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Vyaire - Third Omnibus Claims Objection to Claims (Non-Substantive Tax - Duplicate and Late Filed)

Date
2025-05-08

Summary

Doc 1081-2, filed May 8, 2025 in In re Vyaire Medical, Inc., Case No. 24-11217 (BLS), a Chapter 11 case in the U.S. Bankruptcy Court for the District of Delaware, is Exhibit A, a proposed order granting and sustaining the Plan Administrator's Third Omnibus Objection (Non-Substantive) to Certain Claims. The proposed order would disallow and expunge the duplicate claims on Schedule 1, the late filed claims on Schedule 2 and the insufficient documentation claims on Schedule 3, and directs Omni Agent Solutions, Inc. to revise the claims register. Schedule 1 lists seven duplicate claims, including claims by the Georgia Department of Revenue and the Texas Comptroller of Public Accounts. Schedule 2 lists six claims described as filed after the applicable bar dates, and Schedule 3 lists one claim by Owens & Minor Distribution, Inc. The document is 12 pages.

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Full text

              Case 24-11217-BLS   Doc 1081-2   Filed 05/08/25   Page 1 of 12




                                     EXHIBIT A

                                    Proposed Order




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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.
                                                          )

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

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

Substantive) to Certain Claims (the “Objection”);2 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, Schedule 2, and Schedule 3 hereto, the

Amico Declaration, 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 Duplicate Claim listed on Schedule 1 hereto is hereby disallowed and

expunged in its entirety.


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 “Confirmation Order”). 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.



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

expunged in its entirety.

          4.       Each Insufficient Documentation Claim listed on Schedule 3 hereto is hereby

disallowed and expunged in its entirety.

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

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

          6.       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.

          7.       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, 2, and 3 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.

          8.       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.

          9.       This Order is without prejudice to the 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
    Capitalized terms not defined herein shall have the meanings ascribed to the terms in the Objection.
                                                           2
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         10.      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
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                                      Schedule 1

                                   Duplicate Claims




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                                                                                                                     SCHEDULE 1
                                                                                                                DUPLICATE CLAIMS
            Objection Key
            (Sec)- Secured
            (Adm)- Administrative
            (503)- 503(b)(9)
            (Pri)- Priority
            (GUC)- Non-Priority General Unsecured
            (Tot)- Total Claim




                                                                                                                               Duplicate
                                                                            Debtor Against Whom Claim    Remaining Claim                    Remaining Claim Amount &
Item No.                      Claimant Name                   Case Number                                                     Claim to be                                                    Reason for Disallowance
                                                                                      is Filed              Number                            Classification Status
                                                                                                                              Disallowed
     1      GE Medical Systems Information Technologies, Inc.24-11217       Vyaire Medical, Inc.               220                219       (Sec)-   $           -
                                                                                                                                            (Adm)-   $    174,315.60
                                                                                                                                            (503)-   $           -
                                                                                                                                            (Pri)-   $           -   Claim No. 219 is duplicative of Claim No. 220.
                                                                                                                                            (GUC)-   $           -
                                                                                                                                            (Tot)-   $    174,315.60

     2      Georgia Department of Revenue                  24-11223         SensorMedics Corporation             3                 2        (Sec)-   $           -
                                                                                                                                            (Adm)-   $           -
                                                                                                                                            (503)-   $           -
                                                                                                                                            (Pri)-   $    584,533.55 Claim No. 2 is duplicative of Claim No. 3.
                                                                                                                                            (GUC)-   $     41,957.05
                                                                                                                                            (Tot)-   $    626,490.60

     3      Greatbatch Medical                             24-11217         Vyaire Medical, Inc.               119                147       (Sec)-   $            -
                                                                                                                                            (Adm)-   $            -
                                                                                                                                                                        Claim No. 147 is duplicative of Claim No. 119. Claim No. 119 was
                                                                                                                                            (503)-   $            -
                                                                                                                                                                        previously reclassified pursuant to the Order Granting and Sustaining
                                                                                                                                            (Pri)-   $            -
                                                                                                                                                                        Plan Administrator's First Omnibus Objection (Substantive) to
                                                                                                                                            (GUC)-   $   2,579,488.00
                                                                                                                                                                        Certain Section 503(b)(9) Claims [ Docket No. 1001].
                                                                                                                                            (Tot)-   $   2,579,488.00

     4      NM Taxation & Revenue Department               24-11231         Vyaire Medical 203, Inc.            18                15        (Sec)-   $            -
                                                                                                                                            (Adm)-   $            -
                                                                                                                                            (503)-   $            -
                                                                                                                                                                        Claim No. 15 is duplicative of Claim No. 14, which was subsequently
                                                                                                                                            (Pri)-   $            -
                                                                                                                                                                        amended by Claim No. 18.
                                                                                                                                            (GUC)-   $            -
                                                                                                                                            (Tot)-   $            -


     5      Texas Comptroller of Public Accounts           24-11217         Vyaire Medical, Inc.                 8                177       (Sec)-   $           -
                                                                                                         Case No. 24-11229                  (Adm)-   $           -
                                                                                                                                                                        The Debtors' books and records indicate that Claim No. 177 is a
                                                                                                                                            (503)-   $           -
                                                                                                                                                                        duplicate claim made under a different debtor entity. The surviving
                                                                                                                                            (Pri)-   $    166,689.48
                                                                                                                                                                        claim is Claim No. 8 filed against Vyaire Holding Company in case
                                                                                                                                            (GUC)-   $      7,501.03
                                                                                                                                                                        number 24-11229.
                                                                                                                                            (Tot)-   $    174,190.51


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                                                                                                                     Duplicate
                                                                  Debtor Against Whom Claim    Remaining Claim                    Remaining Claim Amount &
Item No.                   Claimant Name            Case Number                                                     Claim to be                                                   Reason for Disallowance
                                                                            is Filed              Number                            Classification Status
                                                                                                                    Disallowed

     6      Texas Comptroller of Public Accounts   24-11230       Vyaire Medical 202, Inc.             8                 3        (Sec)-   $           -
                                                                                               Case No. 24-11229                  (Adm)-   $           -
                                                                                                                                                             The Debtors' books and records indicate that Claim No. 177 is a
                                                                                                                                  (503)-   $           -
                                                                                                                                                             duplicate claim made under a different debtor entity. The surviving
                                                                                                                                  (Pri)-   $    166,689.48
                                                                                                                                                             claim is Claim No. 8 filed against Vyaire Holding Company in case
                                                                                                                                  (GUC)-   $      7,501.03
                                                                                                                                                             number 24-11229.
                                                                                                                                  (Tot)-   $    174,190.51


     7      Texas Comptroller of Public Accounts   24-11231       Vyaire Medical 203, Inc.             8                11        (Sec)-   $           -
                                                                                               Case No. 24-11229                  (Adm)-   $           -
                                                                                                                                                             The Debtors' books and records indicate that Claim No. 177 is a
                                                                                                                                  (503)-   $           -
                                                                                                                                                             duplicate claim made under a different debtor entity. The surviving
                                                                                                                                  (Pri)-   $    166,689.48
                                                                                                                                                             claim is Claim No. 8 filed against Vyaire Holding Company in case
                                                                                                                                  (GUC)-   $      7,501.03
                                                                                                                                                             number 24-11229.
                                                                                                                                  (Tot)-   $    174,190.51




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                                      Schedule 2

                                   Late Filed Claims




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                                                                                                                 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 Amount & Classification Adjusted Classification Status
Item No.                      Claimant Name        Claim Date Filed     Case Number   Debtor Against Whom Claim      Claim No.                                                                                 Reason for Disallowance
                                                                                                                                            Status                       & Amount
                                                                                                is Filed
    1      Hogan Lovells US LLP                              1/27/2025 24-11217       Vyaire Medical, Inc.             239       (Sec)-      $             -   (Sec)-        $            -
                                                                                                                                 (Adm)-      $        9,183.50 (Adm)-        $            -
                                                                                                                                 (503)-                         (503)-       $            -
                                                                                                                                 (Pri)-      $             -    (Pri)-       $            -      Claim No. 239 was filed on 1/27/2025, which was after
                                                                                                                                 (GUC)-                         (GUC)-       $            -      the Administrative Claims Bar Date, 12/27/2024.
                                                                                                                                 (Tot)-      $        9,183.50 (Tot)-        $            -


    2      Mitchell Barthelemy                               9/13/2024 24-11217       Vyaire Medical, Inc.             181       (Sec)-      $             -    (Sec)-       $            -
                                                                                                                                 (Adm)-      $             -    (Adm)-       $            -
                                                                                                                                 (503)-      $             -    (503)-       $            -
                                                                                                                                 (Pri)-      $        6,593.72 (Pri)-        $            -      Claim No. 181 was filed on 9/13/2024 which was after
                                                                                                                                 (GUC)-                         (GUC)-       $            -      the General Bar Date, 8/2/2024.
                                                                                                                                 (Tot)-      $        6,593.72 (Tot)-        $            -


    3      TDOR                                             12/18/2024 24-11217       Vyaire Medical, Inc.             216       (Sec)-      $             -    (Sec)-       $            -
                                                                                                                                 (Adm)-      $             -    (Adm)-       $            -
                                                                                                                                 (503)-                         (503)-       $            -
                                                                                                                                 (Pri)-      $       10,564.00 (Pri)-        $            -      Claim No. 216 was filed on 12/18/2024, which was
                                                                                                                                 (GUC)-                         (GUC)-       $            -      after the Governmental Bar Date, 12/9/2024.
                                                                                                                                 (Tot)-      $       10,564.00 (Tot)-        $            -



    4      TDOR                                             12/18/2024 24-11230       Vyaire Medical 202, Inc.           8       (Sec)-      $             -    (Sec)-       $            -
                                                                                                                                 (Adm)-      $             -    (Adm)-       $            -
                                                                                                                                 (503)-      $             -    (503)-       $            -
                                                                                                                                                                                                 Claim No. 8 was filed on 12/18/2024, which was after
                                                                                                                                 (Pri)-      $      104,525.00 (Pri)-        $            -
                                                                                                                                                                                                 the Governmental Bar Date, 12/9/2024.
                                                                                                                                 (GUC)-      $             -    (GUC)-       $            -
                                                                                                                                 (Tot)-      $      157,207.44 (Tot)-        $            -


    5      TDOR                                             12/18/2024 24-11234       Vyaire Medical 211, Inc.          32       (Sec)-      $             -    (Sec)-       $            -
                                                                                                                                 (Adm)-      $             -    (Adm)-       $            -
                                                                                                                                 (503)-      $             -    (503)-       $            -
                                                                                                                                                                                                 Claim No. 32 was filed on 12/18/2024, which was after
                                                                                                                                 (Pri)-      $        7,582.00 (Pri)-        $            -
                                                                                                                                                                                                 the Governmental Bar Date, 12/9/2024.
                                                                                                                                 (GUC)-      $             -    (GUC)-       $            -
                                                                                                                                 (Tot)-      $        7,582.00 (Tot)-        $            -

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                                                                                                                       Claim Amount & Classification Adjusted Classification Status
Item No.                   Claimant Name   Claim Date Filed     Case Number   Debtor Against Whom Claim   Claim No.                                                                                 Reason for Disallowance
                                                                                                                                 Status                       & Amount
                                                                                        is Filed


    6      The West Group Limited                    3/31/2025 24-11217       Vyaire Medical, Inc.          250       (Sec)-      $             -    (Sec)-       $            -
                                                                                                                      (Adm)-      $             -    (Adm)-       $            -
                                                                                                                      (503)-      $        2,585.00 (503)-        $            -
                                                                                                                      (Pri)-      $             -    (Pri)-       $            -      Claim No. 250 was filed on 3/31/2025, which was after
                                                                                                                      (GUC)-      $      199,200.62 (GUC)-        $            -      the General Bar Date, 8/2/2024.
                                                                                                                      (Tot)-      $      201,785.62 (Tot)-        $            -




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                                      Schedule 3

                           Insufficient Documentation Claims




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                                                                                                  SCHEDULE 3
                                                                                              LATE FILED CLAIMS
           Objection Key
           (Sec)- Secured
           (Adm)- Administrative
           (503)- 503(b)(9)
           (Pri)- Priority
           (GUC)- Non-Priority General Unsecured
           (Tot)- Total Claim




                                                                                                                     Claim Amount &                Adjusted Classification
Item No.                     Claimant Name          Case Number   Debtor Against Whom Claim   Claim No.                                                                                    Reason for Disallowance
                                                                                                                   Classification Status              Status & Amount
                                                                            is Filed
    1      Owens & Minor Distribution, Inc.        24-11217       Vyaire Medical, Inc.          223       (Sec)-           $            -   (Sec)-          $            -
                                                                                                          (Adm)-           $      40,552.84 (Adm)-          $            -
                                                                                                                                                                             Claim does not include or attach sufficient
                                                                                                          (503)-                            (503)-          $            -
                                                                                                                                                                             documentation to constitute prima facie evidence of
                                                                                                          (Pri)-           $               -   (Pri)-       $            -   the validity and amount of the claim, and the Debtors'
                                                                                                          (GUC)-           $      13,974.29 (GUC)-          $            -   books and records do not reflect any basis for the
                                                                                                          (Tot)-           $      54,527.13 (Tot)-          $            -   claim.




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