 462

 CERTIFICATION OF COUNSEL REGARDING JOINT STIPULATION BETWEEN
THE DEBTORS AND DELL-METTAWA, LLC REGARDING REJECTION OF LEASE
                  IN CONNECTION WITH ZOLL SALE

             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 August 15, 2024, the Debtors filed the Notice of (I) Successful Bidder for the

Sale of Certain of the Debtors’ Ventilation Assets, (II) Proposed Purchase Agreement in

Connection Therewith, and (III) Proposed Sale Order in Connection Therewith [Docket No. 388],

which attached thereto as Exhibit A is the Asset Purchase Agreement related to the Debtors’

Ventilation Assets (as may be amended or otherwise modified from time to time and including all

related documents, exhibits, schedules, and agreements thereto, collectively, the “Zoll APA”).

             2.     On September 4, 2024, the Court entered the Order (A) Approving the Zoll Asset

Purchase Agreement and Authorizing the Sale of Certain Ventilation Assets of the Debtors Outside

the Ordinary Course of Business, (II) Authorizing the Sale of Assets Free and Clear of All Liens,


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’ proposed 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 798     Filed 11/25/24    Page 2 of 3




Claims, Interests, and Encumbrances, (III) Authorizing the Assumption and Assignment of

Executory Contracts and Unexpired Leases in Connection Therewith, and (IV) Granting Related

Relief [Docket No. 496] (the “Zoll Sale Order”) approving the sale of Debtors’ Ventilation Assets

to Zoll (the “Zoll Sale”).

        3.     Following entry of the Zoll Sale Order, and to facilitate the terms of the Zoll APA,

the Debtors, Dell-Mettawa, and Zoll agreed to (i) negotiate the terms of a new lease agreement

between Vyaire and Dell-Mettawa, and for which Zoll agreed to serve as a guarantor for Vyaire’s

obligations thereunder (the “New Lease”), (ii) the rejection of the Original Lease effective as of

October 31, 2024, and (iii) allowance and payment of Dell-Mettawa’s administrative claim for

stub rent.

        4.     The Debtors have shared the Joint Stipulation Between the Debtors and Dell-

Mettawa, LLC Regarding Rejection of Lease in Connection With Zoll Sale with counsel for the

Official Committee of Unsecured Creditors and counsel for the Debtors’ debtor-in-possession

lenders and such parties do not have comments or objections to entry of the Order.

        5.     The Debtors respectfully request that the Court enter the Order at its earliest

convenience.




                             [Remainder of page Intentionally Left Blank]




                                                  2
                        Case 24-11217-BLS          Doc 798    Filed 11/25/24     Page 3 of 3



Dated: November 25, 2024
Wilmington, Delaware

 /s/ Patrick J. Reilley
  COLE SCHOTZ P.C.                                           KIRKLAND & ELLIS LLP
  Patrick J. Reilley (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                                   Co-Counsel to the Debtors
 and Debtors in Possession                                   and Debtors in Possession




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