Exhibit B, Declaration of Joel Amico, First Omnibus Objection to Section 503(b)(9) Claims — Vyaire Medical

Summary

Joel Amico, a Director with AP Services, LLC, signed this declaration on January 27, 2025; it was filed as Exhibit B (Doc 976-3) in support of the Plan Administrator's First Omnibus Objection (Substantive) to Certain Section 503(b)(9) Claims in the Chapter 11 cases of Vyaire Medical, Inc., et al., Case No. 24-11217 (BLS) in the District of Delaware. He states that the Plan Administrator retained AP Services as a consultant to help reconcile claims filed against the debtors' estates and wind down the cases under the Plan and Confirmation Order, and that he has more than 20 years of experience in the restructuring industry. He declares that he and staff under his direction reviewed the proofs of claim listed on Schedules 1 through 4 to the Proposed Order and determined that each should be disallowed, expunged, modified, reduced or reclassified as set out there.

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Case 24-11217-BLS   Doc 976-3   Filed 01/27/25   Page 1 of 3




                      EXHIBIT B

                    Amico Declaration
                  Case 24-11217-BLS             Doc 976-3         Filed 01/27/25       Page 2 of 3




                          IN THE UNITED STATES BANKRUPTCY COURT
                               FOR THE DISTRICT OF DELAWARE

                                                              )
In re:                                                        )        Chapter 11
                                                              )
VYAIRE MEDICAL, INC., et al.,                                 )        Case No. 24-11217 (BLS)
                                                              )
                             Debtors.                         )        (Jointly Administered)
                                                              )
                                                              )

                DECLARATION OF JOEL AMICO OF AP SERVICES, LLC
        IN SUPPORT OF PLAN ADMINISTRATOR’S FIRST OMNIBUS OBJECTION
               (SUBSTANTIVE) TO CERTAIN SECTION 503(B)(9) CLAIMS

           I, Joel Amico, pursuant to section 1746 of title 28 of the United States Code, hereby

declare that the following is true and correct to the best of my knowledge, information and

belief:

           1.       I am a Director with AP Services, LLC (“AP Services”). AP Services was

retained by the Plan Administrator as a consultant to, among other things, assist with the

reconciliation of claims filed against the Debtors’ estates and facilitate the wind-down of the

Debtors’ cases pursuant to the Plan and Confirmation Order. I have more than 20 years of

experience in the restructuring industry, including many years of providing consulting and

advisory services in both pre-confirmation and post-confirmation chapter 11 cases.

           2.       I submit this declaration (the “Declaration”) in support of the Plan

Administrator’s First Omnibus Objection (Substantive) to Certain Section 503(b)(9) Claims (the

“Objection”), filed contemporaneously herewith.1 I am over the age of 18, competent to testify

and authorized to submit the Declaration on behalf of the Plan Administrator.




1
    Capitalized terms not defined herein have the meanings ascribed to them in the Objection.
             Case 24-11217-BLS         Doc 976-3      Filed 01/27/25    Page 3 of 3




       3.      Every matter set forth herein is based on (a) my personal knowledge and

experience as a Director with AP Services and an authorized representative of the Plan

Administrator, (b) my review, or the review of work performed by other AP Services consultants

whom I oversee in a managerial capacity, of relevant documents, and/or (c) my understanding

based on information obtained from the Debtors’ books and records.

       4.      I have read and reviewed the Objection, including the information set forth on

Schedules 1 through 4 to the Proposed Order, and I am familiar with the information contained

in those documents.

       5.      To the best of my knowledge, information and belief, the information that is

contained in the Objection is true and correct.

       6.      I, and/or one or more individuals at AP Services working under my direction,

have reviewed the Debtors’ books and records and proofs of claim listed on Schedule 1 through

4 to the Proposed Order, together with any supporting documentation attached thereto, made

reasonable efforts to research the Disputed Claims in the Debtors’ books and records and have

determined each claim should be disallowed, expunged, modified, reduced, or reclassified, as

applicable, for the reasons and in the manner set forth on Schedules 1 through 4.

       I declare under penalty of perjury that the foregoing is true and correct to the best of my

knowledge, information and belief.


Dated: January 27, 2025
                                              /s/ Joel Amico
                                              JOEL AMICO




                                                  2


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