Vyaire - CNO to AP Service Application for Completion Fee

Summary

A Certificate of No Objection regarding the Application of AP Services, LLC for Approval of Completion Fee [Docket No. 795], filed December 16, 2024 as Doc 843 in Case No. 24-11217 (BLS), the jointly administered Chapter 11 cases of Vyaire Medical, Inc., et al., in the U.S. Bankruptcy Court for the District of Delaware. Counsel to the Debtors certifies that no answer, objection or other responsive pleading to the application, filed November 22, 2024, has been received and that the objection deadline of December 13, 2024 has passed. It requests entry of the proposed order attached to the application as Exhibit C. The signature block names Patrick J. Reilley of Cole Schotz P.C.

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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. 795
CERTIFICATE OF NO OBJECTION REGARDING APPLICATION
OF AP SERVICES, LLC FOR APPROVAL OF COMPLETION FEE
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 Application of AP Services, LLC for Approval of Completion Fee [Docket No. 795]
(the “Application”) filed with the United States Bankruptcy Court for the District of Delaware
(the “Court”) on November 22, 2024.  Pursuant to the notice of Application, objections to the
Application were to be filed and served no later than December 13, 2024, at 4:00 p.m. (prevailing
Eastern Time) (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 responsive pleading to the Application appears thereon.  It is hereby respectfully requested
that the Court enter the proposed order attached to the Application as Exhibit C at the earliest
convenience of the Court.
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 843    Filed 12/16/24    Page 1 of 2

2
Dated: December 16, 2024
Wilmington, Delaware
/s/ Patrick J. Reilley
COLE SCHOTZ P.C.
KIRKLAND & ELLIS LLP
Patrick J. Reilley (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 843    Filed 12/16/24    Page 2 of 2

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