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Motion Of Zensar Technologies Inc. For Entry

Date
2024-10-31

Summary

A Certification of Counsel filed November 8, 2024 as Doc 716 in In re Vyaire Medical, Inc., Case No. 24-11217 (BLS), in the U.S. Bankruptcy Court for the District of Delaware, regarding the motion Zensar Technologies Inc. filed on October 31, 2024 at Docket No. 699. That motion sought an order compelling assumption or rejection of executory contracts and allowing and compelling payment of administrative expenses. Counsel certifies that the response deadline was November 7, 2024, that Zensar received informal comments from the Debtors, and that no objection appears on the docket. It states that Zensar and the Debtors reached an agreement, attaches an agreed proposed order as Exhibit A and a blackline as Exhibit B, and asks the Court to enter the agreed proposed order. It is signed by Stanley B. Tarr of Blank Rome LLP as counsel to Zensar.

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Full text

                 Case 24-11217-BLS              Doc 716       Filed 11/08/24         Page 1 of 2




                        IN THE UNITED STATES BANKRUPTCY COURT
                             FOR THE DISTRICT OF DELAWARE

In re:                                               Chapter 11

VYAIRE MEDICAL, Inc.,1                               Case No. 24-11217 (BLS)

                               Debtor.               Re: Docket No. 699

                   CERTIFICATION OF COUNSEL REGARDING
              MOTION OF ZENSAR TECHNOLOGIES INC. FOR ENTRY
                 OF AN ORDER (I) COMPELLING ASSUMPTION OR
           REJECTION OF EXECUTORY CONTRACTS AND (II) ALLOWING
         ADMINISTRATIVE EXPENSES AND COMPELLING PAYMENT THEREOF

The undersigned hereby certifies as follows:

          1.      On October 31, 2024, Zensar Technologies Inc. (“Zensar”) filed the Motion of

Zensar Technologies Inc. for Entry of an Order (I) Compelling Assumption or Rejection of

Executory Contracts and (II) Allowing Administrative Expenses and Compelling Payment Thereof

[Docket No. 699] (the “Motion”). Pursuant to the notice of hearing attached to the Motion, the

deadline to file objections or responses to the approval of the Motion was November 7, 2024 at

4:00 p.m. (ET) (the “Response Deadline”).

          2.      Prior to the Response Deadline, Zensar received informal comments from the

Debtors. No other formal or informal responses to the Motion were received. The undersigned

further certifies that he has caused to be performed a review of the Court’s docket in these cases

and no objection or response to the Motion appears thereon.




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.
                                                          1
              Case 24-11217-BLS         Doc 716     Filed 11/08/24   Page 2 of 2




       3.      Zensar and the Debtors have reached an agreement to consensually resolve the

Motion. Attached hereto as Exhibit A is an agreed proposed form of order (the “Agreed Proposed

Order”) reflecting such agreement. Attached hereto as Exhibit B is a blackline of the Agreed

Proposed Order marked against the form of order filed with the Motion.

       4.      Zensar and the Debtors consent to entry of the Agreed Proposed Order. Prior to

submitting this certification, the parties circulated a copy of the Agreed Proposed Order to the

Official Committee of Unsecured Creditors, the United States Trustee, and the DIP Lenders, and

received no opposition to entry of the Agreed Proposed Order.

       WHEREFORE, Zensar respectfully requests entry of the Agreed Proposed Order attached

hereto as Exhibit A at the earliest convenience of the Court.



Dated: November 8, 2024                      BLANK ROME LLP
Wilmington, Delaware
                                             /s/ Stanley B. Tarr
                                             Stanley B. Tarr (DE No. 5535)
                                             Lawrence R. Thomas III (DE No. 6935)
                                             Jordan L. Williams (DE No. 7128)
                                             1201 N. Market Street, Suite 800
                                             Wilmington, Delaware 19801
                                             Telephone: (302) 425-6400
                                             Facsimile:      (302) 425-6464
                                             Email:          stanley.tarr@blankrome.com
                                                             lorenzo.thomas@blankrome.com
                                                             jordan.williams@blankrome.com

                                             Counsel to Zensar Technologies Inc.




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