Proceeding. Plaintiffs’ lawsuit is based on events that occurred prior to the Debtor’s bankruptcy — namely, Defendants’ failure to properly draft and enforce a Rule 11 agreement and Defendants negligently advising McVey to file a Chapter 11 petition for SBMC. Because Plaintiffs’ lawsuit is based on pre-petition events and the Exculpatory Provision only immunizes Defendants from post-petition acts or omissions, the Provision is ineffective to bar this Adversary Proceeding. Interpretation of the Exculpatory Provision cannot be broadened to limit the liability of Defendants for pre-petition acts or omissions. Texas law governing releases provides that the language within an exculpatory provision must be narrowly construed. Victoria Bank & Trust Co. v. Brady, 811 S.W.2d 931, 938 (Tex.1991) (<HOLDING>); Duncan v. Cessna Aircraft Co., 665 S.W.2d
holding that personal injury exception should be construed narrowly so as not to include torts without physical injury recognizing that due on sale clauses are enforceable in texas holding that general categorical release clauses are narrowly construed holding that  1 narrowly construed did not exclude employment contract of television news reporter holding that the definition of customer under sipa should be construed narrowly