22 B 1957
Debtor filed a lawsuit asserting claims for defamation and false light based on actions that occurred after confirmation of his chapter 11 plan.  Defendants sought attorneys’ fees under the anti-SLAPP statute.  Debtor filed a motion seeking sanctions against Defendants for violation of the automatic stay.  HELD: Motion denied.  First, the automatic stay does not apply to litigation commenced by a debtor.  Second, even if it did, a request for attorneys’ fees under the anti-SLAPP statute is excepted from the automatic stay.  Third, even if the court found a stay violation, there would be no basis to award actual or punitive damages.  Debtor did not establish any actual damages and, as a pro se litigant, is not entitled to attorneys’ fees.  Neither is there any evidence to support an award of punitive damages.