specific); I. Appel, 300 B.R. at 570 (holding combination of blanket provision in plan and reference to potential claims against defendants in disclosure statement was sufficient to provide adequate notice to parties in interest that debtor had potential outstanding claims against defendants).

To fully preserve a liquidating trustee's ability to prosecute claims and causes of action post-confirmation and avoid the potential preclusive effect of res judicata, a plan retention provision must balance the specificity that many courts require against maintaining some flexibility to bring valid claims and causes of action that may not have been fully investigated and determined prior to confirmation of the plan. Whenever possible, a debtor should specifically and unequivocally identify each claim and cause of action (including parties against whom those claims and causes of action may be asserted) that it intends to reserve under the plan. In addition, a plan retention provision should clearly state that the claims and causes of action identified therein are being "preserved" and "reserved" for post-confirmation enforcement and provide for the appointment of a party (i.e., liquidating trustee) to act as a representative of the estate to prosecute claims and causes of action post-confirmation for the benefit of the estate.

V. RETENTION OF BANKRUPTCY COURT'S JURISDICTION TO HEAR POST-CONFIRMATION LITIGATION

While plans typically include provisions regarding the matters over which the bankruptcy court retains jurisdiction post-confirmation, a bankruptcy court may not create jurisdiction to hear a matter through a plan. See In re Resorts Intl., 372 F.3d 154, 161 (3d Cir. 2004); In re Railworks Corp., 325 B.R. 709 (Bankr. D. Md. 2005). Instead, a bankruptcy court's jurisdiction to hear and determine a case must be decided on the basis of federal statutes, not plan provisions.