Vyaire - CNO to Motion to Remove Actions

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A Certificate of No Objection regarding the Debtors' motion for an order enlarging the period within which the Debtors may remove actions (Docket No. 495) in In re Vyaire Medical, Inc., et al., Case No. 24-11217 (BLS), in the U.S. Bankruptcy Court for the District of Delaware. Counsel to the Debtors certifies that no answer, objection or other responsive pleading has been received to the motion filed on September 4, 2024. It states that objections were due no later than September 18, 2024, that the Objection Deadline has passed, and it asks the Court to enter the proposed order attached to the motion. The certificate is dated September 19, 2024 and bears the /s/ of Patrick J. Reilley.

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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. 495
CERTIFICATE OF NO OBJECTION
REGARDING MOTION OF DEBTORS FOR ENTRY
OF AN ORDER (I) ENLARGING THE PERIOD WITHIN WHICH THE
DEBTORS MAY REMOVE ACTIONS AND (II) GRANTING RELATED RELIEF
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 that, as of the date hereof, no answer, objection, or other responsive pleading has been
received to the Motion of Debtors for Entry of an Order (I) Enlarging the Period Within Which
the Debtors May Remove Actions and (II) Granting Related Relief [Docket No. 495]
(the “Motion”) filed with the United States Bankruptcy Court for the District of Delaware
(the “Court”) on September 4, 2024.  Pursuant to the notice of Motion, objections to the Motion
were to be filed and served no later than September 18, 2024 (the “Objection Deadline”).
The Objection Deadline has passed and no objections or other responsive pleading to the
Motion appear on the docket or were served upon the undersigned counsel.  It is hereby
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.
Case 24-11217-BLS    Doc 534    Filed 09/19/24    Page 1 of 2

2
respectfully requested that the Court enter the proposed order attached to the Motion at the earliest
convenience of the Court.
Dated: September 19, 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
Case 24-11217-BLS    Doc 534    Filed 09/19/24    Page 2 of 2

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