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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)
)
Liquidating Debtor.
)
)
Re: Docket No. 977
CERTIFICATE OF NO OBJECTION REGARDING THE PLAN ADMINISTRATOR’S
SECOND OMNIBUS OBJECTION (NON-SUBSTANTIVE) TO CERTAIN CLAIMS
(AMENDED/SUPERSEDED AND LATE FILED)
The undersigned counsel to David M. Barse, the plan administrator (the “Plan
Administrator”) in the above-captioned chapter 11 case, hereby certifies that, as of the date hereof,
no answer, objection, or other responsive pleading has been filed or received to the Plan
Administrator’s
Second
Omnibus
Objection
(Non-Substantive)
to
Certain
Claims
(Amended/Superseded and Late Filed) [Docket No. 977] (the “Objection”) filed with the United
States Bankruptcy Court for the District of Delaware (the “Court”) on January 27, 2025.
Responses to the Objection were to be filed and served no later than February 26, 2025 at 4:00
p.m. (ET) (the “Response Deadline”).
The Response Deadline has passed, and no responses or other responsive pleading to the
Objection appear on the docket or were served upon the undersigned counsel. It is therefore
respectfully requested that the Court enter the proposed order attached to the Objection at the
earliest convenience of the Court.
1
This chapter 11 case is now being administered by the Plan Administrator pursuant to the terms of the Findings
of Fact, Conclusions of Law, and Order Approving the Debtors’ Disclosure Statement for, and Confirming the
Second Amended Joint Chapter 11 Plan of Vyaire Medical, Inc. and Its Debtor Affiliates Pursuant to Chapter 11
of the Bankruptcy Code [Docket No. 745]. The Plan Administrator’s mailing address is Vyaire Medical, Inc.,
Attn: David M. Barse, Plan Administrator, c/o Cole Schotz P.C., 500 Delaware Avenue, Suite 1410, Wilmington,
DE 19801.
Case 24-11217-BLS Doc 999 Filed 02/27/25 Page 1 of 2
2
Dated: February 27, 2025
Wilmington, Delaware
/s/ Patrick J. Reilley
COLE SCHOTZ P.C.
Patrick J. Reilley (No. 4451)
Stacy L. Newman (No. 5044)
500 Delaware Avenue, Suite 1410
Wilmington, Delaware 19801
Telephone:
(302) 652-3131
Facsimile:
(302) 652-3117
Email:
preilley@coleschotz.com
snewman@coleschotz.com
- and -
Michael D. Sirota, Esq. (admitted pro hac vice)
Warren A. Usatine, Esq (admitted pro hac vice)
Matteo Percontino, Esq. (admitted pro hac vice)
Court Plaza North, 25 Main Street
Hackensack, New Jersey 07601
Telephone:
(201) 489-3000
Facsimile:
(201) 489-1536
Email:
msirota@coleschotz.com
wusatine@coleschotz.com
mpercontino@coleschotz.com
Counsel to the Plan Administrator
Case 24-11217-BLS Doc 999 Filed 02/27/25 Page 2 of 2