Lehman Brothers Holdings Inc said it hopes to win court approval of its reorganization plan in mid-November, more than three years after filing the largest bankruptcy in U.S. history.

Creditors would vote on Lehman's Chapter 11 plan by October 14, with a confirmation hearing to follow on November 17, Lehman proposed in a Wednesday filing with the U.S. bankruptcy court in Manhattan.

Once the fourth-largest U.S. bank, Lehman has been selling and winding down assets to repay creditors.

In January, it submitted a revised reorganization plan that offered bondholders more money.

The previous month, a bondholder group that includes the Paulson & Co hedge fund and the California Public Employees Retirement System pension fund proposed a competing plan.

Lehman's revised plan would repay creditors roughly $60.1 billion, equal to about 18.6 cents on the dollar based on an estimated $322 billion of valid claims.

Goldman Sachs Group Inc is part of a creditor group that may file a third proposed plan.

Today's filings underscore the debtors' intent to move forward, Lehman Chief Executive Bryan Marsal said in a statement. He called Lehman's plan the best way of balancing competing interests and avoiding years of costly lawsuits.

Lehman said a June 28 hearing was scheduled to approve its disclosure statement describing its reorganization plan.

Approval is required before a plan can be sent to creditors for a vote. Any plan would require approval of U.S. Bankruptcy Judge James Peck, who oversees Lehman's bankruptcy.

Gerard Uzzi, a partner at White & Case LLP representing the Paulson and Calpers group, did not immediately return a call seeking comment. Goldman spokesman Michael DuVally declined to comment.

Lehman's plan calls for senior unsecured creditors, including many bondholders, to recover 21.4 cents on the dollar, up from an original 14.7 cents.

The higher payout requires that creditor group and two others to vote in favor of the plan. If that did not occur, then the payout would be just 15 to 17 cents on the dollar.

The Paulson-Calpers group has said it has about $20 billion of claims. It believed Lehman's original plan favored large banks that were creditors of Lehman's derivatives business.

Lehman filed for Chapter 11 protection on September 15, 2008. It reported $639 billion of assets, six times as much as any other U.S. company to go bankrupt.

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

(Reporting by Jonathan Stempel in New York, editing by Bernard Orr)

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