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Vyaire - Second Non-Substantive Omnibus Claims Objection to 503b9 Claims (Amended and Superseded and Late Filed)

Date
2025-01-27

Summary

Exhibit A, a proposed order granting and sustaining the Plan Administrator's Second Omnibus Objection (Non-Substantive) to Certain Claims, filed January 27, 2025 as Doc 977-2 in In re Vyaire Medical, Inc., et al., Case No. 24-11217 (BLS), in the U.S. Bankruptcy Court for the District of Delaware. The proposed order would disallow and expunge each amended or superseded claim on Schedule 1 and each late filed claim on Schedule 2, and directs the claims agent Omni Agent Solutions, Inc. to revise the claims register. Schedule 1 lists two claims superseded by later claims, including Claim No. 22 totaling $114,729.28. Schedule 2 lists five claims filed after the General Bar Date of 8/2/2024, including Claim No. 206 for $19,204.32. The order reserves the right to object to the listed claims on other grounds.

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Full text

Case 24-11217-BLS   Doc 977-2   Filed 01/27/25   Page 1 of 6




                      EXHIBIT A

                     Proposed Order
                 Case 24-11217-BLS              Doc 977-2         Filed 01/27/25       Page 2 of 6




                          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)
                                                              )
                                                              )        Re: Docket No. __

       ORDER GRANTING AND SUSTAINING PLAN ADMINISTRATOR’S SECOND
         OMNIBUS OBJECTION (NON-SUBSTANTIVE) TO CERTAIN CLAIMS

          Upon consideration of the Plan Administrator’s Second Omnibus Objection (Non-

Substantive) to Certain Claims (the “Objection”);1 and the Court having jurisdiction over this core

proceeding under 28 U.S.C. §§ 157 and 1334; and venue of this matter in the District of

Delaware being proper under 28 U.S.C. §§ 1408 and 1409; and the Court having reviewed the

Objection, the Disputed Claims listed on Schedule 1 and Schedule 2 hereto, the Declaration of

Joel Amico of AP Services, LLC in support of the Objection, any responses to the Objection,

and any replies to those responses; and due notice of the Objection having been provided; and

the relief sought by the Objection being in the best interests of the Debtors, the Debtors’

creditors and all other parties in interest; and after due deliberation thereon and good and

sufficient cause appearing therefor, it is hereby

ORDERED, ADJUDGED AND DECREED THAT:

          1.       The Objection is GRANTED to the extent set forth herein.

          2.       Each Amended/Superseded Claim listed on Schedule 1 hereto is hereby

disallowed and expunged in its entirety.




1
    Capitalized terms not defined herein shall have the meanings ascribed to the terms in the Objection.
              Case 24-11217-BLS          Doc 977-2      Filed 01/27/25     Page 3 of 6




        3.      Each Late Filed Claim listed on Schedule 2 hereto is hereby disallowed and

expunged in its entirety.

        4.      The Plan Administrator is authorized to take any action necessary or appropriate

to give effect to this Order and the relief granted therein.

        5.      Omni Agent Solutions, Inc., the Court-appointed claims and noticing agent in the

chapter 11 cases, is hereby authorized and directed to make such revisions to the official claims

register as are necessary to reflect the relief granted in this Order.

        6.      The Plan Administrator, the Debtors and their estates, any successors thereto and

any other party in interest shall retain and shall have the right to object in the future to any of the

claims listed on Schedules 1 and 2 on any additional grounds, and the Plan Administrator shall

retain and shall have the right to amend, modify and/or supplement the Objection as may be

necessary.

        7.      The Plan Administrator’s objection to each Disputed Claim addressed in the

Objection constitutes a separate contested matter as contemplated by Bankruptcy Rule 9014.

This Order shall be deemed a separate order with respect to each Disputed Claim. Any stay of

this Order pending appeal by any of the claimants subject to this Order shall only apply to the

contested matter which involves such claimant and shall not act to stay the applicability and/or

finality of this Order with respect to the other contested matters covered hereby.

        8.      This Order is without prejudice rights of the Plan Administrator, the Debtors’

estates, any successors thereto and any other party in interest to object to any other proof of

claim filed in the chapter 11 cases.




                                                   2
             Case 24-11217-BLS        Doc 977-2     Filed 01/27/25    Page 4 of 6




       9.     The Court shall retain jurisdiction over the claimants whose claims are subject to

the Objection with respect to any matter arising from or related to the Objection or this Order,

including the interpretation, enforcement and implementation of this Order.




                                               3
                                                                    Case 24-11217-BLS                      Doc 977-2           Filed 01/27/25                 Page 5 of 6
                                                                                                           SCHEDULE 1
                                                                                            AMENDED/SUPERSEDED CLAIMS
                                                    Objection Key
            (Sec)- Secured
            (Adm)- Administrative
            (503)- 503(b)(9)
            (Pri)- Priority
            (GUC)- Non-Priority General Unsecured
            (Tot)- Total Claim



                                                                                                              Amended /
                                                                          Debtor Against
                                                                                         Surviving Claim      Superseded      Surviving Claim Amount &
Item No.                      Claimant Name                 Case Number   Whom Claim is                                                                                     Reason for Disallowance
                                                                                               No.            Claim to be       Classification Status
                                                                              Filed
                                                                                                              Disallowed
                                                                          Vyaire Medical                                    (Sec)-
    1       Da/Pro Rubber Inc.                            24-11217                             116                22                  $            -
                                                                               Inc.
                                                                                                                            (Adm)-    $            -
                                                                                                                            (503)-    $       4,350.00
                                                                                                                                                         Claim No. 22 has been amended and superseded by Claim No. 116.
                                                                                                                            (Pri)-    $            -
                                                                                                                            (GUC)-    $     110,379.28
                                                                                                                            (Tot)-    $     114,729.28


                                                                          Vyaire Medical                                    (Sec)-
    2       Newark Corporation                            24-11217                             152                34                  $            -
                                                                               Inc.
                                                                                                                            (Adm)-    $            -
                                                                                                                            (503)-    $      32,000.00
                                                                                                                                                         Claim No. 34 has been amended and superseded by Claim No. 152.
                                                                                                                            (Pri)-    $            -
                                                                                                                            (GUC)-    $     336,749.80
                                                                                                                            (Tot)-    $     368,749.80




68877/0001-49192355v2
                                                         Case 24-11217-BLS                       Doc 977-2                Filed 01/27/25                  Page 6 of 6
                                                                                                          SCHEDULE 2
                                                                                                     LATE FILED CLAIMS
                                                   Objection Key
           (Sec)- Secured
           (Adm)- Administrative
           (503)- 503(b)(9)
           (Pri)- Priority
           (GUC)- Non-Priority General Unsecured
           (Tot)- Total Claim




                                                                                                                  Claim    Claim Amount & Classification Adjusted Classification Status
Item No.                     Claimant Name         Claim Date Filed     Case Number   Debtor Against Whom Claim                                                                                         Reason for Disallowance
                                                                                                                   No.               Status                       & Amount
                                                                                                is Filed
    1      3MD Relocation Services, LLC                      8/27/2024 24-11217           Vyaire Medical Inc.      170    (Sec)-       $             -   (Sec)-       $            -
                                                                                                                          (Adm)-       $             -   (Adm)-       $            -
                                                                                                                          (503)-       $        2,004.50 (503)-       $            -
                                                                                                                          (Pri)-       $             -   (Pri)-       $            -      Claim No. 170 was filed on 8/27/2024, which was after
                                                                                                                          (GUC)-                         (GUC)-       $            -      the General Bar Date, 8/2/2024.
                                                                                                                          (Tot)-       $        2,004.50 (Tot)-       $            -


    2      John L. O'Donahue, VMD, PhD, DABT                12/17/2024 24-11217           Vyaire Medical Inc.      215    (Sec)-       $             -   (Sec)-       $            -
                                                                                                                          (Adm)-       $             -   (Adm)-       $            -
                                                                                                                          (503)-       $        7,260.00 (503)-       $            -
                                                                                                                          (Pri)-       $             -   (Pri)-       $            -      Claim No. 215 was filed on 12/17/2024, which was
                                                                                                                          (GUC)-                         (GUC)-       $            -      after the General Bar Date, 8/2/2024.
                                                                                                                          (Tot)-       $        7,260.00 (Tot)-       $            -


    3      McKinley Equipment Corporation                    8/28/2024 24-11217           Vyaire Medical Inc.      171    (Sec)-       $             -   (Sec)-       $            -
                                                                                                                          (Adm)-       $             -   (Adm)-       $            -
                                                                                                                          (503)-       $        1,191.63 (503)-       $            -
                                                                                                                          (Pri)-       $             -   (Pri)-       $            -      Claim No. 171 was filed on 8/28/2024, which was after
                                                                                                                          (GUC)-       $        4,381.43 (GUC)-       $            -      the General Bar Date, 8/2/2024.
                                                                                                                          (Tot)-       $        5,573.06 (Tot)-       $            -


    4      Qmedic W.L.L.                                     8/31/2024 24-11217           Vyaire Medical Inc.      174    (Sec)-       $             -   (Sec)-       $            -
                                                                                                                          (Adm)-       $             -   (Adm)-       $            -
                                                                                                                          (503)-       $        4,989.95 (503)-       $            -
                                                                                                                          (Pri)-       $             -   (Pri)-       $            -      Claim No. 174 was filed on 8/31/2024, which was after
                                                                                                                          (GUC)-       $             -   (GUC)-       $            -      the General Bar Date, 8/2/2024.
                                                                                                                          (Tot)-       $        4,989.95 (Tot)-       $            -


    5      Trademark Plastics, Inc.                         11/12/2024 24-11217           Vyaire Medical Inc.      206    (Sec)-       $             -   (Sec)-       $            -
                                                                                                                          (Adm)-       $             -   (Adm)-       $            -
                                                                                                                          (503)-       Blank             (503)-       $            -
                                                                                                                                                                                          Claim No. 206 was filed on 11/12/2024, which was
                                                                                                                          (Pri)-       $             -   (Pri)-       $            -
                                                                                                                                                                                          after the General Bar Date, 8/2/2024.
                                                                                                                          (GUC)-       $       19,204.32 (GUC)-       $            -
                                                                                                                          (Tot)-       $       19,204.32 (Tot)-       $            -




68877/0001-49192355v2


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