S.D.N.Y . 2013 ) [ keywords : presumption-habitual residence ; centre of main interests ( COMI ) -timing ; establishment ] This application for recognition in the United States of America of the personal insolvency proceeding the debtor had commenced in London was contested by a major creditor who had sued the debtor in the United States and sought to avoid the stay that would arise automatically on recognition of the English proceedings under Chapter 15 of the United States Bankruptcy Code ( enacting the Model Law in the United States ) .