In North American Catholic Educational Programming Foundation, Inc. v. Gheewalla, read opinion here , the Delaware Chancery court rejected a direct claim by a creditor against directors  of a company allegedly in the "zone of insolvency" who were supposedly  beholden to Goldman Sachs due to its source of funding. The court held:

(1) that creditors of a Delaware corporation in the “zone of insolvency” may not assert direct claims for breach of fiduciary duty against its directors;

(2) that the Complaint fails to state a claim for the narrow, if extant, cause of action for direct claims involving breach of fiduciary duty brought by creditors against directors of insolvent corporations; and

(3) that, with dismissal of its fiduciary duty claims, NACEPF has not offered the Court any basis for exercising personal jurisdiction over the Defendants with respect to NACEPF’s other claims.

See also summary and commentary on this blog of recent Chancery Court decision that rejected a cause of action for "deepening insolvency"