NEW YORK - Bankrupt Lightsquared Inc. on March 11 filed a brief in the U.S. Bankruptcy Court for the Southern District of New York arguing that its key employee incentive plan (KEIP) should be modified to provide cash bonuses to key employees if the company successfully receives new funding and achieves a successful change of control in the company under its plan of reorganization (In Re: Lightsquared Inc., No. 12-12080, Chapter 11, S.D. N.Y. Bkcy.).