By Robert E. Grossman and Brad Lenox
In In re Endi Plaza LLC, the Bankruptcy Court for the Southern District of New York granted a stay pending an appeal of its prior order dismissing a bankruptcy case for bad faith but required the debtor to post a bond of more than $3 million during the pendency of the stay period. This decision is instructive for secured creditors that have been frustrated in their efforts to exercise state law rights by the filing of a bankruptcy case.