Vyaire - CNO to Motion to Extend Deadline to Reject Leases

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A certificate of no objection filed September 26, 2024 as Doc 571 in In re Vyaire Medical, Inc., et al., Case No. 24-11217 (BLS), in the United States 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 debtors' motion to extend the time to assume or reject unexpired leases of nonresidential real property [Docket No. 522]. It states that the objection deadline, September 25, 2024, has passed and requests that the court enter the proposed order attached to the motion. The certificate is signed /s/ Stacy L. Newman for Cole Schotz P.C. and Kirkland & Ellis LLP.

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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. 522
CERTIFICATE OF NO OBJECTION
REGARDING MOTION OF DEBTORS FOR ENTRY
OF AN ORDER (I) EXTENDING THE TIME WITHIN WHICH
THE DEBTORS MUST ASSUME OR REJECT UNEXPIRED LEASES OF
NONRESIDENTIAL REAL PROPERTY 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 Time Within Which the
Debtors Must Assume or Reject Unexpired Leases of Nonresidential Real Property and (II)
Granting Related Relief [Docket No. 522] (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
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 571    Filed 09/26/24    Page 1 of 2

2
responsive pleading to the Motion appears thereon.  It is hereby 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 571    Filed 09/26/24    Page 2 of 2

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