Certificate of No Objection — Motion Extending Exclusive Periods (Vyaire Medical, Inc., Case 24-11217-BLS)

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Certificate of No Objection in the Vyaire Medical, Inc. chapter 11 case, Case No. 24-11217 (BLS), Re: Docket No. 521, regarding the Motion of Debtors for Entry of an Order extending the Debtors' exclusive periods to file a Chapter 11 plan and solicit acceptances thereof. The undersigned counsel certifies that no answer, objection or other responsive pleading has been received and that none appears on the Court's docket. The Motion was filed on September 11, 2024, and objections were to be filed and served no later than September 25, 2024. The document is dated September 26, 2024 and carries the text /s/ Stacy L. Newman.

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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. 521
CERTIFICATE OF
NO OBJECTION REGARDING MOTION OF
DEBTORS FOR ENTRY OF AN ORDER (I) EXTENDING THE
DEBTORS’ EXCLUSIVE PERIODS TO FILE A CHAPTER 11 PLAN
AND SOLICIT ACCEPTANCES THEREOF PURSUANT TO SECTION
1121 OF THE BANKRUPTCY CODE 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) Extending the Debtors’ Exclusive
Periods to File a Chapter 11 Plan and Solicit Acceptances Thereof Pursuant to Section 1121 of
the Bankruptcy Code and (II) Granting Related Relief [Docket No. 521] (the “Motion”) filed with
the United States Bankruptcy Court for the District of Delaware (the “Court”) on September 11,
2024.  Pursuant to the notice of Motion, objections to the Motion were to be filed and served no
later than September 25, 2024 (the “Objection Deadline”).  The undersigned further certifies that
the Objection Deadline has passed, the Court’s docket has been reviewed in this case, and no
answer, objection, or other responsive pleading to the Motion appears thereon.  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 570    Filed 09/26/24    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 26, 2024
Wilmington, Delaware
/s/ Stacy L. Newman
COLE SCHOTZ P.C.
KIRKLAND & ELLIS LLP
Patrick J. Reilley, Esq. (No. 4451)
KIRKLAND & ELLIS INTERNATIONAL LLP
Stacy L. Newman (No. 5044)
Joshua A. Sussberg, P.C. (admitted pro hac vice)
500 Delaware Avenue, Suite 1410
601 Lexington Ave
Wilmington, Delaware 19801
New York, New York 10022
Telephone:
(302) 652-3131
Telephone:
(212) 446-4800
Facsimile:
(302) 652-3117
Facsimile:
(212) 446-4900
Email:
preilley@coleschotz.com
Email:
joshua.sussberg@kirkland.com
snewman@coleschotz.com
- and -
- and -
Michael D. Sirota, Esq. (admitted pro hac vice)
Spencer A. Winters, P.C. (admitted pro hac vice)
Warren A. Usatine, Esq (admitted pro hac vice)
Yusuf U. Salloum (admitted pro hac vice)
Court Plaza North, 25 Main Street
333 West Wolf Point Plaza
Hackensack, New Jersey 07601
Chicago, Illinois 60654
Telephone:
(201) 489-3000
Telephone:
(312) 862-2000
Facsimile:
(201) 489-1536
Facsimile:
(312) 862-2200
Email:
msirota@coleschotz.com
Email:
spencer.winters@kirkland.com
wusatine@coleschotz.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 570    Filed 09/26/24    Page 2 of 2

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