Likewise, debtors should think twice before assuming that a bankruptcy filing in the Southern District of New York will allow them to avoid incurring a hefty make-whole premium in a credit agreement or note indenture. Notably, however, the Debtor in 1141 Realty Owner, LLC did not raise the arguments addressed in the Fifth Circuit's recent opinion in In re Ultra Petroleum Corporation, which suggested that a make-whole premium constituted "unmatured interest" that a creditor is barred from recovering under section 502(b)(2) of the Bankruptcy Code. In re Ultra Petroleum Corp., 913 F.3d 533, 547–548 (5th Cir. 2019).