On September 9, 2014, the Bankruptcy Court for the Southern District of New York held that certain senior lenders were not entitled to the benefit of their indentures’ make-whole premiums, because they had voluntarily accelerated their notes.  As we have reminded our readers several times, careful drafting of what may seem like basic boilerplate provisions is important.  Seemingly benign stand-alone provisions may have unintended consequences when linked together in a single agreement.