Lehman Brothers Holdings Inc. (LEH)

* Lehman has more than $16 bln in cash

* 64,000 claims against bank top $820 bln, may top $1 trln* Lehman CEO says is operating on 24-month time frame* Lehman estate managing $14.4 bln in real estate assets (Recasts first sentence, adds court hearing details, CEO comments, other background) By Emily Chasan and Chelsea Emery NEW YORK, Nov 18 (Reuters) - Lehman Brothers Holdings Inc (LEHMQ.PK), the U.S. investment bank whose September 2008 collapse sharply accelerated a world financial meltdown, said on Wednesday it expects to have a reorganization plan outline ready by the end of March 2010. The bankrupt investment firm is contending with more than 64,000 claims from creditors with a face amount value of more than $820 billion. Lehman's chief executive, turnaround specialist Bryan Marsal, said in bankruptcy court on Wednesday it was possible the claims could reach $1 trillion due to certain unresolved issues. Lehman is working to categorize the claims, the company said in a securities filing. Initial claim objections are expected to be filed in the next 30 to 45 days. Lehman has been gaining increasing control over its assets and now has cash holdings of $16 billion, Marsal said at a hearing in U.S. Bankruptcy Court in Manhattan. Marsal said he is working on a 24-month time frame that would envision having Lehman on its way out of bankruptcy court by the second anniversary of its bankruptcy filing. However, he cautioned the court that some people "would tell me I'm nuts" and that it may end up leaving bankruptcy on a three-year time frame or longer if it cannot resolve certain issues in time. Among those issues are whether it will need to file one reorganization plan, or many, for all the different Lehman units operating in bankruptcy. Other issues are outstanding intercompany claims and claims against Lehman's international operations, as well as a time-intensive process to resolve derivatives claims, Marsal said. Financial reporting is improving and becoming more current, after the disruption caused by Lehman's abrupt bankruptcy filing in September 2008, the company said. It expects to report its June 30 balance sheet by Nov. 30. Marsal said Lehman was also moving ahead of schedule with a plan to move off of computer systems owned by Barclays, which acquired its U.S. brokerage and had much of the information about the Lehman-owned assets. An examiner overseeing the company's operations is expected to submit a report by Feb. 1, Lehman said. Lehman is also managing some $14.4 billion in real estate assets and has "stabilized" its bank platform assets, which it envisions could yield a significant recovery for creditors if certain regulatory issues are resolved, Marsal said. He said Lehman has also reduced its unfunded real estate commitments to below $400 million. LAWSUITS Lehman, which is engaged in several lawsuits related to issues surrounding its collapse, is also likely be entangled in more litigation ahead, Marsal said. Lawyers for the firm sued Barclays Capital (BARC.L) earlier this week to claw back billions of dollars of excess profit it claims Barclays received in its hurried purchase last year of Lehman's U.S. brokerage business. Discovery is under way, according to the securities filing. Marsal said Lehman was also moving ahead with litigation against Bank of America Corp (BAC.N) which acted as a clearing bank for Lehman, helping it process transactions around the time of its bankruptcy. Marsal said more litigation against its clearing banks would also be forthcoming. One of those clearing banks is JPMorgan Chase & Co. (JPM.N) The litigation represents a major source of potential recovery for creditors, Marsal said. Even if the lawsuits take longer than 24 months, Marsal said they should not hold up Lehman's reorganization plan. Creditors could receive a distribution after the reorganization plan is in effect, Marsal said. 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 and Chelsea Emery, editing by Matthew Lewis) © Thomson Reuters 2009 All rights reserved