of Kelvin Pub., Inc., 1995 WL 734481, *4 (6th Cir.1995) (unpublished) (internal quotations omitted). Section 105 does not itself create a private right of action, but may be invoked to preserve a right elsewhere in the Code. Id.; Yancey v. Citifinancial Inc. (In re Yancey), 301 B.R. 861, 868 (Bankr.W.D.Tenn.2003). “Section 105(a) of the Code provides the bankr ss.1997) (using § 105(a) to hold the creditor in contempt to enforce the court’s discharge of a debt where the creditor had deliberately attempted to collect a prepetition debt in disregard of the discharge order). Section 105 also enables courts to issue orders necessary to protect estate property subject to bankruptcy proceedings. See, e.g., Green v. Drexler (In re Feit & Drexler, Inc.), 760 F.2d 406, 411, 414-15 (2nd Cir.1985) (<HOLDING>); Air Line Pilots Ass’n Int'l v. Am. Nat’l Bank
holding that a court had the power pursuant to  105a to compel a defendant to deliver her property which was the subject of a bankruptcy proceeding from outside the courts territorial jurisdiction holding that a motion to enforce bankruptcy sale order is a core proceeding and citing 11 usc  105a as the section which gives the bankruptcy court the power and the jurisdiction to enforce its valid orders  holding that when evidence exists that the crime may have been committed outside marylands territorial jurisdiction and a defendant disputes the territorial jurisdiction of the maryland courts to try him or her the issue of where the crime was committed is factdependent and thus for the trier of fact holding that the basis of in rem jurisdiction is the presence of the subject property within the territorial jurisdiction of the forum state holding that bankruptcy court has discretionary power pursuant to 11 usc  105a to order preconfirmation plan payments in a chapter 12 proceeding