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372 F.3d at 167 (holding post-confirmation malpractice claim brought by liquidating trustee against accounting firm providing advice to liquidating trust did not have close nexus to bankruptcy because claim arose solely out of alleged post-confirmation misconduct involving accounting firm to trust and not, for instance, pre-petition claim that could have been asserted by debtor in possession directly prior to confirmation); see also Grimes v. Graue (In re Haws), 158 B.R. 965, 971 (Bankr. S.D. Tex. 1993) (finding post-confirmation jurisdiction did not exist where only nexus to bankruptcy case was fact that plaintiff was liquidating trustee appointed pursuant to plan). This standard applies whether the plan provides for reorganization or liquidation. See BWI Liquidating Corp. v. City of Rialto, et al. (In re BWI Liquidating Corp.), 437 B.R. 160, 167 (Bankr. D. Del. 2010). Moreover, the potential for post-confirmation claims and causes of action to increase liquidating trust assets does not necessarily create a close nexus sufficient to confer "related to" bankruptcy court jurisdiction post-confirmation. Resorts, 372 F.3d at 171; BWI Liquidating Corp., 437 B.R. at 166.
Importantly, courts have held that where a plan does not specifically reserve a claim or cause of action, "related to" jurisdiction will not exist. See, e.g., BWI, 437 B.R. at 166 (holding plan must specifically describe a cause of action in order to retain "related to" jurisdiction); AstroPower, 335 B.R. at 325; see also In re W. Integrated Networks, LLC, 322 B.R. 156, 163-64 (Bankr. D. Colo. 2005). "To find a sufficiently close nexus, the plan must 'specifically describe [] an action over which the Court had 'related to' jurisdiction pre-confirmation and expressly provide[] for the retention of such jurisdiction to liquidate that claim for the benefit of the estate's creditors". BWI, 437 B.R. at 165 (noting specific language helps ensure bankruptcy
