Although borrowers in multiple-debtor cases may still attempt to exact leverage against their creditors under the Per-Plan Cases, courts in all jurisdictions should be reluctant to apply an analysis inconsistent with Jameson and Tribune in light of the easily distinguishing characteristics of each of the Per-Plan Cases. Dechert attorneys Michael Sage and Brian Greer note lenders should be prepared in circumstances when they are the only creditor whose vote could be solicited on a debtor’s plan of reorganization to act aggressively. Such lenders should consider, among other things, seeking the immediate dismissal of the debtor’s Chapter 11 case, relief from the automatic stay, and termination of the debtor’s exclusive period to file a Chapter 11 plan.