Nix v. Household Fin. Corp. II (In re Nix), No. 12-80062-HB, 2012 WL 27667, at *7 (Bankr. D.S.C. Jan. 5, 2012) (Burris)

Blanket reservation of rights in form plan was insufficient to defeat res judicata effect of confirmation with respect to causes of action “based on pre-confirmation activity that arise from the same or related facts that were relevant to confirmation.” Plan language stated: “Nothing herein is intended to waive or affect adversely any rights of the debtor, the trustee, or party with respect to any causes of action owned by the debtor.” Accord Ginn v. CitiMortgage, Inc. (In re Ginn), No. 11-80054-HB, 2012 WL 112974 (Bankr. D.S.C. Jan. 11, 2012) (Burris); Pressley v. CitiMortgage (In re Pressley), No. 11-80048-HB, 2012 WL 115379 (Bankr. D.S.C. Jan. 12, 2012) (Burris).

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