Lyons-Vyaire - Certif of Counsel _COC_ re Order Approving Stip for Relief from Stay _MFR_ v1
- Date
- 2024-10-01
Summary
A certification of counsel filed October 25, 2024 as Doc 678 in In re Vyaire Medical, Inc., et al., Case Nos. 24-11217 (BLS), in the U.S. Bankruptcy Court for the District of Delaware. Adam Hiller of Hiller Law, LLC files it for movant Jeffrey Paul Lyons, III, as administrator of an estate, regarding a proposed order approving a joint stipulation granting limited relief from the automatic stay. It states that the movant filed a Motion for Relief from the Automatic Stay (Docket No. 589) on October 1, 2024, and that the Debtors negotiated and executed the stipulation instead of responding. Counsel certifies that no objection or response to the motion was received or appears on the docket, notes an objection deadline of October 18, 2024 that was extended for the Debtors, and asks the Court to enter the proposed order.
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Case 24-11217-BLS Doc 678 Filed 10/25/24 Page 1 of 2
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
In re Chapter 11
VYAIRE MEDICAL, INC., et al., Case Nos. 24-11217 (BLS), et seq.
Debtors. (Jointly Administered)
Re: Docket No. 589
CERTIFICATION OF COUNSEL REGARDING
PROPOSED ORDER APPROVING JOINT STIPULATION
GRANTING LIMITED RELIEF FROM AUTOMATIC STAY
WITH JEFFREY PAUL LYONS, III, AS ADMINISTRATOR
OF THE ESTATE OF CONNITA SHONTELL RANSOM
Adam Hiller, counsel for Jeffrey Paul Lyons, III, as Administrator of the
Estate of Connita Shontell Ransom, (“Movant”) hereby certifies as follows:
1. On October 1, 2024, Movant filed a Motion for Relief from the
Automatic Stay (Docket No. 589) (the “Motion”) in the above-referenced cases.
2. In lieu of a response, Vyaire Medical, Inc. and its affiliated debtors
and debtors-in-possession (the “Debtors”) entered into negotiations with Movant
and executed a Joint Stipulation Granting Limited Relief From Automatic Stay
With Jeffrey Paul Lyons, III, As Administrator Of The Estate Of Connita Shontell
Ransom (the “Stipulation,” attached hereto as Exhibit A-1) with Movant. A
proposed order approving the Stipulation is attached hereto as Exhibit A (the
“Proposed Order”).
Case 24-11217-BLS Doc 678 Filed 10/25/24 Page 2 of 2
3. The undersigned hereby certifies that he has received no formal or
informal objection or response to the Motion. The undersigned further certifies that
he has reviewed the docket in this case and that no objection or response to the
Motion appears thereon. The notice accompanying the Motion set a deadline of
October 18, 2024 for receipt of objections to the Motion. This deadline was
extended for the Debtors in order to facilitate negotiations.
4. Movant requests that the Court enter the Proposed Order as an order
of the Court at the Court’s convenience.
Dated: October 25, 2024 Respectfully submitted,
Wilmington, Delaware
HILLER LAW, LLC
/s/ Adam Hiller
Adam Hiller (DE No. 4105)
300 Delaware Avenue, Suite 210, #227
Wilmington, Delaware 19801
(302) 442-7677 telephone
ahiller@adamhillerlaw.com
Attorney for Movant
Jeffrey Paul Lyons, III, as Administrator of
the Estate of Connita Shontell Ransom
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- gov.uscourts.deb.193283.678.0.pdf
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- 128,645 bytes
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- d9d051002f68b9d6338431c91a2508f404cc46416b532d7152c1f7b5e80873d3
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