Lyons-Vyaire - Mt for Relief from Stay v1
- Date
- 2024-11-14
Summary
A notice of motion filed October 1, 2024 as Doc 589-1 in the jointly administered Chapter 11 cases of Vyaire Medical, Inc., et al., Case Nos. 24-11217 (BLS), et seq., in the U.S. Bankruptcy Court for the District of Delaware. It gives notice that Jeffrey Paul Lyons, II, as administrator of an estate, has filed a Motion for Relief From The Automatic Stay. The motion seeks relief to prosecute litigation under non-bankruptcy law against one or more of the debtors over an incident that occurred on January 1, 2021 and involved a ventilator, including pursuing available insurance proceeds. Responses are due by October 18, 2024 at 4:00 P.M. and the hearing is set for November 14, 2024 at 1:30 p.m. The three-page notice is signed by Adam Hiller of Hiller Law, LLC, with Morgan & Morgan also listed as attorneys for the movant.
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Full text
Case 24-11217-BLS Doc 589-1 Filed 10/01/24 Page 1 of 3
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
Chapter 11
In re
Case Nos. 24-11217 (BLS), et seq.
VYAIRE MEDICAL, INC., et al.,1
(Jointly Administered)
Debtors.
Hearing Date: November 14, 2024, 1:30 p.m.
Objections Due By: October 18, 2024
NOTICE OF MOTION
TO: Parties listed on the Certificate of Service
Jeffrey Paul Lyons, II, as Administrator of the Estate of Connita Shontell
Ransom, (“Movant”) has filed a Motion for Relief From The Automatic Stay (the
“Motion”), which seeks the following relief: Relief from the automatic stay to
prosecute litigation under applicable non-bankruptcy law against one or more of the
above-captioned debtors for claims arising from an incident that occurred on January
1, 2021 involving an LTV 1150 ventilator and minor child J.D.B., including but not
limited to pursuing available insurance proceeds.
HEARING ON THE MOTION WILL BE HELD ON NOVEMBER 14,
2024 AT 1:30 P.M. PREVAILING EASTERN TIME.
You are required to file a response, if any, on or before October 18, 2024 at
4:00 P.M. Prevailing Eastern Time. At the same time, you must also serve a copy of
the response upon Movant’s attorneys:
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 589-1 Filed 10/01/24 Page 2 of 3
Adam Hiller, Esquire Steven Nauman, Esquire
Hiller Law, LLC Morgan & Morgan
300 Delaware Avenue 20 North Orange Avenue, Suite 1600,
Suite 210, #227 Orlando, FL 32801
Wilmington, Delaware 19801 (407) 244-3962 telephone
(302) 442-7677 telephone snauman@forthepeople.com
ahiller@adamhillerlaw.com
The hearing date specified above may be a preliminary hearing or may be
consolidated with the final hearing, as determined by the Court.
The attorneys for the parties shall confer with respect to the issues raised by the
motion in advance for the purpose of determining whether a consent judgment may be
entered and/or for the purpose of stipulating to relevant facts such as value of the
property, and the extent and validity of any security instrument.
IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE,
THE RELIEF REQUESTED IN THE MOTION MAY BE GRANTED BY THE
COURT WITHOUT FURTHER NOTICE OR HEARING.
Dated: October 1, 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
-and-
-2-
Case 24-11217-BLS Doc 589-1 Filed 10/01/24 Page 3 of 3
Steven Nauman, Esquire
Morgan & Morgan
20 North Orange Avenue, Suite 1600,
Orlando, FL 32801
(407) 244-3962 telephone
snauman@forthepeople.com
Attorneys for Movant, Jeffrey Paul Lyons, II
-3-
File and source
- File
- gov.uscourts.deb.193283.589.1.pdf
- Size
- 133,312 bytes
- SHA-256
- d11bfb31db740b7eba9f0233893d1e7634ad8d7c82a16bff004dfc953e784a9b
- Original
- PACER (login required)