Lock Up Your Creditors - Court Gives Broad Protection to Binding Plan Support Agreements

Rejecting the formalistic approach, the Delaware Bankruptcy Court in Indianapolis Downs, LLC focused on the policies underlying the idea of the disclosure statement to uphold a post-petition lock-up agreement, entered into before approval of a disclosure statement, with sophisticated financial players who had access to the material information that the disclosure statement would have provided. This opinion represents a potentially significant relaxation of the bankruptcy solicitation rules and validates what has become a standard and often essential practice of involving major creditors in the negotiations leading to a proposed plan.