According to Bloomberg, LightSquared Inc. has filed a reorganization plan that offers new treatment to Dish Network Corp. (DISH) Chairman Charles Ergen’s $1 billion in debt, in a bid to resolve a protracted legal fight.

The Bloomberg report says a new plan filed “offers a compromised treatment” for Ergen’s debt “that would avoid costly litigation” over how his claim should be treated, according to the court papers. The Chapter 11 plan is “the only restructuring proposal that avoids a value-minimizing liquidation” and will allow the company to exit bankruptcy, according to the filling. It would pay senior secured claims in full and give potential recoveries to more junior stakeholders through an auction of stock in a newly reorganized company.

Bloomberg reported the new plan will have a term loan of $1 billion if Ergen votes to accept it, or $1.2 billion plus potential further amounts if Ergen votes to reject it, according to the filing.

To read the full Bloomberg report, click here.