OPINION
ERIC L. FRANK, Chief Judge.
I. INTRODUCTION
Under bankruptcy law, it is an elementary principle that an automatic stay arises upon the filing of a bankruptcy petition. See 11 U.S.C. § 362(a). The automatic stay applies to a broad range of conduct, but in its most conventional application, the automatic stay restrains pending debt collection litigation, thereby furnishing an obvious benefit to the debtor: a "breathing...
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