creditors from acting unilaterally to obtain payment from a debtor to the detriment of other creditors. Id. (citation omitted). Although the scope of the automatic stay is broad, the clear language of section 362(a) stays actions only against a “debtor.” Id. (citing Assoc. of St. Croix Condominium Owners v. St. Croix Hotel Corp., 682 F.2d 446, 448 (3d Cir.1982)). As a consequence, “[i]t is universally acknowledged that an automatic stay of proceedings accorded by § 362 may not be invoked by entities such as sureties, guarantors, co-obligors, or others with a similar legal or factual nexus to the ... debtor.” Id. at 1205 (quoting Lynch v. Johns-Manville Sales Corp., 710 F.2d 1194, 1196-97 (6th Cir.1983)); see also United States v. Dos Cabezas Corp., 995 F.2d 1486, 1491-93 (9th Cir.1993) (<HOLDING>); Croyden Associates v. Alleco, Inc., 969 F.2d
holding osha does not preclude an employee from pursuing a tort action for a retaliatory discharge holding that when the basis of the earlier suit was that the plaintiff had had defaulted on a promissory note and the claim in the instant action is whether that promissory note was valid the transaction test is met holding that fraudulent collection on promissory note was reasonably related to breach of contract claim holding that stay does not preclude government from pursuing deficiency judgment against nondebtor cosignors of promissory note holding that a promissory note is not enforceable against a party who signed the deed of trust but did not sign the promissory note inasmuch as promissory notes and deeds of trust are separate legal documents with unique purposes