Diocese of Alexandria - Chapter 11 Plan Terms

Plan Terms

Overview

• The Diocese of Alexandria, a Louisiana nonprofit corporation serving an 11,108-square-mile region of central Louisiana, filed Chapter 11 on Oct. 31, 2025 in the Western District of Louisiana and on Sept. 18, 2026 filed a second amended plan of reorganization resolving abuse and other unsecured claims through a funded trust.
• The plan turns on a $500,000 Settlement Payment to a newly created Plan Trust plus the assignment of the diocese's rights under its historical liability policies; holders of Class 4 general unsecured claims, which include abuse survivor claims, are the trust's sole beneficiaries and look only to the trust for recovery.
• The diocese remains a going concern: it continues after the effective date as the reorganized debtor, a Louisiana nonprofit with 501(c)(3) status, and all estate assets other than the trust assets vest in it free and clear.
• The plan draws a hard line around the Diocese of Shreveport, a separate Louisiana nonprofit and distinct public juridic person that is neither the debtor, the reorganized debtor, nor an affiliate for plan purposes. Parishes that sat under Alexandria's ecclesiastical jurisdiction before 1986 moved to Shreveport that year but remain named co-insureds under the policies at issue.
• The creditors' committee was appointed Nov. 21, 2025 and is represented by Wiener, Weiss & Madison. Gold, Weems, Bruser, Sues & Rundell and Husch Blackwell serve as debtor's counsel, with Getzler Henrich as financial advisor and Stretto as noticing, claims and solicitation agent.

Key Dates

• Petition date Oct. 31, 2025; creditors' committee appointed Nov. 21, 2025; second amended plan filed Sept. 18, 2026.
• Plan supplement due four days before the voting deadline, with the amended Southern Heritage Bank loan documents due before the confirmation hearing.
• Effective date: the first business day after the confirmation date on which every condition precedent is satisfied or waived.
• Initial plan funding date, when the Settlement Payment is due: the first business day 45 days after the effective date.
• Administrative claims bar date 60 days after the effective date, with objections due 90 days later; final fee applications 45 days after the effective date.
• Claim objection deadline: the later of the first business day at least one year after the effective date or a period fixed by the debtor, reorganized debtor, plan trustee or the court.
• Interim distributions no earlier than one year after the effective date; final distribution date the later of five years after the effective date or a reasonable time after the trustee resolves liability and coverage issues on the assigned interests, with the Future Claims Reserve de-segregated if no future claim arrives by the 60th day before it.
• Second anniversary of the effective date: the trustee's authority to let survivors litigate against insurers expires, and the trust and trustee become the successor for U.S. Trustee fee purposes.

Settlement Payment and Plan Funding

• Size: $500,000 in the aggregate, payable to the Plan Trust on the initial plan funding date, the first business day 45 days after the effective date.
• Form: cash, real property credited at fair market value, or any combination, at the debtor's sole and absolute discretion; the trust takes title to any real property free and clear under section 1141, with customary closing prorations allocated to the debtor.
• Floor and withdrawal trigger: the payment increases as necessary so that it is not less than the liquidation value, defined as the amount the court determines section 1129(a)(7) requires for Class 4 holders based on the liquidation analysis at Exhibit B to the disclosure statement. That figure is fixed for all plan purposes and not subject to redetermination on post-effective-date events absent further court order. The plan caps the payment nowhere; instead, if the court determines at confirmation that the amount required exceeds $1.5 million, the debtor may withdraw the plan.
• Fair market value for contributed real property is the greater of the amount contended by any party in interest other than the debtor or reorganized debtor, or the value set by an independent MAI-certified appraisal dated no more than 120 days before the contribution, subject to the committee's or plan trustee's right to object before the court; other non-cash assets are valued by an independent appraiser on the same 120-day look-back, with publicly traded securities marked at the close on the business day before contribution. Appraisal costs fall solely on the debtor, reorganized debtor or contributing party and are not reimbursable from trust assets.
• A contribution credited at fair market value fully and finally satisfies the corresponding dollar amount of the funding obligation; the trust and its beneficiaries bear the risk of any shortfall between credited value and amounts actually realized, and the debtor can never be required to top up based on post-valuation events.
• Distributions to Classes 1 through 3 are funded with cash, including cash from operations and lender financing. After the effective date the reorganized debtor may raise additional capital and obtain financing without further court order, subject to any post-effective-date agreement.

Classification and Treatment of Claims

• Administrative claims, professional fee claims and priority tax claims are unclassified. Administrative claims are paid in cash in full on the effective date or, if allowed later, within 30 days of allowance becoming final; the administrative claims bar date is 60 days after the effective date, with objections due 90 days thereafter. Final fee applications are due 45 days after the effective date. Priority tax claims receive section 1129(a)(9)(C) treatment with post-effective-date interest under sections 511 and 1129(a)(9)(C). The debtor does not believe any priority claims exist.
• A timely filed and properly served administrative claim that draws no objection is deemed allowed in the amount requested, and the reorganized debtor may settle administrative claims in the ordinary course without court approval. Substantial-contribution requests under sections 503(b)(3), (4) and (5) are due by the administrative claims bar date. From the confirmation date the reorganized debtor pays its professionals' reasonable and documented fees in the ordinary course, and the retention and compensation requirements of sections 327 through 331 and 1103 stop applying to services rendered after that date.
• Class 1, the Southern Heritage Bank secured claim of approximately $1.65 million arising from an April 15, 2025 loan (impaired, entitled to vote): the bank retains its lien on its collateral and is paid in full under loan documents amended by written agreement with the reorganized debtor, with the amended documents filed as part of the plan supplement before the confirmation hearing.
• Class 2, the Sabine State Bank guarantee claim of approximately $626,276.61 under a guaranty agreement dated on or about June 21, 2021 (impaired, entitled to vote): the guaranty is modified so that it is unenforceable against the debtor or reorganized debtor unless and until the bank has fully and finally exhausted all rights and remedies against the borrower and against all collateral securing the borrower's obligations.
• Class 3, general convenience claims (impaired, entitled to vote): each holder receives, at the debtor's election, 75% of its allowed claim in cash or treatment consistent with section 1129(a)(9), payable within 60 days of the effective date or when due in the ordinary course. The class captures general unsecured claims other than abuse-related contribution claims allowed at $5,000 or less, or reduced to that amount by irrevocable written election on a court-approved form that debtor's counsel must receive by the voting deadline, with transferred or subdivided portions tested against the entire original claim. A survivor claim electing convenience treatment gives up any distribution from the Plan Trust, including any share of trust cash and any insurance recoveries, and remains subject to objection.
• Class 4, general unsecured claims (impaired, entitled to vote): each holder receives its pro rata share of the Settlement Payment held by the Plan Trust, plus — only where the plan trustee determines the claim is covered by a subject policy — a pro rata share, calculated among covered holders only, of proceeds the trust actually receives on the assigned insurance interests. Pro rata shares are calculated on allowed amounts fixed by settlement with the debtor, reorganized debtor or plan trustee, or by liquidation in a court of competent jurisdiction, in each case reduced by the Future Claims Reserve and net of the trustee's costs of administering the trust. Future claims sit in Class 4 but neither they nor the future claims representative may vote.
• Once the debtor completes its funding obligation to the trust, it and the reorganized debtor have no further obligation to Class 4 claimants; obligations to Classes 1 through 3 are satisfied on payment. Any class without an allowed or temporarily allowed claim above zero as of the confirmation hearing is deemed vacant and eliminated for voting purposes.

The Plan Trust

• The trust is established under a trust agreement filed as Exhibit C, funded with the Settlement Payment and the assigned insurance interests, together the only trust assets, and is intended to qualify as a liquidating trust under Treasury Regulation section 301.7701-4(d) and as a grantor trust; it is expected to be tax exempt. The trustee must also take reasonable steps to keep the trust qualified as a designated or qualified settlement fund under section 468B, with the debtor as transferor and the trustee as administrator, and the debtor makes the grantor trust election on the trust's first timely filed return. The trust is irrevocable and the reorganized debtor may not alter, amend, revoke or terminate it.
• Plan trustee: Lucy Sikes, appointed by the court in the confirmation order, serving from the effective date but permitted to act earlier if the court authorizes; the debtor is to propose the trustee in the plan supplement. She bills $400 per hour, with employees at standard rates capped at the principals' rates and annual increases beginning January 2027 limited to 10%.
• The trustee is the estate's representative under section 1123 with the powers of a trustee under sections 704, 108 and 1106 and Bankruptcy Rule 2004, including prosecuting, selling and settling causes of action; where the plan and confirmation order conflict on her authority, the confirmation order controls. Under Bankruptcy Rule 9001(b)(5) she is the person authorized to act for the reorganized debtor in defending claims for the purpose of liquidating them to collect against the subject policies. The confirmation order will bar any action against her in her official capacity outside the bankruptcy court without that court's permission.
• On the effective date the trust assumes the debtor's rights and obligations on every Class 4 claim and succeeds to all related defenses, though the reorganized debtor retains its own right to object to Class 4 claims and the assumption does not relieve any insurer of obligations under the subject policies. The trust is not the same legal entity as the debtor, only an assignee of certain assets and liabilities and an estate representative under section 1123(b)(3).
• The committee may make reasonable revisions to the trust agreement subject to court approval before entry of the confirmation order; absent revisions, the Exhibit C form becomes effective on execution at or shortly after confirmation. Where the documents conflict, the confirmation order controls over everything, the trust agreement controls over the plan on trust administration and operation, a plan supplement document controls over the plan, and the plan controls over the disclosure statement.
• Trust cash is held in cash or short-term highly liquid investments, and may be spent to meet current liabilities, preserve asset value, pay administrative expenses including taxes and professional fees, and satisfy other trust liabilities. The trustee maintains a registry of beneficial interests, and transfers of those interests are ineffective until she receives written notice. The trust may retain professionals without court approval and at its own expense, including counsel that previously represented the debtor or the committee.
• The trustee may not guarantee debt, lend trust assets, move them to another trust for which the trustee also serves, or make any distribution the plan, confirmation order or trust agreement does not authorize; investments must comply with section 345, with no duty to diversify, and the trust may not hold more than 4.9% of any public reporting company's securities or any non-public stock or partnership interest unless acquired involuntarily to preserve value. Property the trustee reasonably considers de minimis or burdensome, including a pending adversary proceeding, may be abandoned on 15 days' notice to beneficiaries, and a written objection within that period forces the abandonment to the court.
• The trust indemnifies the trustee, her members, designees, professionals, agents and representatives against liabilities arising from implementation or administration of the trust or plan, excluding willful misconduct, gross negligence, fraud or breach of the fiduciary duty of loyalty.
• The trustee prepares annual financial reports as of each December 31, within 45 days of the period close and available to beneficiaries on request, and a final report before termination filed with a motion for its approval and for the trustee's discharge. The trustee also reports each distribution, its recipient and any signed release to the reorganized debtor, which receives all releases and payment records at wind-up and 30 days' notice before any trust records are destroyed. The trustee may resign, effective within 30 days of delivering the written resignation, or be removed by the court for good cause on a beneficiary's motion, with the court designating any successor.
• Privileged and confidential material transferred to the trust keeps its protection and vests in the trustee alone, though the trustee may share it with an insurer as necessary to obtain recoveries on the assigned interests, and the register of beneficiaries is kept confidential under the case's protective orders. Where the trust or trustee prevails in a dispute over the trust agreement, it may recover costs and reasonable attorneys' fees from the losing party, and neither the trust nor the trustee bears Medicare Secondary Payer liability except for residual liability arising out of an insurance settlement.
• The trust terminates after liquidating, administering and distributing its assets and completing its other duties, within a reasonable time after the final distribution date, and remains in force until the court enters a final order on the trustee's motion terminating it. The trust agreement fixes an outside term of five years after the effective date, or such later date as the final distribution date requires, extendable only in one-year increments and only where the court approves within six months of the start of each extended term. If on termination the trustee determines distribution to beneficiaries would cost more than the available funds, remaining funds and investments go to Manna House.

Insurance Assignment

• On the effective date, automatically and without further act, the debtor's rights and interests in the subject policies transfer to the Plan Trust. The assignment is of rights and interests — not of the policies themselves — including bad faith and breach of the duty of good faith and fair dealing claims, solely to the extent necessary for the trust to pursue and receive proceeds on account of survivor claims, notwithstanding any anti-assignment provision. It is made free and clear under section 363(f), except for insurers' rights, defenses and coverage positions, is absolute on entry of the confirmation order subject only to the effective date occurring, and is governed by the Bankruptcy Code and Louisiana law.
• The subject policies are defined by function, not by list: any policy in effect on or before the effective date, issued or allegedly issued to or for the diocese's benefit, for which coverage might exist for a survivor claim, with Exhibit A naming those identified so far. Those span occurrence years from 1972 through 2022 and include Travelers, Continental, Great American, St. Paul, Aetna, Bituminous, California Union and Commercial Union (Chubb), Interstate Fire & Casualty, Underwriters at Lloyd's and London market companies, Centennial, National Surety, Colonial Penn/American Re, Lexington (AIG), INA/Century Indemnity (Chubb), Federal Insurance (Chubb), United National, and Catholic Mutual Relief Society of America certificates 8030–8529 for the Nov. 1, 1988 through July 1, 2022 period. The exhibit may be supplemented if additional qualifying policies are identified, with the reorganized debtor cooperating to assign them and filing a notice of redline.
• Neither the debtor nor the reorganized debtor retains any interest in or control over the assigned interests or their proceeds after the effective date, and the reorganized debtor will neither pay amounts owed in any insurance litigation — damages, retentions, deductibles or fees — nor expend resources on it. The trust bears sole responsibility for premiums, deductibles, self-insured retentions and fronting obligations arising out of survivor claims, and assumes whatever notice obligations exist under the policies.
• Invoking the Fifth Circuit's decision in Albany Ins. Co. v. Bengal Marine, 857 F.2d 250 (5th Cir. 1988), and Louisiana statutes, the plan provides that the debtor and plan trustee are insolvent and that recovery against the subject policies is not conditioned on or defeated by satisfaction of any deductible, self-insured retention or similar obligation, including the duty to defend, and that no insurer may assert such a failure to deny, delay or reduce coverage.
• The plan is expressly neutral on coverage: it does not affect insurers' or insureds' rights and defenses, carries no preclusive effect on policy rights or obligations, is not a determination of the reasonableness of the plan or any settlement embodied in it, and does not determine the applicability of any policy provision. Coverage actions may be brought outside the bankruptcy court, and arbitration rights under the policies are preserved.
• The assumed insurance policies at Exhibit B — the diocese's current program, including primary and excess property, liability package and excess, cyber, terrorism, deadly weapon protection, equipment breakdown, automobile and workers' compensation, effective June 1, 2026 and Jan. 1, 2026 — are deemed assumed by or continued for the reorganized debtor under sections 365, 1123(a)(5)(A) and 1123(b)(2) with all parties' rights unaltered. No cure payments are required for defaults existing as of the effective date unless the court orders or the parties agree otherwise, and the debtor reserves the right to seek rejection before the effective date.
• The debtor does not believe fully paid, expired-period policies are executory contracts. If the court disagrees, those contracts — including the subject policies — are rejected outside the assumed policies, with rejection deemed a prepetition breach; rejection does not impair any coverage rights, each insurer's coverage obligation remains independently required under Bengal Marine and Louisiana law, and the sole consequence is that an affected insurer may file a rejection damages claim treated in Class 4.

Insurance Recoveries and Survivor Litigation

• The plan trustee must actively pursue recoveries under the assigned interests, then liquidate and convert them to cash and distribute proceeds pro rata to holders whose allowed claims are covered by the applicable policy, as she determines under applicable law and, where necessary, as resolved by a court of competent jurisdiction. She is also authorized to pursue recovery of an unpaid judgment from any insurer.
• In lieu of pursuing recoveries, the trustee may sell the subject policies back to the issuing insurers for cash under sections 105 and 363 and Bankruptcy Rule 9019, allocating proceeds between the trust assets and the Future Claims Reserve and distributing pro rata to covered holders. Any insurance settlement, buyback or similar agreement requires court approval, with publication notice in outlets and for a duration the court directs; an approved settlement binds the trust and controls over the trust agreement where the two conflict.
• Before the second anniversary of the effective date the trustee may authorize survivors, at their own expense, to commence or resume litigation against the applicable insurer solely to pursue claims on the assigned interests. She must first consult the reorganized debtor, make a good faith determination that the claim is covered in whole or part — a determination that binds no one on ultimate coverage and preserves insurer defenses — and require execution of a post-effective-date litigation agreement satisfactory to her and the reorganized debtor, a copy of which goes to the reorganized debtor on execution. Survivors are excluded from litigating where the insurer has already bought back the relevant policy.
• Any award on a survivor claim is paid under the plan, the holder has no recourse against the reorganized debtor or its assets, and any recovery, including payment of a judgment, is deemed assigned to the Plan Trust.
• The reorganized debtor must make commercially reasonable efforts to cooperate in pursuit of the assigned interests, short of violating the policies, and to give the trustee access to the documents and information needed to defend claims being liquidated, which the trustee may verify to the best of the trustee's knowledge, information and belief rather than on personal knowledge. Where the trustee requests material action, the trust bears all resulting costs and expenses, including reasonable attorneys' fees.

Future Claims

• A future claim is a survivor claim that arose before the effective date where, as of that date, the court would conclude the survivor was unaware of the injury or the wrongdoing despite notice of the plan, or that court-approved notice would not satisfy due process as to that survivor, and in either case the failure to assert timely would be excused under applicable law. The plan's example is a bona fide assertion of repressed memories, with all objections to the scientific basis for such claims reserved.
• The Future Claims Reserve is a segregated portion of the trust assets sized in good faith by the trustee based on the number and value of already-liquidated or settled allowed claims and such other estimation methodologies as she deems appropriate, and in no event less than $50,000. It does not limit future claimants' right to insurance-derived proceeds where coverage is determined to exist.
• If no future claims are received by the 60th day before the final distribution date, the reserve is de-segregated into the trust's general accounts. If a future claim is first asserted after that date, the trustee must reserve reasonable amounts from remaining assets, in consultation with the future claims representative, and may not make a distribution that would materially impair the trust's ability to satisfy such claims.
• The future claims representative is discharged on the effective date but retains consultation rights over the trustee's disbursement of trust assets and the setting of the final distribution date, remains bound by confidentiality, joint defense, mediation and protective order obligations, and keeps the right to be heard on its own fee applications.

Distributions

• The reorganized debtor pays Classes 1 through 3 on the timing set by the treatment provisions. The trustee distributes on one or more interim distribution dates, no earlier than one year after the effective date, and on the final distribution date — the later of five years after the effective date or a reasonable time after resolution, in her discretion, of all liability and coverage issues on the assigned interests, fixed after accounting for unresolved future claims and any insurance litigation bearing on them and after consulting the future claims representative.
• Every Class 4 holder must execute a release satisfactory to the trustee and the reorganized debtor before receiving a distribution, running to the debtor, the reorganized debtor and the trust and, where the distribution includes insurance-derived proceeds, to the applicable insurers and any insureds or additional insureds under the policy, expressly including the parishes, meaning both the diocese's current parishes and missions, each separately incorporated under Louisiana nonprofit law, and the former Alexandria parishes now under the Diocese of Shreveport.
• No distributions are made on a disputed claim until objections are resolved and the claim is allowed. Post-petition interest does not accrue or get paid on any claim absent contrary provision in the plan, the confirmation order or a court-approved written agreement. Undeliverable distributions are reported to the court with the holder's last known address, and if still undeliverable after six months may be transferred to the Plan Trust. Payments falling due on a non-business day move to the next business day without interest, and all distributions are subject to withholding and reporting requirements.
• The reorganized debtor and the trustee each keep the right to set off claims they hold against a holder before distributing, without waiving those claims by doing so, and no holder may recoup against a claim of the debtor or reorganized debtor unless it actually performed the recoupment and gave written notice by the confirmation date.

Judgment Reduction and Contribution Bar

• A non-settling party is any person alleged to be liable in solido, jointly, severally or otherwise with the debtor on an abuse or survivor claim, regardless of ecclesiastical affiliation.
• From the effective date, no non-settling party or other person may commence, continue or pursue an abuse-related contribution claim against the reorganized debtor, which is forever released from all liability for contribution, indemnity, equitable indemnity, subrogation, reimbursement or other indirect or direct recovery arising from an abuse or survivor claim. Contribution claims disallowed under section 502(e)(1)(B) remain forever disallowed notwithstanding section 502(j) to the extent contingent at allowance, subject to the carve-outs for claims adjudicated noncontingent or determined noncontingent by final order before the effective date.
• In exchange, any judgment, award, verdict or settlement a holder obtains against a non-settling party is reduced and credited by the debtor's allocable share, leaving the non-settling party liable only for damages attributable to its own fault; the reduction is in all events no less than the amount needed to fully satisfy and extinguish the barred contribution claim, and constitutes the consideration for the bar.
• The allocable share is determined by the court adjudicating the underlying claim under non-bankruptcy law governing comparative fault and apportionment among joint tortfeasors, including Louisiana solidary obligation principles; the bankruptcy court retains jurisdiction to determine it if no other court does.
• Holders' direct claims against non-settling parties for their own several share are expressly preserved, and the article effects no release of any non-settling party. It does not apply to or affect any insurer's claims, rights or defenses, which are governed solely by the plan neutrality provisions and non-bankruptcy law; abuse-related contribution claims exclude any insurer claim for contribution.

Releases, Exculpation and Injunctions

• Debtor release: on the effective date the debtor, reorganized debtor and estate release each released party from all claims and causes of action, known or unknown, including derivative claims, arising from the debtor, its restructuring efforts, avoidance actions other than those brought as counterclaims or defenses, the Chapter 11 case, and the negotiation, execution and implementation of the plan and related documents through the effective date. Carved out are post-effective-date obligations under the plan or implementing documents and claims for acts determined by final order to constitute actual fraud, willful misconduct or gross negligence.
• Released parties are the debtor, the reorganized debtor, the estate, the plan trustee, the future claims representative, and each of their related entities. The plan states expressly that neither the Diocese of Shreveport, nor any parish or entity under its ecclesiastical jurisdiction, nor Bishop Marshall in his capacity as Apostolic Administrator of Shreveport is a released party or a related party.
• Exculpated parties are the debtor and its agents, representatives, members, principals, shareholders, officers, trustees and directors to the fullest extent permitted under the Fifth Circuit's decision in In re Highland Capital Mgmt., 132 F.4th 353 (5th Cir. 2025), together with the estate, the committee and each committee member in an official capacity, in each case solely for conduct within the scope of their duties in the case and the plan process. Bishop Marshall is exculpated only as an officer of the debtor, not as Apostolic Administrator of Shreveport. Exculpation reaches only acts during the period a person served in that capacity and never conduct before the petition date, excludes actual fraud, willful misconduct and gross negligence and post-effective-date obligations, and by its terms may not be read to exceed the scope of Highland Capital.
• Discharge injunction: under section 1141(d) the debtor is discharged on the effective date from claims arising before that date, including claims arising from or during the policy periods of the subject policies, and holders of discharged claims are permanently enjoined from commencing or continuing actions, enforcing judgments, creating or enforcing liens, or asserting setoff or subrogation against the debtor, the reorganized debtor or its property. Violations transfer the offending proceeding to the bankruptcy or district court on notice, and a party prevailing against a willful violation may seek costs and fees.
• Channeling injunction: on entry of the confirmation order, holders and parties in interest are enjoined from interfering with implementation of the plan; from and after the effective date, entities holding claims compromised, released, exculpated or otherwise discharged under the plan are permanently enjoined from pursuing them against the debtor, the reorganized debtor or the exculpated parties. No claim against those parties relating to the case or the plan process may be brought without the bankruptcy court first finding, after notice and a hearing, that it is colorable and specifically authorizing it; that court has sole and exclusive jurisdiction to adjudicate the underlying claim.
• The channeling injunction does not enjoin a survivor's direct, non-derivative claim against the Diocese of Shreveport and entities under its ecclesiastical jurisdiction, including the former Alexandria parishes, under non-bankruptcy law, subject to two exceptions the article states, one of which turns on whether the holder has yet executed a post-effective-date litigation agreement and the other on authorization under the trustee's Articles 5.03 and 5.06 powers. Apart from that carve-out the injunction does not enjoin actions against non-settling parties, but continues to apply in full to the debtor, the reorganized debtor and the exculpated parties.
• Release of liens: on the effective date, concurrently with distributions and, for secured claims, satisfaction in full of the allowed portion, all mortgages, liens, pledges and security interests against estate property are released and revert to the reorganized debtor without further order or filing.

Causes of Action

• The reorganized debtor retains and may exclusively enforce all causes of action not waived, released, exculpated, assigned to the trust or settled, including contract claims, coverage disputes under the subject policies, and claims under sections 362, 522, 541, 542, 543 and 553, whether arising before or after the petition date, and may prosecute, settle or abandon them without further court approval.
• The retention stops at the trust's door: any contract or coverage claim relating to or arising from the assigned insurance interests, and all rights relating to coverage for survivor or future claims, are assigned insurance interests owned and controlled by the Plan Trust.
• The debtor expressly waives every cause of action constituting an avoidance action.

Claims Administration

• The debtor pursues objections before the effective date; after it, the reorganized debtor handles all claims and the plan trustee handles Class 4 claims, with the trustee free to object to or establish allowance or estimation procedures for Class 4. The claim objection deadline is the later of the first business day at least one year after the effective date or such other period fixed by the debtor, reorganized debtor, plan trustee or the court.
• Proofs of claim filed after the applicable bar date under the bar date order [Docket No. 250] and objected to are deemed untimely and, if disallowed, receive nothing — except that a claim the court determines should be treated as a future claim may participate in the trust solely in that capacity. Future claims are submitted under the procedure in the trust agreement.
• A ballot is not an informal proof of claim and does not amend one, and any amendment to a timely filed proof of claim must be filed by the confirmation date, without prejudice to objections to the amendment.
• Either the debtor, the reorganized debtor or the plan trustee, depending on timing and claim type, may seek estimation under section 502(c) of amounts to be reserved or of the claim for allowance or other purposes, with the court determining whether estimation applies and on what timing.

Voting and Confirmation

• All four classes are impaired and entitled to vote; there are no deemed-accepting or deemed-rejecting classes. Future claims and the future claims representative do not vote.
• A class accepts on two-thirds in amount and more than one-half in number of allowed claims actually voting, excluding votes designated under section 1126(e) and insider votes. The debtor will seek confirmation under section 1129(b) as to any rejecting class and reserves the right to modify treatment or withdraw the plan before the confirmation date.
• The plan supplement is due four days before the voting deadline and will include the amended Southern Heritage Bank loan documents, filed before the confirmation hearing, and the proposed plan trustee.

Conditions Precedent and Withdrawal Rights

• The effective date requires, unless waived by the debtor without notice or further court action:
  • entry of the confirmation order as a final order;
  • receipt of all necessary Canon Law approvals to pursue confirmation;
  • execution and filing of the plan and all plan supplement documents;
  • no order of any court or regulator materially restricting or prohibiting consummation;
  • payment in full of all court-approved professional fees and expenses;
  • formation of the Plan Trust; and
  • court approval of the plan trustee's appointment.
• The debtor may revoke or withdraw the plan before the confirmation date and file subsequent plans, in its sole and absolute discretion, including on either of two stated grounds: excess liquidation value, if the court determines at confirmation that the amount required to satisfy section 1129(a)(7) for Class 4 exceeds $1.5 million; or a fiduciary out, if the debtor determines in good faith after consulting counsel that continued pursuit of the plan would be inconsistent with its fiduciary duties or its obligations as a debtor in possession.
• If the debtor withdraws, the confirmation order is not entered, or the effective date does not occur, the plan is null and void in all respects, along with any settlement or compromise embodied in it and any contract assumption or rejection it effected, and nothing in it waives claims, prejudices rights, constitutes an admission, or is admissible against the debtor in any forum.
• The debtor may amend the plan before confirmation and, after confirmation and on court order, may modify it under section 1127(b) to remedy defects or reconcile inconsistencies. Entry of the confirmation order approves post-solicitation modifications under section 1127(a) and constitutes a finding that they require no further disclosure or re-solicitation under Bankruptcy Rule 3019.

Reorganized Debtor and Governance

• The reorganization assets — all assets of the debtor and estate, excluding the trust assets — vest in the reorganized debtor on the effective date free and clear of liens, claims, charges and encumbrances, and it may operate, use, acquire or dispose of property and settle claims without court supervision except as the plan or confirmation order restricts.
• Exhibit E identifies the proposed directors and officers: Bishop Robert William Marshall, Jr. as president, who was appointed Apostolic Administrator of the Diocese of Shreveport on Sept. 15, 2026 by Pope Leo XIV and receives no compensation from that appointment beyond expense reimbursement, though Shreveport may reimburse a portion of his salary; Very Rev. Michael Craig Scott, pastor of St. James Memorial in Alexandria, as vice president-treasurer; Rev. Msgr. Scott Chemino, pastor of St. Anthony of Padua in Bunkie, as vice president; and Rev. Chad Partain, pastor of St. Frances Cabrini in Alexandria, as secretary. Officer compensation is set by the reorganized debtor in its sole discretion in the ordinary course after the effective date.
• The committee dissolves automatically on the effective date, with its members, professionals and agents released from further duties but remaining bound by confidentiality, joint defense, mediation and protective order obligations and retaining the right to be heard on professional fee applications.
• Executory contracts entered into before the petition date are assumed under sections 365 and 1123 effective as of the confirmation date, except those previously assumed or rejected, subject to a pending motion, or expressly rejected. Existing benefit programs are deemed assumed on the effective date, and the reorganized debtor continues to honor applicable workers' compensation laws and its workers' compensation program, with workers' compensation claims deemed withdrawn automatically and non-bankruptcy defenses and rights preserved.

U.S. Trustee Fees

• Fees due before the effective date are paid in full by the debtor on the effective date. From the effective date to the second anniversary, the reorganized debtor is solely responsible for fees on disbursements by or for the debtor or reorganized debtor; after that anniversary, the trust and trustee are deemed the successor for the payment obligation regardless of whose disbursements generate it.
• For section 1930(a)(6) and quarterly reporting purposes only, the trust is deemed the debtor's successor as to its own post-effective-date disbursements, and fees attributable to them are paid from trust assets — including insurance settlement proceeds and other recoveries — as a trust administrative expense ahead of Class 4 distributions, until the case is closed, converted or dismissed. Fees are assessed on the trust's distributions to Class 4 holders; the trust's receipt of contributions from the debtor or of insurance proceeds is not itself a disbursement.
• Where the U.S. Trustee collects fees directly from the debtor or reorganized debtor attributable to post-second-anniversary disbursements or to the trust's disbursements, the reorganized debtor has a right of contribution and reimbursement against the trust for the full amount, payable from trust assets within 30 days of written demand and carrying priority over Class 4 distributions.
• The plan states these provisions allocate funding responsibility without altering the debtor's or reorganized debtor's statutory liability, and that the confirmation order will constitute a final judgment binding the U.S. Trustee on the matters addressed, citing section 1141(a) and Matter of Linn Energy, 927 F.3d 862 (5th Cir. 2019). If the case is reopened in any action involving the trust, reopening costs including the statutory fee are borne solely by the trust, and by the reorganized debtor if the trust has already terminated; the reorganized debtor may seek to close the case before the trust is fully administered, and anticipated further trust distributions are not grounds for delay. The reorganized debtor and the trustee each file post-confirmation quarterly reports on their own disbursements until the case is closed, dismissed or converted.

Retention of Jurisdiction and Governing Law

• The bankruptcy court and district court retain exclusive jurisdiction consistent with 28 U.S.C. sections 157 and 1334 and Stern v. Marshall, 564 U.S. 462 (2011), including over claim allowance and estimation, the trustee's pro rata distribution determinations, interpretation and enforcement of the trust agreement and administration of the trust, matters concerning estate and trust assets and their liquidation, sales of the subject policies under sections 105 and 363 and Rule 9019, and interpretation and enforcement of the judgment reduction and contribution bar, including determining the allocable share where no other court has.
• Where the bankruptcy court lacks constitutional authority to enter final judgment, it submits proposed findings and conclusions to the district court for de novo review under section 157(c)(1) and Bankruptcy Rule 9033 absent party consent; personal injury tort and wrongful death claims are determined by the district court under section 157(b)(5), without prejudice to estimation for allowance, distribution or feasibility purposes.
• The trust agreement adds a fallback forum: the Louisiana courts, including any federal court sitting there, also have jurisdiction over the Plan Trust, but only if and to the extent the bankruptcy court cannot exercise or abstains from exercising jurisdiction over it.
• Louisiana law governs the plan and related documents and any governance matters of the trust or reorganized debtor, except where federal law supplies the rule. Section 1146 exempts transfers under the plan from stamp, transfer and similar taxes. On the effective date the plan and plan supplement become immediately effective and binding notwithstanding Bankruptcy Rules 3020(e), 6004(h) and 7062.