Subject: re: Vyaire - Vyaire Medical Sale Order - Trudell - Surety Bonds;for settlement

Summary

Exhibit C to the First Stipulation of Facts Between Plan Administrator and Hartford Fire Insurance Company in the Vyaire Medical bankruptcy, Case 24-11217-BLS, Doc 1141-3, filed 11/17/25, reproducing an email chain about Hartford surety bonds. According to the emails, Matthew Repetto of Crowell & Moring LLP wrote on behalf of Trudell Medical on December 4, 2024 seeking a resolution over the bonds. Gary D. Bressler, counsel for Hartford, replied that continued use of its bonds for the buyers without Hartford's consent violated the sale orders and that Trudell would need to go through underwriting and sign an indemnity agreement. He raised the same requirement for Zoll. Repetto confirmed that Trudell agreed in principle and followed up on December 20, 2024.

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Full text

Exhibit C – December 3, 2024 Email Chain
First Stipulation of Facts
Between
Plan Administrator and
Hartford Fire Insurance Company

Case 24-11217-BLS    Doc 1141-3    Filed 11/17/25    Page 1 of 5

1
Percontino, Matteo
From:
Repetto, Matthew <MRepetto@crowell.com>
Sent:
Friday, December 20, 2024 12:41 PM
To:
Gary D. Bressler
Cc:
Michael R. Morano; Percontino, Matteo
Subject:
RE: Vyaire - Vyaire Medical Sale Order - Trudell - Surety Bonds;for settlement
discussions only
Hi Gary, Following up on the below. Available to discuss if needed. Matthew Repetto Pronouns: he/ him/his Crowell & M
 External email

Hi Gary,

Following up on the below. Available to discuss if needed.

Matthew Repetto
Pronouns: he/him/his
Crowell & Moring LLP
mrepetto@crowell.com
+1.212.895.4209 direct

From: Repetto, Matthew
Sent: Monday, December 9, 2024 10:37 AM
To: Gary D. Bressler <gbressler@mdmc-law.com>
Cc: Michael R. Morano <mmorano@mdmc-law.com>; Percontino, Matteo <MPercontino@coleschotz.com>
Subject: RE: Vyaire - Vyaire Medical Sale Order - Trudell - Surety Bonds;for settlement discussions only

Hi Gary,

Thank you for the email below. I am reaching out to confirm that Trudell has agreed in principle with the steps outlined
below and has asked that you share the form of indemnity agreement for our review and consideration.

Thank you!
Matthew Repetto
Pronouns: he/him/his
Crowell & Moring LLP
mrepetto@crowell.com
+1.212.895.4209 direct

From: Gary D. Bressler <gbressler@mdmc-law.com>
Sent: Friday, December 6, 2024 4:05 PM
To: Repetto, Matthew <MRepetto@crowell.com>
Cc: Michael R. Morano <mmorano@mdmc-law.com>; Percontino, Matteo <MPercontino@coleschotz.com>
Subject: RE: Vyaire - Vyaire Medical Sale Order - Trudell - Surety Bonds;for settlement discussions only

Mathew Thank you for taking the time to speak to me today. As I have explained to Matteo and you, it is Hartfor d’s position that the continued use of its bonds for the benefit of the buyers without Hartford’s consent is in violation of the sales
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Case 24-11217-BLS    Doc 1141-3    Filed 11/17/25    Page 2 of 5

2
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Mathew

Thank you for taking the time to speak to me today. As I have explained to Matteo and you, it is Hartford’s
position that the continued use of its bonds for the benefit of the buyers without Hartford’s consent is in
violation of the sales orders. . To the extent that Trudell wants the bonds to stay in place for their benefit,
your client would have to work out an agreement satisfactory to Hartford.(assuming Hartford is
amenable to any agreement) The first step would be for your client to go through underwriting. In order to
initiate this process we would ask that your client reach out to the broker. My understanding is that the
broker is Mary Y. Volmer at Marsh whose direct number is 865 7697766 and whose mobile number is
8654379639. Mary’s email address is mary.y.volmar@marsh.com

Finally, our client is insistent that Trudell sign an indemnity agreement while it is going through the
underwriting process and our client’s bonds remain exposed . We would appreciate it is you would let us
know by the end of Monday if Trudell is ok in principle with this and if so , my law partner Michael Morano
will send over a form of agreement.

Matteo

You indicated that Zoll has said it does not think it needs the bonds but it is checking. However, does not
Zoll need the Debtors licensed in Maryland, Nevada and/or California to perform under their transition
agreement  with Zoll. If so, Zoll is benefiting from the bonds continued exposure and our client requires
the same things of Zoll as it does of Trudell.

Thanks. As is customary for our client, our client reserves all claims ,rights and defenses.

To help
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Gary D. Bressler
Partner
300 Delaware Avenue
Suite 1014
Wilmington, Delaware 19801
gbressler@mdmc-law.com
T: 302-300-4508 F: 302-654-4031
mdmc-law.com
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Case 24-11217-BLS    Doc 1141-3    Filed 11/17/25    Page 3 of 5

3
The information contained in this message is intended only for the personal and confidential use of the designated recipients named above. This message may be an
attorney-client communication, and as such is privileged and confidential. If the reader of this message is not the intended recipient, you are hereby notified that you have
received this document in error and that any review, dissemination, distribution or copying of this message is strictly prohibited. If you have received this communication in
error, please notify us immediately by reply e-mail message or by telephone and delete the original message from your e-mail system and/or computer database.
From: Repetto, Matthew <MRepetto@crowell.com>
Sent: Friday, December 6, 2024 3:13 PM
To: Gary D. Bressler <gbressler@mdmc-law.com>
Cc: Michael R. Morano <mmorano@mdmc-law.com>
Subject: RE: Vyaire - Vyaire Medical Sale Order - Trudell - Surety Bonds

This message originated from outside your organization
Hi Gary,

My apologies, I was tied up most of the day. I am free at 3:30pm if that time works for you. Let me know!

Matthew Repetto
Pronouns: he/him/his
Crowell & Moring LLP
mrepetto@crowell.com
+1.212.895.4209 direct

From: Gary D. Bressler <gbressler@mdmc-law.com>
Sent: Thursday, December 5, 2024 1:41 PM
To: Repetto, Matthew <MRepetto@crowell.com>
Cc: Michael R. Morano <mmorano@mdmc-law.com>
Subject: Re: Vyaire - Vyaire Medical Sale Order - Trudell - Surety Bonds

Would 3 pm tomorrow work for a call ? Gary D. Bressler Partner 300 Delaware Avenue Suite 1014 Wilmingt on , Delaware 19801 gbressler@ mdmc-law. com T: 302-300-4508 F: 302-654-4031 mdmc-law. com The information contained in this message is i ntended
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You may not have corresponded with this sender before. Exercise caution when engaging with this email.
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Would 3 pm tomorrow work for a call ?

To help protect your priv acy, Microsoft Office prevented automatic download of this picture from the Internet.
Gary D. Bressler
Partner
300 Delaware Avenue
Suite 1014
Wilmington, Delaware 19801
gbressler@mdmc-law.com
T: 302-300-4508 F: 302-654-4031
mdmc-law.com
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Case 24-11217-BLS    Doc 1141-3    Filed 11/17/25    Page 4 of 5

4
The information contained in this message is intended only for the personal and confidential use of the designated recipients named above. This message may be an
attorney-client communication, and as such is privileged and confidential. If the reader of this message is not the intended recipient, you are hereby notified that you have
received this document in error and that any review, dissemination, distribution or copying of this message is strictly prohibited. If you have received this communication in
error, please notify us immediately by reply e-mail message or by telephone and delete the original message from your e-mail system and/or computer database.
From: Repetto, Matthew <MRepetto@crowell.com>
Date: Wednesday, December 4, 2024 at 11:11 PM
To: Gary D. Bressler <gbressler@mdmc-law.com>
Subject: Vyaire - Vyaire Medical Sale Order - Trudell - Surety Bonds
This message originated from outside your organization
Hi Gary,

I am reaching out on behalf of Trudell Medical in connection with the Hartford surety bonds listed below. Hoping to
discuss an appropriate and prompt resolution. Please let me know if it is best to discuss via telephone, and if so, please
provide your availability this week or early next week. Thank you!

Matthew Repetto
Pronouns: he/him/his
mrepetto@crowell.com
+1.212.895.4209 direct
LinkedIn
Crowell & Moring LLP
Two Manhattan West
375 Ninth Avenue
New York, NY 10001
Crowell
Collaboration Powers Success
crowell.com
This message may contain privileged and confidential information. IF IT WAS SENT TO YOU BY MISTAKE, DO NOT READ IT. Instead, please notify the sender
(or postmaster@crowell.com) by reply e-mail, and delete this e-mail. Unauthorized dissemination, forwarding or copying of this e-mail is strictly prohibited.
Case 24-11217-BLS    Doc 1141-3    Filed 11/17/25    Page 5 of 5

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