The Roman Catholic Church for the Archdiocese of N and Apostolates

UNITED STATES BANKRUPTCY COURT
EASTERN DISTRICT OF LOUISIANA
IN RE: 	§ 	CASE NO: 20-10846
§ 	(JOINTLY ADMINISTERED)
THE ROMAN CATHOLIC CHURCH 	§
OF THE ARCHDIOCESE OF NEW 	§ 	CHAPTER 11
ORLEANS,1 	§ 	COMPLEX CASE
§
DEBTOR. 	§ 	SECTION A
1 	An Order directing joint administration of the Chapter 11 bankruptcy case of The Roman Catholic
Church of The Archdiocese of New Orleans, [No. 20-10846], as lead case, with the Chapter 11 bankruptcy
cases of (i) All Saints Roman Catholic Church, New Orleans, Louisiana, [No. 25-12579], (ii) Annunciation
Of The Blessed Virgin Mary Roman Catholic Church, Bogalusa, Louisiana, [No. 25-12580], (iii) Ascension
Of Our Lord Roman Catholic Church, Laplace, Louisiana, [No. 25-12581], (iv) The Visitation Of Our Lady
Roman Catholic Church, Marrero, Louisiana, [No. 25-12582], (v) Assumption Of Mary Roman Catholic
Church, Avondale, Louisiana, [No. 25-12583], (vi) Assumption Of The Blessed Virgin Mary Roman
Catholic Church Braithwaite, Louisiana, [No. 25-12584], (vii) Blessed Francis Xavier Seelos Roman
Catholic Church, New Orleans, Louisiana, [No. 25-12585], (viii) Blessed Sacrament-St. Joan Of Arc
Roman Catholic Church, New Orleans, Louisiana, [No. 25-12586], (ix) The Congregation Of St. Rita
Roman Catholic Church Of Harahan, [No. 25-12587], (x) Blessed Trinity Roman Catholic Church, New
Orleans, Louisiana, [No. 25-12588], (xi) Christ The King Roman Catholic Church, Gretna, Louisiana, [No.
25-12589], (xii) Corpus Christi-Epiphany Roman Catholic Church, New Orleans, Louisiana, [No. 25-
12590], (xiii) Divine Mercy Roman Catholic Church, Kenner, Louisiana, [No. 25-12591], (xiv) Good
Shepherd Roman Catholic Church, New Orleans, Louisiana, [No. 25-12592], (xv) Sts. Peter And Paul
Roman Catholic Church, Pearl River, Louisiana, [No. 25-12593], (xvi) Holy Family Roman Catholic
Church, Franklinton, Louisiana, [No. 25-12594], (xvii) St. Thomas Roman Catholic Church, Pointe A La
Hache, Louisiana, [No. 25-12595], (xviii) Holy Family Roman Catholic Church, Luling, Louisiana, [No.
25-12596], (xix) St. Rita Roman Catholic Church, New Orleans, Louisiana, [No. 25-12597], (xx) Holy
Name Of Mary Roman Catholic Church, New Orleans, Louisiana, [No. 25-12598], (xxi) St. Rita Roman
Catholic Church, Harahan, Louisiana, [No. 25-12599], (xxii) Holy Spirit Roman Catholic Church, New
Orleans, Louisiana, [No. 25-12600], (xxiii) St. Raymond And St. Leo The Great Roman Catholic Church,
New Orleans, Louisiana, [No. 25-12601], (xxiv) Immaculate Conception Roman Catholic Church, Marrero,
Louisiana, [No. 25-12602], (xxv) Immaculate Conception Roman Catholic Church, New Orleans,
Louisiana, [No. 25-12603], (xxvi) St. Pius X Roman Catholic Church, New Orleans, Louisiana, [No. 25-
12604], (xxvii) Mary Queen Of Peace Roman Catholic Church, Mandeville, Louisiana, [No. 25-12605],
(xxviii) St. Philip Neri Roman Catholic Church, Metairie, Louisiana, [No. 25-12606], (xxix) Mary Queen
Of Vietnam Roman Catholic Church, New Orleans, Louisiana, [No. 25-12607], (xxx) St. Peter's Roman
Catholic Church, Covington, Louisiana, [No. 25-12608], (xxxi) Mary, Help Of Christians Roman Catholic
Church, Harvey, Louisiana, [No. 25-12610], (xxxii) St. Peter Roman Catholic Church, Reserve, Louisiana,
[No. 25-12611], (xxxiii) Mater Dolorosa Roman Catholic Church, New Orleans, Louisiana, [No. 25-
12612], (xxxiv) St. Peter Claver Roman Catholic Church, New Orleans, Louisiana, [No. 25-12613], (xxxv)
Most Holy Name Of Jesus Roman Catholic Church, New Orleans, Louisiana, [No. 25-12614], (xxxvi) St.
Paul The Apostle Roman Catholic Church, New Orleans, Louisiana, [No. 25-12615], (xxxvii) Most Holy
Trinity Roman Catholic Church, Covington, Louisiana, [No. 25-12616], (xxxviii) St. Patrick's Roman
Catholic Church, Port Sulphur, Louisiana, [No. 25-12617], (xxxix) Our Lady Of Divine Providence Roman
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Catholic Church, Metairie, Louisiana, [No. 25-12618], (xl) St. Patrick's Roman Catholic Church, New
Orleans, Louisiana, [No. 25-12619], (xli) St. Michael The Archangel Roman Catholic Church, Paradis,
Louisiana, [No. 25-12620], (xlii) Our Lady Of Grace Roman Catholic Church, Reserve, Louisiana, [No.
25-12621], (xliii) St. Martin De Porres Roman Catholic Church, New Orleans, Louisiana, [No. 25-12622],
(xliv) Our Lady Of Lavang Roman Catholic Church, New Orleans, Louisiana, [No. 25-12623], (xlv) St.
Matthew The Apostle Roman Catholic Church, River Ridge, Louisiana, [No. 25-12624], (xlvi) Our Lady
Of Lourdes Roman Catholic Church, Slidell, Louisiana, [No. 25-12625], (xlvii) St. Mary's Roman Catholic
Church, New Orleans, Louisiana, [No. 25-12626], (xlviii) Our Lady Of Lourdes Roman Catholic Church,
Violet, Louisiana, [No. 25-12627], (xlix) St. Mary Magdalen Roman Catholic Church, Metairie, Louisiana,
[No. 25-12628], (l) Our Lady Of Perpetual Help Roman Catholic Church, Belle Chasse, Louisiana, [No.
25-12629], (li) Our Lady Of Perpetual Help Roman Catholic Church, Kenner, Louisiana, [No. 25-12630],
(lii) Our Lady Of Prompt Succor Roman Catholic Church, Chalmette, Louisiana, [No. 25-12632], (liii) St.
Martha Roman Catholic Church, Harvey, Louisiana, [No. 25-12633], (liv) Our Lady Of Prompt Succor
Roman Catholic Church, Westwego, Louisiana, [No. 25-12634], (lv) St. Mark Roman Catholic Church,
Ama, Louisiana, [No. 25-12635], (lvi) Our Lady Of The Holy Rosary Roman Catholic Church, Hahnville,
Louisiana, [No. 25-12636], (lvii) Our Lady Of The Lake Roman Catholic Church, Mandeville, Louisiana,
[No. 25-12637], (lviii) St. Maria Goretti Roman Catholic Church, New Orleans, Louisiana, [No. 25-12638],
(lix) Our Lady Of The Rosary Roman Catholic Church, New Orleans, Louisiana, [No. 25-12639], (lx) St.
Margaret Mary Roman Catholic Church, Slidell, Louisiana, [No. 25-12640], (lxi) Resurrection Of Our Lord
Roman Catholic Church, New Orleans, Louisiana, [No. 25-12641], (lxii) St. Luke The Evangelist Roman
Catholic Church, Slidell, Louisiana, [No. 25-12642], (lxiii) Sacred Heart Of Jesus Roman Catholic Church,
Lacombe, Louisiana, [No. 25-12644], (lxiv) St. Louis, King Of France, Roman Catholic Church, Metairie,
Louisiana, [No. 25-12645], (lxv) Sacred Heart Of Jesus Roman Catholic Church, Norco, Louisiana, [No.
25-12646], (lxvi) St. Katharine Drexel Roman Catholic Church, New Orleans, Louisiana, [No. 25-12647],
(lxvii) St. Agnes Le Thi Thanh Roman Catholic Church, Marrero, Louisiana, [No. 25-12650], (lxviii) St.
Josephine Bakhita Roman Catholic Church, New Orleans, Louisiana, [No. 25-12651], (lxix) St. Agnes
Roman Catholic Church, Jefferson, Louisiana, [No. 25-12652], (lxx) St. Joseph's Roman Catholic Church,
Gretna, Louisiana, [No. 25-12653], (lxxi) St. Joseph The Worker Roman Catholic Church, Marrero,
Louisiana, [No. 25-12654], (lxxii) St. Andrew The Apostle Roman Catholic Church, New Orleans,
Louisiana, [No. 25-12655], (lxxiii) St. Joseph Roman Catholic Church, Algiers, Louisiana, [No. 25-12657],
(lxxiv) St. Angela Merici Roman Catholic Church, Metairie, Louisiana, [No. 25-12658], (lxxv) St. John
The Baptist Roman Catholic Church, Folsom, Louisiana, [No. 25-12659], (lxxvi) St. Ann Roman Catholic
Church And Shrine, Metairie, Louisiana, [No. 25-12660], (lxxvii) St. John The Baptist Roman Catholic
Church, Edgard, Louisiana, [No. 25-12661], (lxxviii) St. John Paul II Roman Catholic Church, Waggaman,
Louisiana, [No. 25-12663], (lxxix) St. Anselm Roman Catholic Church, Madisonville, Louisiana, [No. 25-
12664], (lxxx) St. John Of The Cross Roman Catholic Church, Lacombe, Louisiana, [No. 25-12665],
(lxxxi) St. Anthony Of Barataria Roman Catholic Church, Lafitte, Louisiana, [No. 25-12667], (lxxxii) St.
Joan Of Arc Roman Catholic Church, Laplace, Louisiana, [No. 25-12668], (lxxxiii) St. Joachim Roman
Catholic Church, Marrero, Louisiana, [No. 25-12669], (lxxxiv) St. Jerome Roman Catholic Church,
Kenner, Louisiana, [No. 25-12670], (lxxxv) St. Anthony Of Padua Roman Catholic Church, Luling,
Louisiana, [No. 25-12671], (lxxxvi) St. Jane De Chantal Roman Catholic Church, Abita Springs, Louisiana,
[No. 25-12672], (lxxxvii) St. Anthony Of Padua Roman Catholic Church, New Orleans, Louisiana, [No.
25-12673], (lxxxviii) St. Anthony Roman Catholic Church, Gretna, Louisiana, [No. 25-12674], (lxxxix) St.
Augustine Roman Catholic Church, New Orleans, Louisiana, [No. 25-12675], (xc) St. Genevieve Roman
Catholic Church, Slidell, Louisiana, [No. 25-12676], (xci) St. Benedict Roman Catholic Church,
Covington, Louisiana, [No. 25-12677], (xcii) St. Francis Xavier Roman Catholic Church, Metairie,
Louisiana, [No. 25-12678], (xciii) St. Benilde Roman Catholic Church, Metairie, Louisiana, [No. 25-
12679], (xciv) St. Francis Of Assisi Roman Catholic Church, New Orleans, Louisiana, [No. 25-12680],
(xcv) St. Bernard Roman Catholic Church, St. Bernard, Louisiana, [No. 25-12681], (xcvi) St. Edward The
Confessor Roman Catholic Church, Metairie, Louisiana, [No. 25-12682], (xcvii) St. Catherine Of Siena
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Roman Catholic Church, Metairie, Louisiana, [No. 25-12683], (xcviii) St. Dominic's Roman Catholic
Church, New Orleans, Louisiana, [No. 25-12684], (xcix) St. Charles Borromeo Roman Catholic Church,
Destrehan, Louisiana, [No. 25-12685], (c) St. David Roman Catholic Church, New Orleans, Louisiana,
[No. 25-12686], (ci) St. Christopher Roman Catholic Church, Metairie, Louisiana, [No. 25-12687], (cii) St.
Cletus Roman Catholic Church, Gretna, Louisiana, [No. 25-12688], (ciii) St. Clement Of Rome Roman
Catholic Church, Metairie, Louisiana, [No. 25-12689], (civ) Blessed Sacrament, Inc., [No. 25-12690], (cv)
The Congregation Of The Holy Trinity Roman Catholic Church, [No. 25-12691], (cvi) Epiphany, Inc., [No.
25-12692], (cvii) The Congregation Of The Annunciation Roman Catholic Church, [No. 25-12693], (cviii)
The Congregation Of St. Cecelia Roman Catholic Church, [No. 25-12694], (cix) Immaculate Heart Of
Mary, Inc., [No. 25-12695], (cx) Incarnate Word, Inc., [No. 25-12696], (cxi) The Congregation Of Saints
Peter And Paul Roman Catholic Church, [No. 25-12697], (cxii) St. Theresa Of The Child Jesus, Inc., [No.
25-12698], (cxiii) Our Lady Of Good Harbor, Inc., [No. 25-12699], (cxiv) St. Theresa Of Avila, Inc., [No.
25-12700], (cxv) Our Lady Of Good Counsel, Inc., [No. 25-12701], (cxvi) St. Rose Of Lima, Inc., [No. 25-
12702], (cxvii) Our Lady Of Lourdes, New Orleans, Louisiana, Inc., [No. 25-12703], (cxviii) St.
Raymond’s, Inc., [No. 25-12704], (cxix) Our Lady Of The Sacred Heart, New Orleans, Louisiana, Inc.,
[No. 25-12705], (cxx) St. Philip The Apostle, Inc., [No. 25-12706], (cxxi) Our Lady Star Of The Sea, Inc.,
[No. 25-12707], (cxxii) St. Monica, Inc., [No. 25-12708], (cxxiii) St. Ann, New Orleans, Louisiana, Inc.,
[No. 25-12709], (cxxiv) St. Maurice, Inc., [No. 25-12710], (cxxv) St. Bonaventure, Inc., [No. 25-12711],
(cxxvi) St. Louise De Marillac, Inc., [No. 25-12712], (cxxvii) St. Frances Xavier Cabrini, Inc., [No. 25-
12713], (cxxviii) St. Lawrence The Martyr, Inc., [No. 25-12715], (cxxix) St. Julian Eymard, Inc., [No. 25-
12716], (cxxx) St. Francis De Salles, Inc., [No. 25-12717], (cxxxi) St. John The Baptist, New Orleans,
Louisiana, Inc., [No. 25-12718], (cxxxii) St. Gabriel, Inc., [No. 25-12719], (cxxxiii) St. John Bosco, Inc.,
[No. 25-12720], (cxxxiv) St. Gertrude, Inc., [No. 25-12721], (cxxxv) St. James Major, Inc., [No. 25-12723],
(cxxxvi) St. Henry's, Inc., [No. 25-12724], (cxxxvii) St. Hubert, Inc., [No. 25-12725], (cxxxviii)
Archdiocesan Spirituality Center, [No. 25-12726], (cxxxix) Catholic Charities Archdiocese Of New
Orleans, [No. 25-12727], (cxl) Catholic Charities Children's Day Care Centers, [No. 25-12728], (cxli)
Catholic Charities Group Homes, [No. 25-12729], (cxlii) Clarion Herald Publishing Company, [No. 25-
12730], (cxliii) Korean Catholic Community Of New Orleans, Inc., [No. 25-12731], (cxliv) Notre Dame
Seminary, [No. 25-12732], (cxlv) Our Lady Of Mount Carmel Latin Mass Community, Covington,
Louisiana, [No. 25-12733], (cxlvi) Pace Greater New Orleans, [No. 25-12734], (cxlvii) Padua House, [No.
25-12735], (cxlviii) Philmat, Inc., [No. 25-12736], (cxlix) Project Lazarus, [No. 25-12737], (cl) Roman
Catholic Center Of Jesus The Lord, [No. 25-12738], (cli) School Food And Nutrition Services Of New
Orleans, Inc., [No. 25-12739], (clii) Second Harvest Food Bank Of Greater New Orleans And Acadiana,
[No. 25-12740], (cliii) St. Jude Community Center, Inc., [No. 25-12741], (cliv) St. Michael Special School,
[No. 25-12742], (clv) St. Therese Catholic Academy, [No. 25-12743], and (clvi) The Society For The
Propagation Of The Faith, Archdiocese Of New Orleans, [No. 25-12744], was entered on November 13,
2025, [No. 20-10846, ECF 4603; No. 25-12579, ECF 4; No. 25-12580, ECF 4; No. 25-12581, ECF 4; No.
25-12582, ECF 4; No. 25-12583, ECF 4; No. 25-12584, ECF 4; No. 25-12585, ECF 4; No. 25-12586, ECF
4; No. 25-12587, ECF 4; No. 25-12588, ECF 4; No. 25-12589, ECF 4; No. 25-12590, ECF 4; No. 25-
12591, ECF 4; No. 25-12592, ECF 4; No. 25-12593, ECF 4; No. 25-12594, ECF 4; No. 25-12595, ECF 4;
No. 25-12596, ECF 4; No. 25-12597, ECF 4; No. 25-12598, ECF 4; No. 25-12599, ECF 4; No. 25-12600,
ECF 4; No. 25-12601, ECF 4; No. 25-12602, ECF 4; No. 25-12603, ECF 4; No. 25-12604, ECF 4; No. 25-
12605, ECF 4; No. 25-12606, ECF 4; No. 25-12607, ECF 4; No. 25-12608, ECF 4; No. 25-12610, ECF 4;
No. 25-12611, ECF 4; No. 25-12612, ECF 4; No. 25-12613, ECF 4; No. 25-12614, ECF 4; No. 25-12615,
ECF 4; No. 25-12616, ECF 4; No. 25-12617, ECF 4; No. 25-12618, ECF 4; No. 25-12619, ECF 4; No. 25-
12620, ECF 4; No. 25-12621, ECF 4; No. 25-12622, ECF 5; No. 25-12623, ECF 4; No. 25-12624, ECF 4;
No. 25-12625, ECF 4; No. 25-12626, ECF 4; No. 25-12627, ECF 4; No. 25-12628, ECF 4; No. 25-12629,
ECF 4; No. 25-12630, ECF 4; No. 25-12632, ECF 4; No. 25-12633, ECF 4; No. 25-12634, ECF 4; No. 25-
12635, ECF 4; No. 25-12636, ECF 4; No. 25-12637, ECF 4; No. 25-12638, ECF 4; No. 25-12639, ECF 4;
No. 25-12640, ECF 4; No. 25-12641, ECF 4; No. 25-12642, ECF 4; No. 25-12644, ECF 4; No. 25-12645,
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MEMORANDUM OPINION SUPPLEMENTING CONFIRMATION ORDER
The Court enters this Memorandum Opinion to memorialize the oral ruling of the Court
made on December 8, 2025, to resolve two remaining objection to plan confirmation:
The Court makes these findings of fact and conclusions of law pursuant to Bankruptcy
Rules 7052 and 9014. 	The Court’s oral findings are hereby incorporated into the written
confirmation order that will be issued by this Court.
Before the Court is the objection asserted by Travelers Insurance Company to the
confirmation of the (now) Seventh Amended Plan of Reorganization proposed by the Debtor, the
Additional Debtors, and the Official Committee of Unsecured Creditors. As stated on the record
at the last hearing, the Seventh Amended Plan has resolved all of Travelers’ objections, including
any of its “Insurance Neutrality” objections, save two.
ECF 4; No. 25-12646, ECF 4; No. 25-12647, ECF 4; No. 25-12650, ECF 4; No. 25-12651, ECF 4; No. 25-
12652, ECF 4; No. 25-12653, ECF 4; No. 25-12654, ECF 4; No. 25-12655, ECF 4; No. 25-12657, ECF 4;
No. 25-12658, ECF 4; No. 25-12659, ECF 4; No. 25-12660, ECF 4; No. 25-12661, ECF 4; No. 25-12663,
ECF 4; No. 25-12664, ECF 4; No. 25-12665, ECF 4; No. 25-12667, ECF 4; No. 25-12668, ECF 4; No. 25-
12669, ECF 4; No. 25-12670, ECF 4; No. 25-12671, ECF 4; No. 25-12672, ECF 4; No. 25-12673, ECF 4;
No. 25-12674, ECF 4; No. 25-12675, ECF 4; No. 25-12676, ECF 4; No. 25-12677, ECF 4; No. 25-12678,
ECF 4; No. 25-12679, ECF 4; No. 25-12680, ECF 4; No. 25-12681, ECF 4; No. 25-12682, ECF 4; No. 25-
12683, ECF 4; No. 25-12684, ECF 4; No. 25-12685, ECF 4; No. 25-12686, ECF 4; No. 25-12687, ECF 4;
No. 25-12688, ECF 4; No. 25-12689, ECF 4; No. 25-12690, ECF 4; No. 25-12691, ECF 4; No. 25-12692,
ECF 4; No. 25-12693, ECF 4; No. 25-12694, ECF 4; No. 25-12695, ECF 4; No. 25-12696, ECF 4; No. 25-
12697, ECF 4; No. 25-12698, ECF 4; No. 25-12699, ECF 5; No. 25-12700, ECF 4; No. 25-12701, ECF 4;
No. 25-12702, ECF 4; No. 25-12703, ECF 4; No. 25-12704, ECF 4; No. 25-12705, ECF 4; No. 25-12706,
ECF 4; No. 25-12707, ECF 4; No. 25-12708, ECF 4; No. 25-12709, ECF 4; No. 25-12710, ECF 4; No. 25-
12711, ECF 4; No. 25-12712, ECF 4; No. 25-12713, ECF 4; No. 25-12715, ECF 4; No. 25-12716, ECF 4;
No. 25-12717, ECF 4; No. 25-12718, ECF 4; No. 25-12719, ECF 4; No. 25-12720, ECF 4; No. 25-12721,
ECF 4; No. 25-12723, ECF 4; No. 25-12724, ECF 4; No. 25-12725, ECF 4; No. 25-12726, ECF 4; No. 25-
12727, ECF 4; No. 25-12728, ECF 4; No. 25-12729, ECF 3; No. 25-12730, ECF 4; No. 25-12731, ECF 4;
No. 25-12732, ECF 4; No. 25-12733, ECF 4; No. 25-12734, ECF 4; No. 25-12735, ECF 4; No. 25-12736,
ECF 4; No. 25-12737, ECF 4; No. 25-12738, ECF 4; No. 25-12739, ECF 4; No. 25-12740, ECF 4; No. 25-
12741, ECF 4; No. 25-12742, ECF 4; No. 25-12743, ECF 4; No. 25-12744, ECF 4].
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Of import to the Court’s ruling is the manner in which the proposed plan treats Class 3
Known Abuse Claims and Class 4 Unknown Abuse Claims. At a high level, the plan provides that
a settlement trust will be created on or before the Effective Date and will be funded free and clear
with $130 million cash-on-hand on the Effective Date, and, ultimately, with another $70 million
from the sale of Christopher Homes, guaranteed by two promissory notes issued by the Debtor
and/or Additional Debtors, as well as approximately $30 million from certain Settling Insurers.
The transactions with Settling Insurers involved settlements with the Debtors and Additional
Debtors under Bankruptcy Rule 9019, culminating in the Settling Insurers’ purchase of certain of
Debtors’ insurance policies free and clear under § 363 of the Bankruptcy Code. The motions to
effect those transactions were noticed separate and apart from the plan and approved by separate
orders of this Court. No objections were filed before the entry of those orders. The plan recognizes
and incorporates those orders. The settlement trustee appointed through the plan has sole fiduciary
duty to administer the trust.
Travelers is not a Settling Insurer and none of the funds transferred to the settlement trust
are proceeds paid from any settlement between Travelers and the Debtor and Additional Debtors.
But on the Effective Date, any and all rights and claims belonging to abuse claimants, the Debtor,
and any co-insured party under applicable policies issued by Travelers to the Debtor and/or any
co-insured will be transferred to the settlement trust. In exercising his fiduciary duty to administer
the trust, the settlement trustee has sole authority to liquidate, settle, or even abandon any claims
or causes of action transferred to the settlement trust.
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I. 	PLAN OBJECTION ONE: “The Joint Plan Must Not Impair Travelers’ Ability
To Object to Abuse Claims” (ECF Doc. 4563, ¶¶ 25-28)
In its objection, Travelers asserts that its “right to object to Abuse Claims, including those
filed after the March 1, 2021 bar date established by this Court . . . should be fully preserved under
the Joint Plan.”
Let’s first talk about Travelers’ rights pre-confirmation to object to proofs of claim.
Section 502 of the Bankruptcy Code governs allowance of claim or interests and states in relevant
part that “[a] claim or interest, proof of which is filed under section 501 of this title, is deemed
allowed, unless a party in interest . . . objects.” 	Section 1109(b) of the Bankruptcy Code provides
that “[a] party in interest, including the debtor, the trustee, a creditors’ committee, an equity
security holders’ committee, as creditor, an equity security holder, or any indenture trustee, may
raise and may appear and be heard on any issue in a case under this chapter.” The plain wording
of § 1109(b) lists entities that are “parties in interest” but that list is not an exclusive one. “Courts
have long recognized that the meaning of the term [party in interest] must be determined on an ‘ad
hoc’ basis, and the categories mentioned in Section 1109 are not meant to exclude other types of
interested parties from the purview of that section.” In re Roman Catholic Diocese of Albany, New
York, No. 23-10244, 2025 WL 2536165, at *2 (Bankr. N.D.N.Y. Sept. 3, 2025) (quoting Savage
& Assocs. P.C. v. K&L Gates LLP (In re Telegent, Inc.), 640 F.3d 53, 60 (2d Cir. 2011)). 	The
Supreme Court recognized in Truck Insurance Exchange v. Kaiser Gypsum Co., that the use of
§ 1109(b)’s broad language was part of an “effort to encourage and promote greater participation
in reorganization cases,” as Congress was concerned that “a few insiders, whether representatives
of management or major creditors, could use the reorganization process to gain an unfair
advantage.” 602 U.S. 268, 280 (2024).
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Since the passage of the 1978 Bankruptcy Code, courts have been called upon to define
who is a party in interest in various contexts and situations that arise during the course of a chapter
11 bankruptcy case. But as observed by Judge Glenn in In re MF Global Holdings, Ltd., although
“[a] ‘party in interest’ is broadly defined by the statute . . . an entity that does not hold a financial
stake in the case is generally excluded from the definition of ‘party in interest.’” 469 B.R. 177,
188 (Bankr. S.D.N.Y. 2012). And you see that general rule applied over and over again in chapter
11, including by the Supreme Court in Truck Insurance Exchange, where the Court held that “an
insurer with financial responsibility for bankruptcy claims is a ‘party in interest’ that may
object to a chapter 11 plan of reorganization.” 602 U.S. at 285.
During the course of this bankruptcy case, hundreds of abuse claimants filed proofs of
claim against the Debtor or Additional Debtors—not against Travelers. Unlike the insurer in Truck
Insurance Exchange, Travelers’ liability to defend and pay on abuse claims here has neither been
adjudicated nor has Travelers formally accepted responsibility to pay for those claims. 	In fact,
currently pending before the Court is Travelers’ motion to terminate the automatic stay to allow it
to file a declaratory action in federal district court challenging insurance coverage for abuse claims
filed against the Debtor and/or Additional Debtors. [ECF Doc. 4404]. Judge Littlefield in In re
Roman Catholic Diocese of Albany, New York, asks a great question: 	How can insurance
companies claim standing to object to proofs of claim on the basis that they are likely to contribute
to the bankruptcy distribution while simultaneously claiming they are under no obligation to make
said contribution? See 2025 WL 2536165, at *5. As he correctly pointed out: “[T]he allowance
of a claim creates an obligation for the Diocese, not the Insurers; that obligation is not real until
either the Insurers concede liability or are otherwise adjudicated to be responsible.” Id. at *6.
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Of course, when Judge Littlefield declined to find that the insurers before him had standing
to object to proofs of claim, there was no plan on file in that bankruptcy case. Does the analysis
change here now that the Court is considering a plan that would assign the Debtors’ and Additional
Debtors’ interests in insurance claims and recoveries against Travelers to the settlement trust? The
Court is not convinced that it does, especially since, at this time, the only articulated basis for
Travelers’ objections to abuse claimants’ proofs of claim is to find them untimely filed in the
bankruptcy case. The purpose of a bar date in a chapter 11 case is to ensure finality and fix the
universe of the debtor’s liability—not Travelers’. As observed by Judge Goldblatt in In re AIO
US, Inc., “the case law on party-in-interest standing under § 1109(b) limits an objector to asserting
its own rights—it may not assert the rights of others.” 672 B.R. 261, 273 (Bankr. D. Del. 2025).
And as he also acknowledged, “[t]he Supreme Court has, in other contexts, expressed due concern
for the risk that a party may seek to weaponize its procedural rights to participate in litigation to
serve some ulterior purpose.” Id. (citing Bell Atl. v. Twombly, 550 U.S. 544, 558 (2007) and Truck
Ins. Exchange, 602 U.S. at 282).
Nevertheless, heeding Judge Goldblatt’s advice in In re AIO US, Inc., that “in a close case,
one should err on the side of considering an objection on the merits as opposed to disregarding it
on the ground that the objector lacks standing, and employ other tools as appropriate to guard
against the potential misuse of the procedural right to be heard for tactical purposes,” 672, B.R. at
277, the Court will rule on the merits of Travelers’ objection.
This plan contemplates that abuse claims will be channeled post-confirmation into the
settlement trust for final liquidation and payment, as is common in mass tort bankruptcy cases.
Travelers is concerned that the Debtor’s agreement to allow as timely filed those abuse claims that
were filed after the bar date, but before May 16, 2025 (when the settlement between the Debtor,
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the Additional Debtors, and the Committee was announced), “would potentially lead to
‘allowance’ and payment of many untimely and unwarranted claims to the detriment of the holders
of timely-filed Abuse Claims.” [ECF Doc. 4563, ¶ 27]. Although the Court commends Travelers’
regard for holders of timely filed abuse claims, Travelers’ own rights are well protected. 	The
settlement trust will not be funded by any contribution by Travelers without Travelers’ consent via
settlement or adjudication by a court of competent jurisdiction. 	Section 7.4 of the plan further
reserves all of Travelers’ rights and defenses. In the event that the settlement trustee approves the
filing of a litigation claim against Travelers in a state or federal court with competent jurisdiction—
Travelers is free to assert a defense pertaining to the timeliness of the filing of any proof of claim
in this bankruptcy case before that tribunal.
Accordingly, the Court overrules Travelers’ objection. 	To clear up any confusion or
incongruency between the plan and the allocation protocol, the Court strikes any grant to Travelers
as a Non-Settling Insurer, of the right contained in §§ 4.3(b) and 4.4(b) of the plan to object to
proofs of claim filed by abuse claimants as contrary to applicable law.
II. 	PLAN OBJECTION TWO: 	“The Joint Plan Fails To Sufficiently Protect Non-
Settling Insurer Contribution Claims.” (ECF Doc. 4563, ¶¶ 18–24)
With no ability to recover directly from a Settling Insurer for contribution in the event that
an abuse claimant or the settlement trust (as assignee of the abuse claimant) obtains a judgment
against Travelers in subsequent post-confirmation litigation, § 6.9(d) of the plan provides that
Travelers’ liability to the settlement trust is offset and reduced by the amount that any Settling
Insurer is found liable to pay Travelers.
Travelers’ remaining objection is limited to its inability under the plan to seek contribution
of defense costs from an abuse claimant or the settlement trust (as assignee of the abuse claimant)
in the event that an abuse claimant pursues her claim in a court of competent jurisdiction and
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Travelers obtains a judgment in that litigation or in separate coverage litigation that it is not liable
for the claim. 	In other words, can Travelers recoup its defense costs if an abuse claimant gets
“zero’d out” at trial or if Travelers wins in any action seeking a declaration that there is no coverage
obligations for the sexual abuse claims alleged in this case?
At oral argument, Travelers cited Arceneaux v. Amstar Corporation, 200 So. 3d 277 (La.
2016), to assert that under Louisiana law, “an insurer that defends an indemnity is responsible for
its pro rata share when there is overlapping coverage” and that Louisiana law is “clear” that we
consider “time on the risk that determines how the pro rata shares among co-primary insurers are
determined.” [ECF Doc. 4765]. Travelers asserted its right to recoup defense costs from alleged
co-primary insurers is an equitable one, not based in contract. See id.
In Louisiana, as in most, if not all states, an insurer’s obligation to defend suits against its
insured is broader than its liability for damage claims. The Louisiana Supreme Court articulated
the now long-held rule in Louisiana regarding an insurer’s duty to defend its insured in 1969 in
the case captioned American Home Assurance Co. v. Czarniecki,:
The insurer’s duty to defend suits brought against its insured is determined by the
allegations of the injured plaintiff’s petition, with the insurer being obligated to
furnish a defense unless the petition unambiguously excludes coverage.
Thus, if, assuming all the allegations of the petition to be true, there would be both
(1) coverage under the policy and (2) liability to the plaintiff, the insurer must
defend the insured regardless of the outcome of the suit.
230 So.2d 253, 259 (La. 1969). 	That pronouncement by the Louisiana Supreme Court became
known as the “eight-corners rule”; that is, an insurer must look to the four corners of the petition
and the four corners of the policy to determine whether it has a duty to defend. The general rule
in Louisiana when an insurer seeks contribution for defense costs from another insurer is to
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apportion defense costs equally by head. See, e.g., Vaughn v. Franklin, 785 So.2d 79, 89 (La. 1
Cir. 2001).
The Arceneaux case cited by Travelers is not reflective of the general rule, but identifies a
method of allocating indemnification as well as defense costs that was adopted to deal specifically
with long-latency occupational disease cases:
As to an insurer’s duty to indemnify, liability is to be prorated among insurance
carriers that were on the risk during periods of exposure to injurious conditions.
That indemnification is allocated pro rata is based in large part on Louisiana’s
adoption of the exposure theory in long latency disease cases. 	Long latency
occupational disease cases are sui generis in that a distinct body of jurisprudential
law has been developed which applies solely to them. Under the exposure theory,
the “occurrence” that triggers coverage under an insurance policy is the plaintiff’s
exposure to harmful conditions within the policy period. Such a theory was adopted
to establish when coverage was triggered in cases that involved diseases when there
is a “lengthy temporal separation between the alleged tortious conduct and the
appearance of injury.” 	This approach is based on the concept that insurers may
limit their liability to discrete and finite periods.
200 So. 3d at 282. Based on specific language in the policy before it, the Arseneaux court adopted
the reasoning applied in a U.S. Court of Appeals for the Sixth Circuit case, Insurance Co. of North
America v. Forty-Eight Insulations, Inc., 633 F.2d 1212 (6th Cir. 1980), to apply a pro rata method
of apportioning defense costs in the long-latency disease case before it. In Arseneaux, that meant
apportioning defense costs between an insurer and its insured that was actually considered self-
insured for periods of no coverage. The Arseneaux court observed:
The duty to defend arises solely under contract. It is well-settled that “an insurance
policy is a contract between the parties and should be construed using the general
rules of interpretation of contract set forth in the Civil Code. . . .”
While the duty to defend is broader than the duty to indemnify, neither obligation
is broader than the policy’s coverage period in the context of long latency disease
cases that trigger occurrence-based policies. In addition, the concept of “joint and
several” is not a concept that is currently a part of Louisiana’s tort law. . . .
Having concluded that defense costs are to be prorated in this case, we now
determine the formula for allocation. In this case . . . the amount of time an insurer
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was on the risk would seem to be the appropriate consideration. Because the duty
to defend is distinct from the duty to indemnify, the details of the policy need not
enter the equation of how defense costs are to be allocated so long as the policy is
triggered.
200 So. 3d at 286, 289.
This Court has not located a Louisiana case that treats child sexual abuse as a long-latency
occupational disease as it has with asbestos-disease and hearing loss. Indeed, it stretches common
sense to imagine characteristics of child sexual abuse to include “lengthy temporal separation
between the alleged tortious conduct and the appearance of injury,” but that issue is not before the
Court. 	But whether Louisiana’s more general apportionment-by-head method applies or
Arseneaux’s pro rata apportionment applies to insurers seeking to recoup defense costs from other
insurers in cases of child sexual abuse claims, Travelers has a problem: There is no “equitable”
right to such contribution under Louisiana law and the record before the Court shows that there is
no overlapping coverage for any of the years covered by Travelers.
Travelers relies heavily on the holding in In re Boy Scouts of America, 137 F.4th 126, 168
(3d Cir. 2025), for the proposition that a plan of reorganization that denies a non-settling insurer
the ability to recover defense costs represents a non-consensual third-party release of the non-
settling insurer’s claims in violation of the Supreme Court’s holding in Harrington v. Purdue
Pharma, L.P., 603 U.S. 204 (2024). 	[ECF Doc. 4563]. 	But the facts in that case are markedly
different from those here. In the Boy Scouts case, a primary insurer settled with the debtor and an
overlapping excess carrier found itself unexpectedly incurring defense costs it had the right to
recoup. 	Here, as a primary insurer with no overlapping co-primary insurers, Travelers is required
to absorb its own defense costs and has no claim of contribution of defense costs from an abuse
claimant or the settlement trust (as assignee of the abuse claimant).
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For that reason, the existence of the “Judgment Reduction” provision in § 6.9(d) of the plan
is sufficient to ensure Travelers can obtain full satisfaction and adequate protection for the loss of
any right it may hold to obtain contribution from Settling Insurers. The Court finds that the Purdue
Pharma prohibition on non-consensual, third-party releases is not implicated here.
Accordingly, the Court overrules Travelers’ objection.
III. 	CONFIRMATION RULING
Before the Court is the Seventh Amended Joint Chapter 11 Plan of Reorganization for the
Roman Catholic Church on the Archdiocese of New Orleans and Additional Debtor, Proposed by
the Debtor, the Additional Debtors, and the Official Committee of Unsecured Creditors, Dated as
of December 1, 2025, with attached exhibits, [ECF Doc. 4738].
All objections to the Plan have been either compromised and withdrawn or overruled.
The Court listened to days of testimony from experts and fact witnesses on behalf of the
plan proponents, with robust cross-examination by counsel for the United States Trustee and the
Bond Trustee. 	The testimony included the testimony from Archbishop Gregory Aymond and
Archbishop James Checchio and culminated in deeply personal accounts given in this courtroom
by 23 abuse survivors. 	I also reviewed four written survivor statements that reached the Court
over the weekend.
To Survivors: I would like you to know how valuable and powerful your voices are. Each
of you showed immeasurable courage to stand tall and speak your truth not just for yourselves, but
for all Survivors who could not come forward.
I have sat with the things you told me for almost a week now.
I heard you when you told me the horror of how you were hurt. I heard you when you told
me how you were deceived. Exploited. Alone. Shattered.
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I heard you when you told me how you suffered and continue to suffer. How you have been
heartbroken. How you have felt powerless. And abandoned. And not believed. And discarded.
I heard you when you told me you became angry. And stayed angry.
I heard you when you told me you drank, used drugs, gambled, and binged to try and get
away from the all-consuming pain.
I heard you when you told me that your relationships fell apart. That you didn’t know how
to trust. And just couldn’t trust.
I heard you when you told me you were homeless. Couldn’t work. Couldn’t sleep or eat.
I heard you when you told me you lost your faith. When you described your “dark life.”
I heard you and ached for you when you told me you wanted to die.
But I also heard you when you told me that you found someone who listened and did not
leave.
I heard you when you told me found your faith again. I heard you recite Philippians 4:13.
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I heard you when you told me you found healthy love. And when you told me that you
were able to show healthy love.
I heard the power in your voice and saw resilience in your face.
Most of all, I saw and felt hope.
No court system could ever make Survivors whole.
I heard and believed Survivors when they told me that the abuse they suffered continues to
affect every aspect of their lives and the lives of their friends and family. They described a rotting
ripple effect resulting from abuse.
To be clear: The poison of child abuse affects everyone in our community. Even if you
are unaware that you know someone who has suffered abuse, the betrayal of any child in our
community destroys the things we all search for. We yearn for the safety of family, for friendships,
for connection, and for the kinds of fellowship that are built through ministries, cultural activities,
youth sports, and community outreach by the people in churches, in our schools, and in other
public-service organizations. 	Child abuse takes those things away. 	It sows mistrust. 	It breeds
isolation.
So let’s do something about it today.
Based on the record before it, the Court finds that all elements required for confirmation of
this plan under § 1129 of the Bankruptcy Code have been met. The Court specifically finds that
the Plan has been filed in good faith and by no means forbidden by law pursuant to § 1129(a)(3).
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The Court also finds that, while not perfect, the non-monetary remedies when implemented
represent a good chance that we will not wind up here again. The Court reminds everyone that the
non-monetary terms of this Plan represent the floor—not the ceiling—on our efforts to prevent
and detect abuse and promote transparency and healing. 	Thus, the Court finds that the plan
proponents have satisfied the requirements of § 1129(a)(11).
Confirmation of this plan is a first step in validating and healing the hurt endured by
Survivors and those who love them. Together, the Church, Survivors, and the rest of us have a
real opportunity to do something extraordinary. We have the chance to take responsibility. 	To
rebuild trust. And to lead.
I commend the hard work and steadfastness of the professionals and lay volunteers in this
case.
This plan is complex and has many moving parts, particularly in light of the non-monetary
remedies featuring the Survivors Bill of Rights that will be implemented. I could be mistaken, but
I don’t believe that this country has seen anything as progressive yet in these cases. Although I
know that the Debtor and the Additional Debtors will move as quickly as possible to implement
all of the mechanics, many of the terms of the plan depend upon bringing human resources and
advisors on board. That said, the Court believes it is a good idea to schedule a status conference
for about six months out, on Thursday, May 21, 2026, at 1:30 pm. It will be a great opportunity
to see how we’re doing.
I would ask the Debtor to make the changes to the two sections of the plan that are affected
by the Court’s ruling on Travelers’ objections, file a clean, final version, and if necessary, send an
updated proposed confirmation order to the Court for docketing. I am confident we can process
the order today.
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New Orleans, Louisiana, December 9, 2025.
__________________________________________
MEREDITH S. GRABILL
UNITED STATES BANKRUPTCY JUDGE
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