The creditor group says it is owed about $20 million dating to the time of the merger.
While all of the creditor groups have approved the plan in principle, there will inevitably be wrangling over the details.
But it will be submitted to the bankruptcy court for approval, and any of the creditor groups have an opportunity to object.
"They're putting a number on the scoreboard," said the representative of one creditor group.
Two other creditor groups - holders of pre-1988 debt - are still studying the proposal.
Key to the two reorganization plans are proposed agreements with a major creditor group.
The proposed reorganization must then be approved by the court and various creditor groups.
"Each creditor group will look at individual circumstances, including cash flow," he said.
The bankruptcy judge and various creditor groups get a significant voice in management decisions.
But he was spotted that same day at a New York law firm, pitching his firm's services to another creditor group.