the scope of the § 362(a)(1) automatic stay. The litigation is thus automatically stayed pursuant to § 362(a)(1), and further analysis of whether the party has satisfied the standard for a preliminary injunction is unnecessary. See Kanawha, 87 B.R. at 897 n. 3 ("Because a stay of the district court proceeding prevents enforcement of First National's guaranty agreement, the issue of whether a preliminary injunction that would prohibit the bank from proceeding with its litigation need not be addressed.”). Even if the "unusual circumstances” exception does require additional satisfaction of the standard for a preliminary injunction, as stated in the Stay Order and explained in more detail herein, that standard was satisfied. 11 . See Fisher v. Apostolou, 155 F.3d 876, 882 (7th Cir.1998) (<HOLDING>); Lentz v. Cahaba Disaster Relief, LLC (In re
holding that bankruptcy court may enjoin federal administrative proceedings when they threaten the debtors estate holding that the district court erred when it failed to consider the presumption of irreparable harm holding that it was unnecessary for the bankruptcy court to find that the traditional elements required for a preliminary injunction were satisfied because a bankruptcy court can enjoin proceedings in other courts when it is satisfied that such proceedings would defeat or impair its jurisdiction over the case before it holding that it is axiomatic that remanding a case to state court terminates the jurisdiction of a federal bankruptcy or district court over that case holding that the a bankruptcy court can enjoin proceedings in other courts when it is satisfied that such proceedings would defeat or impair its jurisdiction over the case before it and the court does not need to demonstrate an inadequate remedy at law or irreparable harm