Vyaire - Notice of Filing of First Amended Plan Supplement

Summary

Notice of Filing of First Amended Plan Supplement, Doc 720 in Case 24-11217-BLS, dated November 11, 2024. It recites that on October 2, 2024, the Court entered an order [Docket No. 596] authorizing the Debtors to solicit votes on the Joint Chapter 11 Plan, and that the Debtors filed the Plan Supplement on October 28, 2024 [Docket No. 689]. The Debtors file the First Amended Plan Supplement and continue to reserve all rights to alter, modify, amend, or supplement any document in it. The Confirmation Hearing will commence on November 14, 2024, at 10:00 a.m., prevailing Eastern Time, before the Honorable Brendan L. Shannon. The notice states that Article VIII.C of the Plan contains a third-party release and that copies are available from Omni Agent Solutions, Inc., the Claims and Noticing Agent.

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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)
)
NOTICE OF FILING OF FIRST AMENDED PLAN SUPPLEMENT
PLEASE TAKE NOTICE THAT on October 2, 2024, the United States Bankruptcy
Court for the District of Delaware (the “Court”) entered an order [Docket No. 596]
(the “Disclosure Statement Order”):  (a) authorizing the above-captioned debtors and debtors in
possession (collectively, the “Debtors”) to solicit votes on the Joint Chapter 11 Plan of Vyaire
Medical, Inc. and Its Debtor Affiliates [Docket No. 581] (as modified, amended, or supplemented
from time to time, the “Plan”);2 (b) approving on an interim basis the Disclosure Statement for the
Joint Chapter 11 Plan of Vyaire Medical, Inc. and Its Debtor Affiliates [Docket No. 582]
(the “Disclosure Statement”) as containing “adequate information” pursuant to section 1125 of
the Bankruptcy Code; (c) approving the solicitation materials and documents to be included in the
solicitation packages; (d) approving procedures for soliciting, receiving, and tabulating votes on
the Plan and for filing objections to the Plan; and (e) granting related relief.
PLEASE TAKE FURTHER NOTICE THAT as contemplated under the Plan and the
Disclosure Statement Order, the Debtors filed the Plan Supplement on October 28, 2024,
[Docket No. 689] (the “Plan Supplement”).  The Plan Supplement, as defined in the Plan, means
the compilation of documents and forms of documents, schedules, and exhibits to the Plan (in each
case, as may be altered, amended, modified, or supplemented from time to time) to be Filed by the
Debtors prior to the Confirmation Hearing to the extent available, and any additional documents
Filed prior to the Effective Date, including the following, as applicable:  (a) Schedule of Assumed
Executory Contracts and Unexpired Leases, (b) Schedule of Rejected Executory Contracts and
Unexpired Leases, (c) Schedule of Retained Causes of Action, (d) the Plan Administrator
Agreement, (e) the Restructuring Transactions Memorandum, (f) the Wind-Down Budget, and (g)
any other necessary documentation related to the Sale Transactions or Restructuring Transactions
in accordance with Article IV of the Plan.  The Debtors shall have the right to alter, amend, modify,
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 not otherwise defined herein have the same meaning as set forth in the Plan.
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 1 of 37

2
or supplement the documents contained in the Plan Supplement up to the Effective Date as more
fully set forth in the Plan and, as necessary, approval of the Court.
PLEASE TAKE FURTHER NOTICE THAT the Debtors hereby file this amendment
to the Plan Supplement in support of the Plan (the “First Amended Plan Supplement”). For the
avoidance of doubt, the Debtors continue to reserve all rights to alter, modify, amend, or
supplement any document in the Plan Supplement and First Amended Plan Supplement in
accordance with the Plan and Confirmation Order.
PLEASE TAKE FURTHER NOTICE THAT the hearing at which the Court will
consider Confirmation of the Plan (the “Confirmation Hearing”) will commence on November 14,
2024, at 10:00 a.m., prevailing Eastern Time, before The Honorable Brendan L. Shannon, in the
United States Bankruptcy Court for the District of Delaware, located at 824 North Market St., 6th
Floor, Courtroom No. 1, Wilmington, DE 19801.
PLEASE TAKE FURTHER NOTICE THAT if you would like to obtain a copy of the
Disclosure Statement, the Plan, the Plan Supplement, or related documents, you should contact
Omni Agent Solutions, Inc., the claims and noticing retained by the Debtors in these chapter 11
cases (the “Claims and Noticing Agent”), by:  (a) writing via first class mail, to Vyaire Medical,
Inc. et al., c/o Omni Agent Solutions, Inc., 5955 De Soto Avenue, Suite 100, Woodland Hills, CA
91367; (b) writing via electronic mail to Vyaireinquiries@omniagnt.com; or (c) calling
the Debtors’ restructuring hotline at (866) 956-2140 (U.S. Toll-Free/Domestic) or +1 (818) 666-
3635 (International).  You may also obtain copies of any pleadings filed in these chapter 11 cases
(a) for a fee via PACER at:  http://www.deb.uscourts.gov; or (b) at no charge from Omni Agent
Solutions,
Inc.
by
accessing
the
Debtors’
restructuring
website
at
https://omniagentsolutions.com/Vyaire.
ARTICLE VIII OF THE PLAN CONTAINS RELEASE, EXCULPATION, AND INJUNCTION
PROVISIONS, AND ARTICLE VIII.C OF THE PLAN CONTAINS A THIRD-PARTY
RELEASE.  THUS, YOU ARE ADVISED TO REVIEW AND CONSIDER THE PLAN
CAREFULLY BECAUSE YOUR RIGHTS MIGHT BE AFFECTED THEREUNDER.
THIS NOTICE IS BEING SENT TO YOU FOR INFORMATIONAL PURPOSES ONLY.
IF YOU HAVE QUESTIONS WITH RESPECT TO YOUR RIGHTS UNDER THE PLAN
OR ABOUT ANYTHING STATED HEREIN OR IF YOU WOULD LIKE TO OBTAIN
ADDITIONAL INFORMATION, CONTACT THE CLAIMS AND NOTICING AGENT.
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 2 of 37

Dated: November 11, 2024
Wilmington, Delaware
/s/ Patrick J. Reilley
COLE SCHOTZ P.C.
KIRKLAND & ELLIS LLP
Patrick J. Reilley (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)
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 720    Filed 11/11/24    Page 3 of 37

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)
)
FIRST AMENDED PLAN SUPPLEMENT
PLEASE TAKE NOTICE THAT on September 30, 2024, the above-captioned debtors
and debtors in possession (collectively, the “Debtors”) filed the Joint Chapter 11 Plan of Vyaire
Medical, Inc. and Its Debtor Affiliates [Docket No. 581] (as modified, amended, or supplemented
from time to time, the “Plan”),2 which Plan was the solicitation version served on parties in
connection with the Order (I) Approving the Adequacy of the Disclosure Statement on an Interim
Basis, (II) Scheduling a Combined Disclosure Statement Approval and Plan Confirmation
Hearing, (III) Approving the Solicitation and Notice Procedures, (IV) Approving the Combined
Hearing Notice, and (V) Granting Related Relief (the “Disclosure Statement Order”).
PLEASE TAKE FURTHER NOTICE THAT attached as (i) Exhibit D-1 is a modified
Schedule of Retained Causes of Action (“Modified Exhibit D”), and (ii) Exhibit D-2 is a redline
of the Schedule of Retained Causes of Action marked against the Modified Schedule D.3
PLEASE TAKE FURTHER NOTICE THAT the the documents contained in this First
Amended Plan Supplement are integral to, and considered part of, the Plan. The documents
contained in this First Amended Plan Supplement will be approved by the Bankruptcy Court
pursuant to the Confirmation Order and in accordance with the terms of the Plan.
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 not otherwise defined herein have the same meaning as set forth in the Plan.
3
For the avoidance of doubt, the Debtors reserve all rights to make modifications to this Plan Supplement and the
exhibits thereof in accordance with the terms of the Plan and Confirmation Order.
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2
Dated: November 11, 2024
Wilmington, Delaware
/s/ Patrick J. Reilley
COLE SCHOTZ P.C.
KIRKLAND & ELLIS LLP
Patrick J. Reilley (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)
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 720    Filed 11/11/24    Page 5 of 37

Exhibit D-1
(Modified Schedule of Retained Causes of Action Attached as Exhibit D to Plan
Supplement)
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EXHIBIT D
SCHEDULE OF RETAINED CAUSES OF ACTION
Article IV(O) of the Joint Chapter 11 Plan of Reorganization of Vyaire Medical, Inc. and
Its Debtor Affiliates, dated September 30, 2024 [Docket No. 581] (as may be amended, modified,
or supplemented, the “Plan”),1 provides that the Retained Causes of Action shall initially remain
with the Debtors and shall immediately vest with the Wind-Down Debtors as of the Effective Date.
Unless otherwise released by the Plan, the Debtors or the Wind-Down Debtors, as
applicable, expressly reserve their rights with respect to all Causes of Action that are not expressly
released under the Plan, including the following:
1.
Avoidance Actions arising under applicable state law and Chapter 5 of the
Bankruptcy Code, including, without limitation, Bankruptcy Code sections 502, 510, 542,
544, 548 through 553 and 724(a), including but not limited to against Quad DBC Holdings
LLC.
2.
Claims against Quad DBC Holdings LLC in connection with lease agreement dated
October 3, 2017, and related letter of credit.
3.
All Causes of Action relating to any and all insurance contracts and insurance
policies to which the Debtors are a party or pursuant to which the Debtors have any rights
whatsoever, regardless of whether such contract or policy is specifically identified in the
Plan, including, without limitation, Causes of Action against insurance carriers,
reinsurance carriers, insurance brokers, underwriters, occurrence carriers, or surety bond
issuers relating to coverage, indemnity, contribution, reimbursement, or any other matters.
Without limiting the generality of the foregoing, the Debtors expressly reserve all Causes
of Action against the Entities identified in Exhibit (D)(i) attached hereto.
4.
All Causes of Action relating to any and all tax obligations to which the Debtors
are a party or pursuant to which the Debtors have any rights whatsoever, including, without
limitation, against or related to all entities that owe or that may in the future owe money
related to tax refunds to the Debtors, regardless of whether such entity is specifically
identified herein.  Without limiting the generality of the foregoing, the Debtors expressly
reserve all Causes of Action, including potential tax refund, reimbursement of
overpayments resulting from ordinary course payments or payments of any filed proofs of
claim, and any rights arising under section 505 of the Bankruptcy Code, against the Entities
identified in Exhibit (D)(ii) attached hereto.
5.
All Causes of Action against or related to all entities (other than Released Parties)
that are party to or that may in the future become party to litigation, arbitration, or any other
type of adversarial proceeding or dispute resolution proceeding, whether formal or
informal, judicial or non-judicial, regardless of whether such entity is specifically identified
in the Plan, except to the extent such entity is a Released Party.   Without limiting the
1 Capitalized terms used herein but not otherwise defined shall have the meaning ascribed to them in the Plan.
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 7 of 37

48640121
generality of the foregoing, the Debtors expressly reserve all Causes of Action against the
Entities identified in Exhibit (D)(iii) attached hereto.
6.
All Causes of Action against or related to all entities (other than Released Parties)
that owe or that may in the future owe money to the Debtors, regardless of whether such
entity is expressly identified in the Plan except to the extent such entity is a Released Party.
The Debtors or the Wind-Down Debtors, as applicable, expressly reserve all Causes of
Action against or related to all entities who assert or may assert that the Debtors owe money
to them.  The claims and Causes of Action reserved include without limitation Causes of
Action against vendors, suppliers of goods and services, customers or any other parties,
except to the extent such party is a Released Party:
a.
for overpayments, back charges, duplicate payments, improper holdbacks,
deductions owing or improper deductions taken, deposits, warranties, guarantees,
indemnities, recoupment, or setoff;
b. for (i) wrongful or improper termination, suspension of services or supply of goods,
or failure to meet other contractual or regulatory obligations; (ii) for failure to fully
perform or to condition performance on additional requirements under contracts
with any one or more of the Debtors before the assumption or rejection, if
applicable, of such contracts; (iii) for payments, deposits, holdbacks, reserves or
other amounts owed by any creditor, utility, supplier, vendor, insurer, surety, factor,
lender, bondholder, lessor or other party; (iv) for any liens, including mechanics’,
artisans’, materialmens’, possessory or statutory liens held by the Debtors; (v) for
counter-claims and defenses related to any contractual obligations; (vi) for any
turnover actions arising under Bankruptcy Code sections 542 or 543; and (vii) for
unfair competition, interference with contract or potential business advantage,
breach of contract, infringement of intellectual property or any business tort claims.
7.
All Causes of Action based in whole or in part upon any and all postings of a
security deposits, adequate assurance payment, or any other type of deposit, prepayment,
or collateral, regardless of whether such posting of security deposit, adequate assurance
payment, or any other type of deposit, prepayment or collateral is specifically identified
herein.
8.
All Causes of Action based in whole or in part upon the enforcement of the terms
of the Sale Transactions Documentation.
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Exhibit D(i)
Legal Entity
Insurance Carrier
Policy Type
Policy Number
Policy
Term
Vyaire Holding Company
Federal Insurance
Company
General Liability
3606-61-89
Annual
Vyaire Holding Company
Federal Insurance
Company
US Auto Liability
(24) 7363-96-04
Annual
Vyaire Holding Company
Chubb National
Insurance Company
Workers’
Compensation
(25) 7183-97-95
Annual
Vyaire Holding Company
Federal Insurance
Company
Commercial Umbrella
5672-07-51
Annual
Vyaire Holding Company
ACE American
Insurance Company
Foreign Auto
PHFD38688571 001
Annual
Vyaire Holding Company
ACE American
Insurance Company
Foreign General
Liability
PHFD38688571 001
Annual
Vyaire Holding Company
ACE American
Insurance Company
Foreign Voluntary
Workers’
Compensation
PHFD38688571 001
Annual
Vyaire Holding Company
LifeScience Risk
Products Liability
LSR-PCO-00539-24
Annual
Vyaire Holding Company
Illinois Union
Insurance Company
Products Liability
XSP G47393942 002
Annual
Vyaire Holding Company
Euclid Life Science
Specialty, LLC
Products Liability
LSS2000275
Annual
Vyaire Holding Company
ProAssurance
Specialty Insurance
Company
Products Liability
EX24IL380003
Annual
Vyaire Holding Company
Ironshore Specialty
Insurance Company
Products Liability
HC7TAB7TUL004
Annual
Vyaire Medical Products Ltd
HDI Global SE – UK
Foreign Products
Liability
110-01164144-14072
Annual
Vyaire Holding Company
Beazley Group
Cyber Liability
W1EFF2220701
Annual
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Legal Entity
Insurance Carrier
Policy Type
Policy Number
Policy
Term
Vyaire Holding Company
Indian Harbor
Insurance Company
Cyber Liability
MTE904194703
Annual
Vyaire Holding Company
National Union Fire
Insurance Company of
Pittsburgh, PA
Crime
1-544-18-54
Annual
Vyaire Holding Company
Great American
Insurance Company
Crime Excess
XSC E776448 02 00
Annual
Vyaire Holding Company
Berkshire Hathaway
Specialty Insurance
Director & Officer
Side A Liability
47-EMC-312437-04
Annual
Vyaire Holding Company
Illinois National
Insurance Co.
Director & Officer
Side A Liability
01-545-03-57
Annual
Vyaire Holding Company
Twin City Fire
Insurance Co.
Director & Officer
Side A Liability
83 PE 0401876-23
Annual
Vyaire Holding Company
Axis Insurance
Company
Director & Officer
Side A Liability
P-001-000712001-03
Annual
Vyaire Holding Company.
ACE American
Insurance Company
Director & Officer
Side A Liability
G71089022 003
Annual
Vyaire Holding Company
Old Republic
Professional Liability,
Inc.
Director & Officer
Side A Liability
ORPRO 13 101883
Annual
Vyaire Holding Company
Midvale Indemnity
Company
Director & Officer
Side A Liability
ACL-144453387-02
Annual
Vyaire Holding Company
Federal Insurance
Company
Fiduciary Liability
J06349456
Annual
Vyaire Holding Company
Federal Insurance
Company
Employment Practices
Liability
J06349456
Annual
Vyaire Holding Company
Illinois National
Insurance Co.
Fiduciary Liability
01-545-03-53
Annual
Vyaire Holding Company
Great American
Insurance Co.
Special Risk
SCI273611442
Annual
Vyaire Holding Company
Allied World
Assurance Company
(U.S.) Inc.
Pollution Liability
0310-3558
Annual
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Legal Entity
Insurance Carrier
Policy Type
Policy Number
Policy
Term
Vyaire Holding Company
Lloyd’s Syndicate
1036 COF
Marine Cargo Liability
B0509MARCW2351091
Annual
Vyaire Holding Company
Lloyd’s Syndicate
No.4472 LIB.
Marine Cargo Liability
B0509MARCW2351092
Annual
Vyaire Holding Company
Federal Insurance
Company
Global Property
3606-61-72 DTO
Annual
Vyaire Holding Company
Starr Surplus Lines
Insurance Company
Global Property
23SSLDOND316061
Annual
Vyaire Holding Company
Princeton Excess and
Surplus Lines
Insurance Company
Global Property
78-A3-XP-0001068-00
Annual
Vyaire Holding Company
Mt. Hawley Insurance
Company
Global Property
MPC0606018
Annual
Vyaire Holding Company
Endurance American
Specialty Insurance
Global Property
ARP30048538600
Annual
Vyaire Holding Company
Lloyd’s of London
Global Property
B0509BOWPN2352774
B0509BOWPN2352775
B0509BOWPN2352776
B0509BOWPN2352777
Annual
Vyaire Holding Company
Lloyd’s of London
Global Property
B0509BOWPN2352776
Annual
Vyaire Holding Company
Ascot Specialty
Insurance Company
Property DIC
UB211270B00463
Annual
Vyaire Holding Company
Princeton Excess and
Surplus Lines
Insurance Company
Property DIC
B2A3IM0003894-00
Annual
Vyaire Holding Company
Allianz Underwriters
Insurance Company
Excess Product Recall
Policy
U5L000088181
Annual
Vyaire Holding Company
Allianz Underwriters
Insurance Company
Excess Product Recall
Policy
U5L000089182
Annual
Vyaire Holding Company
Allianz Underwriters
Insurance Company
Excess Product Recall
Policy
U5L00008819
Annual
Vyaire Holding Company
Allianz Underwriters
Insurance Company
Excess Product Recall
Policy
U5L00008919
Annual
Vyaire Holding Company
Western Specialty
Insurance Services,
Inc.
Second Excess
Product Recall
Insurance
B0509FINSR1800116
Annual
Vyaire Holding Company
Lloyd’s of London
Excess Product Recall
B080131400G19
Annual
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Legal Entity
Insurance Carrier
Policy Type
Policy Number
Policy
Term
Vyaire Holding Company
Westchester Surplus
Lines Insurance
Company
Consumer Goods
Policy
G27961344003
Annual
Vyaire Holding Company
Westchester Surplus
Lines Insurance
Company
Consumer Goods
Policy
G29961344004
Annual
Vyaire Medical, Inc.
North American
Capacity Insurance
Company
Product Recall Quota
Share Policy
PRL 2001744 00
Annual
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Exhibit D(ii)
Taxing Authority
Alabama  - Revenue Discovery Systems
Autauga, Birmingham, Chilton, Clanton, Dale, Dothan, Florence, Hamilton, Henry, Jackson,
Lauderdale, Pike, Scottsboro
City of Montgomery
Alabama - STACS
City of Sheffield
Colbert County
Franklin County
Alabama Department of Revenue
Alabama Department of Revenue
Alaska Department of Revenue
Arizona Department of Revenue
Arizona Department of Revenue
Arkansas Department of Finance & Administration
Ascension Parish Sales and Use Tax Authority
Avoyelles Parish School Board
Baldwin County
Bureau of Revenue & Taxation
Caddo Shreveport Sales & Use Tax Commission
Calcasieu Parish
California Department of Tax and Fee Administration
City of Alabaster
City of Arvada
City of Aurora Revenue Division
City of Baton Rouge Parish of East Baton Rouge
City of Boulder
City of Bremerton
City of Colorado Springs
City of Craig
City of Daphne
City of Durango
City of Englewood
City of Everett
City of Foley Revenue Department
City of Fort Collins
City of Golden
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Taxing Authority
City of Grand Junction
City of Greeley
City of Greenwood Village
City of Gunnison
City of Huntsville
City of Lakewood
City of Lamar
City of Littleton
City of Lone Tree
City of Longmont
City of Longview
City of Mobile
City of Monroe/Ouachita Parish
City of New Orleans
City of Parker
City of Pueblo
City of Seattle
City of Steamboat Springs
City of Thornton
Colorado Department of Revenue
Commerce City Tax Division
Comptroller of Maryland
Connecticut Department of Revenue Services
Cullman County
Dekalb County Revenue Department
Delaware Division of Revenue
Denver Department of Finance
Department of the Treasury
Internal Revenue Service
District of Columbia
District of Columbia
Evangeline Parish Sales/Use Tax Commission
Florida Department of Revenue
Georgia Department of Revenue
Georgia Department of Revenue
Hawaii Department of Taxation
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Taxing Authority
Hawaii Department of Taxation
Iberia Parish School Board Sales & Use Tax Department
Idaho State Tax Commission
Idaho State Tax Commission
Illinois Department of Revenue
Illinois Department of Revenue
Indiana Department of Revenue
Indiana Department of Revenue
Iowa Department of Revenue
Iowa Department of Revenue
Jefferson County Department of Revenue
Kansas Department of Revenue
Kansas Department of Revenue
Kentucky Department of Revenue
Kentucky Revenue Cabinet
Lafayette Parish School System
Lafourche Parish School Board
Lincoln Parish
Louisiana - St. Charles
Louisiana - St. John
Louisiana - St. Landry
Louisiana - St. Mary
Louisiana - St. Tammany
Louisiana - Vernon
Louisiana - Washington
Louisiana - Webster
Louisiana Department of Revenue
Louisiana Department of Revenue
Madison County
Maine Department of Revenue
Maine Revenue Services
Maryland Revenue Administration
Massachusetts Department of Revenue
Massachusetts Department of Revenue
Michigan Department of Treasury
Michigan Department of Treasury
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Taxing Authority
Minnesota Department of Revenue
Minnesota Department of Revenue
Mississippi Department of Revenue
Mississippi Department of Revenue
Missouri Department of Revenue
Missouri Department of Revenue
Mobile County
Montana Department of Revenue
Montgomery County Commission Tax & Audit Department
Nebraska Department of Revenue
Nebraska Department of Revenue
Nevada Department of Taxation
New Hampshire Department of Revenue Administration
New Jersey Division of Taxation
New Jersey Division of Taxation
New Mexico Taxation & Revenue Department
New Mexico Taxation & Revenue Department
New York Department of Taxation and Finance
New York Department of Taxation and Finance
North Carolina Department of Revenue
North Carolina Department of Revenue
North Dakota Office of State Tax Commissioner
North Dakota Office of State Tax Commissioner
Ohio Department of Taxation
Oklahoma Tax Commission
Oklahoma Tax Commission
Oregon Department of Revenue
Oregon Department of Revenue
Parish Of Acadia
Pennsylvania Department of Revenue
Pennsylvania Department of Revenue
Plaquemines Parish
Rapides Parish
Rhode Island Division of Taxation
Rhode Island Division of Taxation
Shelby County Business Revenue Office
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 16 of 37

48640121
Taxing Authority
South Carolina Department of Revenue
South Carolina Department of Revenue
South Dakota Department of Revenue
State of Arkansas
Tennessee Department of Revenue
Tennessee Department of Revenue
Texas Comptroller of Public Accounts
Texas Comptroller of Public Accounts
Utah State Tax Commission
Utah State Tax Commission
Vermont Department of Taxes
Vermont Department of Taxes
Virginia Tax Office of Customer Services
Virginia Tax Office of Customer Services
Washington State Department of Revenue
West Virginia State Tax Department
West Virginia Tax Division
Wisconsin Department of Revenue
Wisconsin Department of Revenue
Wyoming Department of Revenue
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 17 of 37

48640121
Exhibit D(iii)
1. All properties, rights, interests and assets related to or arising out of the following cause of
action: Vyaire Medical Holdings B.V. vs. Florian Kienle, Sonja Kienla, William Franz, Roland
Holtz and Peter Biro, District Court of Hamburg (Germany); Docket No. 313 O 251/19
2. All properties, rights, interests and assets related to or arising out of the following cause of
action: Vyaire Holding Company and Vyaire Medical, Inc. v. Westchester Surplus Lines
Insurance Company, Allianz Underwriters Insurance Company, Lloyd’s of London Syndicate
2003 (aka Caitlin Syndicate Limited and North American Insurance Company), Supreme
Court of the State of New York, County of New York, Index No. 652428/2020 (the.
3. All properties, rights, interests and assets related to or arising out of the following cause of
action and any counterclaims related thereto: Sleep Management LLC (d/b/a VieMed) vs.
Vyaire Medical Inc. (d/b/a CareFusion Respiratory Technologies), Western District of
Louisiana (Lafayette) No. 6:20-cv-00969-MJJ-PJH.
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 18 of 37

Exhibit D-2
(Redline of Retained Causes of Action Attached as Exhibit D to Plan Supplement)
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 19 of 37

48640121
EXHIBIT D
SCHEDULE OF RETAINED CAUSES OF ACTION
Article IV(O) of the Joint Chapter 11 Plan of Reorganization of Vyaire Medical, Inc. and
Its Debtor Affiliates, dated September 30, 2024 [Docket No. 581] (as may be amended,
modified, or supplemented, the “Plan”),1 provides that the Retained Causes of Action shall
initially remain with the Debtors and shall immediately vest with the Wind-Down Debtors as of
the Effective Date.
Unless otherwise released by the Plan, the Debtors or the Wind-Down Debtors, as
applicable, expressly reserve their rights with respect to all Causes of Action that are not
expressly released under the Plan, including the following:
1.
Avoidance Actions arising under applicable state law and Chapter 5 of the
Bankruptcy Code, including, without limitation, Bankruptcy Code sections 502, 510, 542,
544, 547548 through 553 and 724(a), against any party who is not a Released Party and
those entities identified in Exhibit D(i) attached heretoincluding but not limited to
against Quad DBC Holdings LLC.
2.
Claims against Quad DBC Holdings LLC in connection with lease agreement
dated October 3, 2017, and related letter of credit.
3.
2. All Causes of Action relating to any and all insurance contracts and insurance
policies to which the Debtors are a party or pursuant to which the Debtors have any rights
whatsoever, regardless of whether such contract or policy is specifically identified in the
Plan, including, without limitation, Causes of Action against insurance carriers,
reinsurance carriers, insurance brokers, underwriters, occurrence carriers, or surety bond
issuers relating to coverage, indemnity, contribution, reimbursement, or any other
matters.  Without limiting the generality of the foregoing, the Debtors expressly reserve
all Causes of Action against the Entities identified in Exhibit (D)(iii) attached hereto.
4.
3. All Causes of Action relating to any and all tax obligations to which the
Debtors are a party or pursuant to which the Debtors have any rights whatsoever,
including, without limitation, against or related to all entities that owe or that may in the
future owe money related to tax refunds to the Debtors, regardless of whether such entity
is specifically identified herein.  Without limiting the generality of the foregoing, the
Debtors expressly reserve all Causes of Action, including potential tax refund,
reimbursement of overpayments resulting from ordinary course payments or payments of
any filed proofs of claim, and any rights arising under section 505 of the Bankruptcy
Code, against the Entities identified in Exhibit (D)(iiiii) attached hereto.
5.
4. All Causes of Action against or related to all entities (other than Released
Parties) that are party to or that may in the future become party to litigation, arbitration,
or any other type of adversarial proceeding or dispute resolution proceeding, whether
formal or informal, judicial or non-judicial, regardless of whether such entity is
specifically identified in the Plan, except to the extent such entity is a Released Party.
Without limiting the generality of the foregoing, the Debtors expressly reserve all Causes
of Action against the Entities identified in Exhibit (D)(iviii) attached hereto.
1 Capitalized terms used herein but not otherwise defined shall have the meaning ascribed to them in the Plan.
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 20 of 37

6.
5. All Causes of Action against or related to all entities (other than Released
Parties) that owe or that may in the future owe money to the Debtors, regardless of
whether such entity is expressly identified in the Plan except to the extent such entity is a
Released Party.  The Debtors or the Wind-Down Debtors, as applicable, expressly
reserve all Causes of Action against or related to all entities who assert or may assert that
the Debtors owe money to them.  The claims and Causes of Action reserved include
without limitation Causes of Action against vendors, suppliers of goods and services,
customers or any other parties, except to the extent such party is a Released Party:
a.
for overpayments, back charges, duplicate payments, improper holdbacks,
deductions owing or improper deductions taken, deposits, warranties, guarantees,
indemnities, recoupment, or setoff;
b. for (i) wrongful or improper termination, suspension of services or supply of
goods, or failure to meet other contractual or regulatory obligations; (ii) for failure
to fully perform or to condition performance on additional requirements under
contracts with any one or more of the Debtors before the assumption or rejection,
if applicable, of such contracts; (iii) for payments, deposits, holdbacks, reserves or
other amounts owed by any creditor, utility, supplier, vendor, insurer, surety,
factor, lender, bondholder, lessor or other party; (iv) for any liens, including
mechanics’, artisans’, materialmens’, possessory or statutory liens held by the
Debtors; (v) for counter-claims and defenses related to any contractual
obligations; (vi) for any turnover actions arising under Bankruptcy Code sections
542 or 543; and (vii) for unfair competition, interference with contract or potential
business advantage, breach of contract, infringement of intellectual property or
any business tort claims.
7.
6. All Causes of Action based in whole or in part upon any and all postings of a
security deposits, adequate assurance payment, or any other type of deposit, prepayment,
or collateral, regardless of whether such posting of security deposit, adequate assurance
payment, or any other type of deposit, prepayment or collateral is specifically identified
herein.
8.
7. All Causes of Action based in whole or in part upon the enforcement of the
terms
of
the
Sale
Transactions
Documentation.
48640121
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48640121
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 22 of 37

[Link-to-previous setting changed from on in original to off in modified.].
[Link-to-previous setting changed from on in original to off in modified.].
48640121
AUTOMATIC DATA PROCESSING INC
AMERICAN CRATING
AVNET, INC.
Exhibit D(i)
BAY CORPORATION
ANA CONCHEIRO GUISAN
AGILITI HEALTH, INC.
BCP SYSTEMS INC.
ADVANCED MOTION CONTROLS
BMW PRECISION MACHINING INC
ANALYTICAL INDUSTRIES INC.
BRENNER-FIEDLER & ASSOC.
BSI GROUP AMERICA INC
ANTON VAN KAAM
AIRGAS USA LLC
CDW COMPUTER CENTERS
CEVA LOGISTICS
APPEXTREMES LLC
CHEMTREC
CIWIT BV
APPLE RUBBER PRODUCTS
ALL SEALS INC
CLAYTON CONTROLS
ADVANCED PRINTING
CLEO COMMUNICATIONS US, LLC
ARTIQ NV
COGNITIVE CONSULTING LLC
ACCENT PLASTICS INC
COGNIZANT TECHNOLOGY SOLUTIONS US C
ASCENSION HEALTH RESOURCE AND SUPPLY MANAGEMENT GROUP, LLC
ALLIED ELECTRONICS
CONNEXIO HEALTH LLC
COPPER & BRASS SALES
ASSURED PARTNERS CAPITAL INC
CORPORATION SERVICE COMPANY
COVINGTON & BURLING LLP
AT&T MOBLILITY II LLC
AMAZON WEB SERVICES INC
CULLIGAN WATER CONDITIONING
AEROTEK INC
DA/PRO RUBBER INC
AUGUSTA HITECH SOFT SOLUTIONS LLC
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 23 of 37

[Link-to-previous setting changed from on in original to off in modified.].
[Link-to-previous setting changed from on in original to off in modified.].
48640121
FLEXIM US CORP
DELL MARKETING LP
E & S PRECISION SHEETMETAL MFG INC
FOOD AND DRUG ADMINISTRATION
FORTE DGTL LLC
EDWARD A ROSE
FRAGOMEN, DEL REY, BERNSEN & LOEWY
FREYR INC
DELL REALTY COMPANY
EIS, INC. FILE 98059
FRONTIER COMMUNICATIONS CORPORATION
DANIELE DELUCA
GE HEALTH CARE
EMERGO GLOBAL REPRESENTATION LLC
GENERANT
DAWAR TECHNOLOGIES
GISPATH INC
DEPARTMENT OF LABOR AND INDUSTRIES
ENDICOTT RESEARCH GROUP INC
GRAINGER
GREATBATCH MEDICAL
ENHESA INC
HAYNES AND BOONE LLP
HEALTH CANADA
DEXTER RESEARCH, INC.
EPM PROS INC
HEALTHTRUST PURCHASING GROUP LP
HEIDRICK & STRUGGLES INC
EUROFINS ELECTRICAL &
HOGAN LOVELLS US LLP
DEEL INC
HOUSE OF BATTERIES
DIGI-KEY CORP. 55348
EXETER 6201 GLOBAL DISTRIBUTION
HUGHES,R.S.,CO.INC.
HYMAN PHELPS & MCNAMARA PC
FEDEX GROUND PACKAGE SYSTEM
ILI INFODISK
IN SITU TRAINING SA
DYMAX CORP
FERMISH CLINICAL TECHNOLOGIES
INDUSTRIAL HEARING & PULMONARY
DAVID M LEWIS COMPANY LLC
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 24 of 37

[Link-to-previous setting changed from on in original to off in modified.].
[Link-to-previous setting changed from on in original to off in modified.].
48640121
MH CUSTOM DESIGN & MFG LC.
KENNETH JOSEPH ORR
LORI ANNE VOSSLER-YANG
MICROSOFT CORPORATION
MMA SECURITIES LLC
MARLEE MFG.
MOOG COMPONENTS GROUP, INC
MOUSER ELECTRONICS
KEY INSTRUMENTS
MARY C TROUT
MSC INDUSTRIAL SUPPLY CO. INC.
INNOVATIVE DISCOVERY LLC
NEWARK CORPORATION
MASTER BOND, INC
NEXGEN DIGITAL
ITD CORPORATION
NORTHWELL HEALTH
KILMAINHAM
MAXTEC
NUMATIC ENGINEERING
OCEAN STATE STAINLESS, INC.
MCKESSON MEDICAL-SURGICAL SUPPLY
OHIO BUREAU OF WORKERS'
ORANGE COAST PNEUMATICS
KPMG LLP
MCMASTER-CARR SUPPLY CO.
OXFORD GLOBAL RESOURCES LLC
PALM SPRINGS PLATING
MEGAN STOPEK
PARKER HANNIFIN - PORTER DIVISION
JABIL CIRCUIT (SHANGHAI) LTD.
PARKER MEDICAL SYSTEMS DIVISION
KYLE PROUGH (KYOTE CREATIVE)
MER MAR, INC.
PATENTBURO PAUL ROSENICH AG
PAX INDUSTRIES
MESSNER REEVES LLP
PEAK TECHNICAL SERVICES INC
PENTAIR FILTRATION SOLUTIONS LLC
LINKLATERS LLP
METALPRO INDUSTRIES
PHOTOMACHINING
INSIGHT
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 25 of 37

[Link-to-previous setting changed from on in original to off in modified.].
[Link-to-previous setting changed from on in original to off in modified.].
48640121
SILMATES PRIVATE LTD
PRECISION METAL PROCESSING INC.
RAINER KUEHNER
SIMCO ELECTRONICS
SPARK DSG LLC
REAL STAFFING GROUP
SPIRACLE TECHNOLOGY
STAR EXHIBITS & ENVIRONMENTS INC
PREETY TULI
RESTRUCTURING PARTNERS & ASSO LLC
SUPERIOR SPRING CO
PINNACLE PRECISION SHEET METAL CORP
T C I PRECISION METALS
RINGCENTRAL INC
TALX CORP
PORZIO COMPLIANCE SERVICES, LLC
TAW ELECTRONICS INC
PREMIER HEALTHCARE ALLIANCE LP
SAFETY-KLEEN
TDS UNLIMITED INC
TECH-ETCH
SALESFORCE.COM INC
TELEDYNE ANALYTICAL INSTRUMENTS
TESTEQUITY, INC
PRESIDIO HOLDINGS INC
SCHMIDT BIOMED SDN BHD
THE WEST GROUP
THERM-O-NAMEL, INC.
SCHROFF INC
THIEME CORPORATION
PRECISION MEDICAL
THOMAS E BACHMAN
PRN STAFFING
SEBASTIAN MASANET
TICIC SUB LLC
T-MOBILE USA, INC.
SELCO PRODUCTS
TOMASZ SZCZAPA
TOOLING EXPRESS INC
QOSINA CORP.
SIEMENS INDUSTRY SOFTWARE INC
TPI - CUSTOM SOLUTIONS
PLANFUL INC
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 26 of 37

[Link-to-previous setting changed from on in original to off in modified.].
[Link-to-previous setting changed from on in original to off in modified.].
48640121
ULINE SHIPPING SUPPLIES
VAN DOORNE N V
TRADE TECHNOLOGIES INC
VENDORMATE INC
TRANSPERFECT TRANSLATIONS
UNITED AD LABEL (RR DONNELLY)
VERA ROSAS REGISTRO E LEGALIZACAO
VERITIV OPERATING COMPANY
UNITED FOAM TECHNOLOGIES
VERTEX INC
VIZIENT INC
TRICON
UPS SUPPLY CHAIN SOLUTIONS INC
WAGEWORKS INC
WEBER PRECISION GRAPHICS
VACUMETRICS INC / VACUMED DIV.
WILLIAM W STRINGER MD
TRANSITIONS INSTITUTE INC
WOLFE PROCUREMENT INC
TRU-FORM PLASTICS INC.
VALUATION RESEARCH CORPORATION
YUSEN LOGISTICS AMERICAS INC
ZENSAR TECHNOLOGIES INC
VALUE PLASTICS
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 27 of 37

[Link-to-previous setting changed from on in original to off in modified.].
[Link-to-previous setting changed from on in original to off in modified.].
48640121
Annual
(25) 7183-97-95
Policy Type
Vyaire Holding Company
Annual
LifeScience Risk
3606-61-89
Products Liability
LSR-PCO-00539-24
Annual
Vyaire Holding Company
Annual
Vyaire Holding Company
Federal Insurance
Company
Illinois Union
Insurance Company
Policy Number
Products Liability
Commercial Umbrella
XSP G47393942 002
Annual
5672-07-51
Vyaire Holding Company
Annual
Euclid Life Science
Specialty, LLC
Vyaire Holding Company
Products Liability
LSS2000275
Policy
Term
Annual
Vyaire Holding Company
Federal Insurance
Company
Vyaire Holding Company
ACE American
Insurance Company
ProAssurance
Specialty Insurance
Company
Legal Entity
Products Liability
Foreign Auto
EX24IL380003
US Auto Liability
Annual
PHFD38688571 001
Vyaire Holding Company
Annual
Ironshore Specialty
Insurance Company
(24) 7363-96-04
Products Liability
HC7TAB7TUL004
Annual
Vyaire Holding Company
Annual
Vyaire Medical Products Ltd
ACE American
Insurance Company
HDI Global SE – UK
Vyaire Holding Company
Foreign Products
Liability
Foreign General
Liability
110-01164144-14072
Annual
PHFD38688571 001
Insurance Carrier
Vyaire Holding Company
Annual
Beazley Group
Vyaire Holding Company
Cyber Liability
W1EFF2220701
Federal Insurance
Company
Annual
Vyaire Holding Company
Chubb National
Insurance Company
Vyaire Holding Company
ACE American
Insurance Company
Indian Harbor
Exhibit D(ii)
Cyber Liability
Foreign Voluntary
Workers’
Compensation
MTE904194703
Workers’
Compensation
Annual
PHFD38688571 001
General Liability
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[Link-to-previous setting changed from on in original to off in modified.].
[Link-to-previous setting changed from on in original to off in modified.].
48640121
Annual
Vyaire Holding Company
Vyaire Holding Company
Berkshire Hathaway
Specialty Insurance
Old Republic
Professional Liability,
Inc.
Director & Officer
Side A Liability
Director & Officer
Side A Liability
ORPRO 13 101883
Annual
47-EMC-312437-04
Vyaire Holding Company
Annual
Midvale Indemnity
Company
Vyaire Holding Company
Director & Officer
Side A Liability
ACL-144453387-02
Policy Type
Annual
Vyaire Holding Company
National Union Fire
Insurance Company of
Pittsburgh, PA
Vyaire Holding Company
Illinois National
Insurance Co.
Federal Insurance
Company
Fiduciary Liability
Director & Officer
Side A Liability
J06349456
Crime
Annual
01-545-03-57
Policy Number
Vyaire Holding Company
Annual
Federal Insurance
Company
1-544-18-54
Employment Practices
Liability
J06349456
Legal Entity
Annual
Vyaire Holding Company
Annual
Vyaire Holding Company
Twin City Fire
Insurance Co.
Illinois National
Insurance Co.
Policy
Term
Fiduciary Liability
Director & Officer
Side A Liability
01-545-03-53
Annual
83 PE 0401876-23
Vyaire Holding Company
Annual
Great American
Insurance Co.
Vyaire Holding Company
Special Risk
SCI273611442
Annual
Vyaire Holding Company
Great American
Insurance Company
Vyaire Holding Company
Axis Insurance
Company
Allied World
Assurance Company
(U.S.) Inc.
Pollution Liability
Director & Officer
Side A Liability
0310-3558
Crime Excess
Annual
P-001-000712001-03
Insurance Carrier
Vyaire Holding Company
Annual
Lloyd’s Syndicate
1036 COF
XSC E776448 02 00
Marine Cargo Liability
B0509MARCW2351091
Insurance Company
Annual
Vyaire Holding Company.
Annual
Vyaire Holding Company
ACE American
Insurance Company
Lloyd’s Syndicate
Marine Cargo Liability
Director & Officer
Side A Liability
B0509MARCW2351092
Annual
G71089022 003
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[Link-to-previous setting changed from on in original to off in modified.].
[Link-to-previous setting changed from on in original to off in modified.].
48640121
Ascot Specialty
Insurance Company
Property DIC
Global Property
UB211270B00463
Annual
78-A3-XP-0001068-00
Vyaire Holding Company
Annual
Princeton Excess and
Surplus Lines
Insurance Company
Vyaire Holding Company
Property DIC
B2A3IM0003894-00
Policy Type
Annual
Vyaire Holding Company
Federal Insurance
Company
Vyaire Holding Company
Mt. Hawley Insurance
Company
Allianz Underwriters
Insurance Company
Excess Product Recall
Policy
Global Property
U5L000088181
Global Property
Annual
MPC0606018
Policy Number
Vyaire Holding Company
Annual
Allianz Underwriters
Insurance Company
3606-61-72 DTO
Excess Product Recall
Policy
U5L000089182
Legal Entity
Annual
Vyaire Holding Company
Annual
Vyaire Holding Company
Endurance American
Specialty Insurance
Allianz Underwriters
Insurance Company
Policy
Term
Excess Product Recall
Policy
Global Property
U5L00008819
Annual
ARP30048538600
Vyaire Holding Company
Annual
Allianz Underwriters
Insurance Company
Vyaire Holding Company
Excess Product Recall
Policy
U5L00008919
Annual
Vyaire Holding Company
Starr Surplus Lines
Insurance Company
Vyaire Holding Company
Lloyd’s of London
Western Specialty
Insurance Services,
Inc.
Second Excess
Product Recall
Insurance
Global Property
B0509FINSR1800116
Global Property
Annual
B0509BOWPN2352774
B0509BOWPN2352775
B0509BOWPN2352776
B0509BOWPN2352777
Insurance Carrier
Vyaire Holding Company
Annual
Lloyd’s of London
23SSLDOND316061
Excess Product Recall
B080131400G19
No.4472 LIB.
Annual
Vyaire Holding Company
Annual
Vyaire Holding Company
Lloyd’s of London
Westchester Surplus
Lines Insurance
Company
Consumer Goods
Policy
Global Property
G27961344003
Annual
B0509BOWPN2352776
Vyaire Holding Company
Annual
Westchester Surplus
Lines Insurance
Company
Vyaire Holding Company
Consumer Goods
Policy
G29961344004
Annual
Vyaire Holding Company
Princeton Excess and
Surplus Lines
Insurance Company
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[Link-to-previous setting changed from on in original to off in modified.].
48640121
Insurance Carrier
Vyaire Medical, Inc.
North American
Capacity Insurance
Company
Policy Type
Product Recall Quota
Share Policy
PRL 2001744 00
Policy Number
Annual
Legal Entity
Policy
Term
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 31 of 37

48640121
Calcasieu Parish
Taxing Authority
California Department of Tax and Fee Administration
Arizona Department of Revenue
City of Alabaster
City of Arvada
Arizona Department of Revenue
Alabama - STACS
City of Sheffield
Colbert County
Franklin County
City of Aurora Revenue Division
City of Baton Rouge Parish of East Baton Rouge
Arkansas Department of Finance & Administration
City of Boulder
Exhibit D(iiiii)
City of Bremerton
Ascension Parish Sales and Use Tax Authority
Alabama Department of Revenue
City of Colorado Springs
Alabama  - Revenue Discovery Systems
Autauga, Birmingham, Chilton, Clanton, Dale, Dothan, Florence, Hamilton, Henry, Jackson,
Lauderdale, Pike, Scottsboro
City of Craig
Avoyelles Parish School Board
City of Daphne
City of Durango
Baldwin County
Alabama Department of Revenue
City of Englewood
City of Everett
Bureau of Revenue & Taxation
City of Foley Revenue Department
City of Fort Collins
Caddo Shreveport Sales & Use Tax Commission
Alaska Department of Revenue
City of Golden
City of Montgomery
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 32 of 37

48640121
City of Greenwood Village
City of Littleton
City of Steamboat Springs
City of Thornton
City of Lone Tree
Colorado Department of Revenue
City of Grand Junction
Commerce City Tax Division
City of Gunnison
City of Longmont
Comptroller of Maryland
Connecticut Department of Revenue Services
City of Longview
Cullman County
Dekalb County Revenue Department
City of Huntsville
City of Mobile
Delaware Division of Revenue
Taxing Authority
Denver Department of Finance
City of Monroe/Ouachita Parish
Department of the Treasury
Internal Revenue Service
City of Greeley
District of Columbia
City of Lakewood
City of New Orleans
District of Columbia
Evangeline Parish Sales/Use Tax Commission
City of Parker
Florida Department of Revenue
Georgia Department of Revenue
City of Lamar
City of Pueblo
Georgia Department of Revenue
Hawaii Department of Taxation
City of Seattle
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 33 of 37

48640121
Indiana Department of Revenue
Lincoln Parish
Louisiana - St. Charles
Iowa Department of Revenue
Louisiana - St. John
Hawaii Department of Taxation
Louisiana - St. Landry
Idaho State Tax Commission
Iowa Department of Revenue
Louisiana - St. Mary
Louisiana - St. Tammany
Jefferson County Department of Revenue
Louisiana - Vernon
Louisiana - Washington
Illinois Department of Revenue
Kansas Department of Revenue
Louisiana - Webster
Taxing Authority
Louisiana Department of Revenue
Kansas Department of Revenue
Louisiana Department of Revenue
Iberia Parish School Board Sales & Use Tax Department
Madison County
Illinois Department of Revenue
Kentucky Department of Revenue
Maine Department of Revenue
Maine Revenue Services
Kentucky Revenue Cabinet
Maryland Revenue Administration
Massachusetts Department of Revenue
Indiana Department of Revenue
Lafayette Parish School System
Massachusetts Department of Revenue
Michigan Department of Treasury
Lafourche Parish School Board
Michigan Department of Treasury
Idaho State Tax Commission
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 34 of 37

48640121
Montana Department of Revenue
New York Department of Taxation and Finance
New York Department of Taxation and Finance
Montgomery County Commission Tax & Audit Department
North Carolina Department of Revenue
Minnesota Department of Revenue
North Carolina Department of Revenue
Mississippi Department of Revenue
Nebraska Department of Revenue
North Dakota Office of State Tax Commissioner
North Dakota Office of State Tax Commissioner
Nebraska Department of Revenue
Ohio Department of Taxation
Oklahoma Tax Commission
Missouri Department of Revenue
Nevada Department of Taxation
Oklahoma Tax Commission
Taxing Authority
Oregon Department of Revenue
New Hampshire Department of Revenue Administration
Oregon Department of Revenue
Minnesota Department of Revenue
Parish Of Acadia
Missouri Department of Revenue
New Jersey Division of Taxation
Pennsylvania Department of Revenue
Pennsylvania Department of Revenue
New Jersey Division of Taxation
Plaquemines Parish
Rapides Parish
Mobile County
New Mexico Taxation & Revenue Department
Rhode Island Division of Taxation
Rhode Island Division of Taxation
New Mexico Taxation & Revenue Department
Shelby County Business Revenue Office
Mississippi Department of Revenue
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 35 of 37

48640121
State of Arkansas
Utah State Tax Commission
Vermont Department of Taxes
Tennessee Department of Revenue
Vermont Department of Taxes
Taxing Authority
Virginia Tax Office of Customer Services
South Carolina Department of Revenue
Tennessee Department of Revenue
Virginia Tax Office of Customer Services
Washington State Department of Revenue
Texas Comptroller of Public Accounts
West Virginia State Tax Department
West Virginia Tax Division
South Dakota Department of Revenue
Texas Comptroller of Public Accounts
Wisconsin Department of Revenue
Wisconsin Department of Revenue
Utah State Tax Commission
Wyoming Department of Revenue
South Carolina Department of Revenue
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 36 of 37

Exhibit D(iviii)
1. All properties, rights, interests and assets related to or arising out of the following cause of
action: Vyaire Medical Holdings B.V. vs. Florian Kienle, Sonja Kienla, William Franz,
Roland Holtz and Peter Biro, District Court of Hamburg (Germany); Docket No. 313 O
251/19
2. All properties, rights, interests and assets related to or arising out of the following cause of
action: Vyaire Holding Company and Vyaire Medical, Inc. v. Westchester Surplus Lines
Insurance Company, Allianz Underwriters Insurance Company, Lloyd’s of London Syndicate
2003 (aka Caitlin Syndicate Limited and North American Insurance Company), Supreme
Court of the State of New York, County of New York, Index No. 652428/2020 (the.
3. All properties, rights, interests and assets related to or arising out of the following cause of
action and any counterclaims related thereto: Sleep Management LLC (d/b/a VieMed) vs.
Vyaire Medical Inc. (d/b/a CareFusion Respiratory Technologies), Western District of
Louisiana (Lafayette) No. 6:20-cv-00969-MJJ-PJH.
48640121
Case 24-11217-BLS    Doc 720    Filed 11/11/24    Page 37 of 37

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