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Notice Of Debtors’ Proposed Order

Date
2024-08-15

Summary

A Notice of Debtors' Proposed Order filed August 20, 2024 as Doc 399 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 concerns a proposed order approving the Zoll Asset Purchase Agreement and authorizing the sale of certain ventilation assets and the assumption and assignment of related contracts. The notice recites that on August 15, 2024 the Debtors filed a Notice of Successful Bidder [Docket No. 388] designating Zoll Medical Corp. as Successful Bidder and Vent Portfolio, LLC as Back-Up Bidder. It states that the proposed Sale Order is attached as Exhibit A and that the Sale Hearing is set for August 26, 2024 before Judge Brendan L. Shannon. It is signed by Cole Schotz P.C.; the signature block also lists Kirkland & Ellis LLP, both as co-counsel to the Debtors.

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Full text

                  Case 24-11217-BLS              Doc 399       Filed 08/20/24         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)
                                                               )
                                                               )

                      NOTICE OF DEBTORS’ PROPOSED ORDER
                    (I) 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, CLAIMS, INTERESTS,
           AND ENCUMBRANCES, (III) AUTHORIZING THE ASSUMPTION AND
         ASSIGNMENT OF EXECUTORY CONTRACTS AND UNEXPIRED LEASES
         IN CONNECTION THEREWITH, AND (IV) GRANTING RELATED RELIEF

        PLEASE TAKE NOTICE that, 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] (the “Notice of Successful Bidder”), 2 (a) designating Zoll Medical
Corp. (“Zoll”) as a Successful Bidder (the “Purchaser”) and Vent Portfolio, LLC (and React Health
Holdings, LLC as guarantor), as a Back-Up Bidder, in connection with the sale of certain of the
Debtors’ Ventilation Assets and (b) disclosing the proposed form of Zoll Asset Purchase
Agreement.

       PLEASE TAKE FURTHER NOTICE that the proposed form of order to authorize the
Sale Transaction under the Zoll Asset Purchase Agreement (the “Sale Order”) is attached hereto
as Exhibit A. The Debtors reserve the right to modify such proposed order prior to the Sale
Hearing.

      PLEASE TAKE FURTHER NOTICE that the Debtors will seek approval of the sale of
such Ventilation Assets to the Purchaser at the Sale Hearing scheduled to commence on

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.
2
      Capitalized terms used but not defined herein have the meanings given to them in the Notice of Successful Bidder
      or Bidding Procedures Order (as defined therein), as applicable.
              Case 24-11217-BLS        Doc 399     Filed 08/20/24     Page 2 of 3




August 26, 2024, at 10:00 a.m. (prevailing Eastern Time) before the Honorable Judge Brendan
L. Shannon, United States Bankruptcy Judge for the Bankruptcy Court for the District of Delaware,
at 824 North Market Street, 6th Floor, Courtroom No. 1, Wilmington, Delaware 19801. The Sale
Hearing may be adjourned by announcement in open Court or on the Court’s calendar without any
further notice required. The Debtors reserve the right to amend, revise,

        PLEASE TAKE FURTHER NOTICE that you may obtain additional information
concerning the above-captioned chapter 11 cases at the website maintained in these chapter 11
cases at https://omniagentsolutions.com/Vyaire.

                         [Remainder of Page Intentionally Left Blank]




                                               2
                         Case 24-11217-BLS         Doc 399    Filed 08/20/24     Page 3 of 3



Dated: August 20, 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


 Co-Counsel to the Debtors                                   Co-Counsel to the Debtors
 and Debtors in Possession                                   and Debtors in Possession




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