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IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE
)
In re:
)
Chapter 11
)
VYAIRE MEDICAL, INC.1
)
Case No. 24-11217 (BLS)
)
Liquidating Debtor.
)
)
)
Re: Docket No. 1058
CERTIFICATE OF NO OBJECTION REGARDING PLAN ADMINISTRATOR’S (I)
FIRST MOTION TO EXTEND THE CLAIMS OBJECTION DEADLINE AND (II)
SECOND MOTION TO EXTEND THE ADMINISTRATIVE
CLAIMS OBJECTION DEADLINE
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 received to the Plan Administrator’s
(I) First Motion to Extend the Claims Objection Deadline and (II) Second Motion to Extend the
Administrative Claims Objection Deadline [Docket No. 1058] (the “Motion”) filed with the United
States Bankruptcy Court for the District of Delaware (the “Court”) on April 8, 2025. Pursuant to
the notice of Motion, objections to the Motion were to be filed and served no later than April 22,
2025 at 4:00 p.m. (ET) (the “Objection Deadline”). The undersigned further certifies that the
Objection Deadline has passed, the Court’s docket has been reviewed in this case, and no answer,
objection, or other responsive pleading to the Motion appears thereon. It is hereby respectfully
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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 600, Wilmington,
DE 19801.
Case 24-11217-BLS Doc 1073 Filed 04/23/25 Page 1 of 2
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requested that the Court enter the proposed order attached to the Motion at the earliest convenience
of the Court.
Dated: April 23, 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 600
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 1073 Filed 04/23/25 Page 2 of 2