Creative Touch Interiors v. Dist. Ct. (Brown)

filed Chapter 11 bankruptcy. The district court stayed the action, finding that the

11 U.S.C. § 362

automatic bankruptcy stay applied and that the amount of the underlying obligation was uncertain because of the bankruptcy litigation. As to the automatic bankruptcy stay, the stay is generally applicable to the debtor only, not a guarantor. See In re PTI Holding Corp.,

346 B.R. 820, 833-34

(Bankr. D. Nev. 2006); Edwards v. Ghandour, 123 Nev. 105, 113-14 & n.10, 159 P.3d 1086, 1091-92 & n.10 (2007) (explaining that the automatic bankruptcy stay does not apply to co- debtors and guarantors),…