In the case of Wells Fargo Bank N.A. v. RLJ Lodging Trust , an Illinois district court denied a lender's motion for summary judgment seeking to enforce a bad boy carve-out provision in a guaranty agreement providing for full recourse in the event that the borrower “contests or in any way materially interferes with, directly or indirectly any foreclosure action, whether by making any motion, bringing any counterclaim, claiming any defense, seeking an injunction or other restrain, commencing any action, or otherwise.”

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