"should not exceed the actual liabilities to Lehman's third parties on a worldwide basis."
In the company's proposed reorganization plan
cheap uggs for kids , it said creditors with third-party guarantee claims could recover up to $94.1 billion, while affiliate creditors with guarantee claims could recover up to $21.2 billion.
"A fundamental goal of the plan is to first deal with third party creditor claims of all estates and then deal with claims filed by affiliates," Suckow said.
"We're hoping to rally people around this concept. If this does not work, then we have not ruled out substantive consolidation."
Lehman is currently negotiating with creditors and plans to ask the bankruptcy court for approval to file a disclosure statement in mid-April that would provide further details on its reorganization plans and the state of the business, according to court papers it filed on Tuesday.
Dennis Dunne, an attorney for Lehman's official committee of unsecured creditors, did not return a call seeking comment on Tuesday.
The case is In re: Lehman Brothers Holdings Inc, U.S. Bankruptcy Court, Southern District of New York, No. 08-13555.
(Reporting by Emily Chasan; editing by Andre Grenon)
Related Quotes and News
A lender which claims it is owed millions by the ######.com domain name operator is asking a U.S. bankruptcy court to dismiss an involuntary bankruptcy case against the company, so it can resume a foreclosure auction, according to new court documents.
The New Jersey lender, DOM Partners LLC, which said it loaned more than $4 million to Escom LLC to fund the website's operations, said in court papers on Friday that Escom shouldn't be in bankruptcy. DOM said it would be best able to recover the debt by holding a new auction for what may be the world's most valuable domain name.
An earlier auction was set to take place March 18 in New York, but was halted when three of Escom's other creditors, saying they are owed more than $10 million
cheap uggs for kids , filed an involuntary bankruptcy proceeding against the website owner in California.
The auctioneer hired by DOM Partners had already been contacted by "scores of potential bidders" ranging from U.S. and international investors to domain name industry executives, media companies and adult entertainment companies, according to the court papers.
Escom LLC reportedly paid $14 million to acquire the ######.com domain name in 2006 and said at the time that it planned to create a "next-generation Web interaction" experience on the site. But the court documents filed by the lender painted a picture of a company with just one employee, little income, and little ability to achieve its intentions.
"ESCOM has no working capital of its own to finance any development of the Domain Name, let alone to pay its secured creditors
cheap uggs for kids . buy christian louboutin shoes on sale as T," a representative for the lender said in court papers.
The lender claims Escom had defaulted on its loan in January 2009
cheap uggs for kids , and that it has been "denied access" to Escom's books and records for the past year.
DOM Partne