Flack, 239 B.R. 155, 164 (Bankr.S.D.Ohio 1999) ("The automatic stay is a significant benefit for debtors and a burden to creditors, and should be generally reserved for instances in which there is a bankruptcy filing. It is presumptuous to create through pre-filing contact, except in the most extreme instances not present in this case, some sort of hybrid stay not contemplated by Congress that has had ample opportunity to create such a provision. Such contact is subject to abuse, denigrates the significance of the stay and serves as a trap for unwary creditors who have a right to generally expect that they are provided reasonable, actual notice of an actual bankruptcy filing before ceasing collection efforts.”); Tese-Milner v. Moon (In re Moon), 385 B.R. 541, 557 (Bankr.S.D.N.Y.2008) (<HOLDING>). 12 . West Virginia certificates of title were
holding that the bankruptcy court lacked subject matter jurisdiction over counterclaims asserted by the bankruptcy estate against a creditor where the claim is a state law action independent of the federal bankruptcy law and not necessarily resolvable by a ruling on the creditors proof of claim in the bankruptcy emphasis added holding that creditor did not have actual knowledge of the bankruptcy filing where the debtor informed creditor of the possibility that a bankruptcy case would be filed holding that creditor lacked appellate standing to appeal order of bankruptcy court absent permission of bankruptcy court holding creditor possessed notice of the bankruptcy case at a date early enough for them to act upon their knowledge holding that a time limit for filing a complaint as a creditor in bankruptcy proceedings is not jurisdictional