Creditors of Lehman Brothers Holdings Inc, including hedge fund Paulson & Co, may file a competing reorganization plan for distributing the bank's assets, a person familiar with the matter said.

The plan, which may be filed this week, would come more than two years after Lehman filed the largest U.S. bankruptcy ever and would vie against Lehman's own reorganization proposal filed in March.

Paulson & Co, led by billionaire John Paulson, and other creditors including the California Public Employees' Retirement System, or Calpers, have opposed the company's plan, saying it would treat large bank creditors better than other creditors and spur litigation. Calpers is the largest U.S. pension fund.

Paulson & Co declined to comment. A Calpers representative was not immediately available.

News of the competing plan was reported earlier by Bloomberg, which said the plan calls for distributing an estimated $57.5 billion of Lehman assets more equally.

Lehman has said its plan, now pending before a U.S. Bankruptcy Court judge in Manhattan, was a compromise aiming to balance competing interests. The company said its plan would create an asset management company to maximize the value of Lehman's assets by managing them over the long term.

Under Lehman's plan, unsecured creditors are expected to recover 10.4 cents to 44.2 cents on the dollar. General unsecured creditors of the holding company would likely recover 14.7 cents on the dollar, while creditors of the derivatives and commercial paper units could recover 21.9 to 44.2 cents on the dollar.

Lehman has said it expects to file a revised reorganization plan in the coming months that would update these estimated recoveries.

The creditors are able to file a competing bankruptcy reorganization plan with the court because Lehman's exclusive right to a plan expired after 18 months.

The case is in Re: Lehman Brothers Holdings Inc., U.S. Bankruptcy Court, Southern District of New York, No. 08-13555.

(Reporting by Dena Aubin; additional reporting by Caroline Humer, editing by Dave Zimmerman)

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