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Revised Salesforce Vyaire Request for Payment v2

Date
2025-01-13

Summary

A notice of motion filed December 27, 2024 as Doc 893-1 in the jointly administered Chapter 11 cases of Vyaire Medical, Inc., et al., Case No. 24-11217 (BLS), in the U.S. Bankruptcy Court for the District of Delaware. The notice states that Salesforce Inc. filed its Motion for Allowance and Payment of Administrative Expense Claim on December 27, 2024. It sets an objection deadline of 4:00 p.m. (prevailing Eastern Time) on January 13, 2025, and states that if an objection is properly filed and served, a hearing will be held before Judge J. Kate Stickles on January 29, 2025 at 10:30 a.m. It warns that the court may grant the relief without further notice or hearing if no response is made. The two-page notice is signed by White and Williams LLP, with Bialson, Bergen & Schwab also listed in the signature block as attorneys for Creditor Salesforce, Inc.

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Full text

                  Case 24-11217-BLS              Doc 893-1         Filed 12/27/24         Page 1 of 2


                          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)

                                                                     Objection Deadline:
                                                                     January 13, 2025 at 4:00 p.m. (ET)

                                                                     Hearing Date:
                                                                     January 29, 2025 at 10:30 a.m. (ET)

                 NOTICE OF MOTION FOR ALLOWANCE AND PAYMENT OF
                 ADMINISTRATIVE EXPENSE CLAIM OF SALESFORCE, INC.

        PLEASE TAKE NOTICE that on December 27, 2024, Salesforce Inc. (“Salesforce”)
filed the Motion for Allowance and Payment of Administrative Expense Claim of Salesforce Inc.
(the “Motion”).

        PLEASE TAKE FURTHER NOTICE that any objections or responses to the Motion
must be (i) in writing and filed with the Clerk of the United States Bankruptcy Court for the District
of Delaware, 824 Market Street, 3rd Floor, Wilmington, Delaware 19801 on or before 4:00 p.m.
(prevailing Eastern Time) on January 13, 2025, (the “Objection Deadline”) and (ii) served on,
so as to be received by, the undersigned counsel to Salesforce on or before the Objection Deadline.

       PLEASE TAKE FURTHER NOTICE that if an objection is properly filed and served, a
hearing will be held before the Honorable J. Kate Stickles, United States Bankruptcy Judge, in the
United States Bankruptcy Court for the District of Delaware, 824 North Market Street, 3rd Floor,
Courtroom #1, Wilmington, Delaware 19801 on January 29, 2025, at 10:30 a.m. (prevailing
Eastern Time).

    IF YOU FAIL TO RESPOND IN ACCORDANCE WITH THIS NOTICE, THE
COURT MAY GRANT THE RELIEF REQUESTED IN THE MOTION WITHOUT
FURTHER NOTICE OR HEARING.




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, along with the last four digits of their U.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.


34174224v.2
              Case 24-11217-BLS   Doc 893-1     Filed 12/27/24   Page 2 of 2


Dated: 12/27/2024                 WHITE AND WILLIAMS LLP

                                      /s/ Rochelle Gumapac
                                      Rochelle Gumapac. Esq. (No. 4866)
                                      Michael A. Ingrassia (No. 7068)
                                      600 North King Street, Suite 800
                                      Wilmington, DE 19801
                                      Phone: 302-467-4503
                                      Fax: 302-467-4550
                                      Email: gumapacr@whiteandwilliams.com
                                      ingrassiam@whiteandwilliams.com

                                      - and -

                                      Amy E. Vulpio
                                      1650 Market Street, Suite 1800
                                      Philadelphia, PA 19103
                                      Telephone: (215) 864-6250
                                      Fax: (215) 789-7550
                                      Email: vulpioa@whiteandwilliams.com

                                      and-


                                      BIALSON, BERGEN & SCHWAB,
                                      A Professional Corporation
                                      Gaye Nell Heck, Esq.
                                      830 Menlo Avenue, Suite 201
                                      Menlo Park, CA 94025
                                      Telephone: (650) 857-9500
                                      Fax: (650) 494-2738
                                      E-mail: Gheck@bbslaw.com

                                      Attorneys for Creditor Salesforce, Inc.




                                        -2-

34174224v.2


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