iHeartMedia Inc., a radio-station operator that filed for bankruptcy in March, is seeking a judge's approval for a bonus plan that could pay its top executives as much as $33 million next year.

In papers filed Tuesday in U.S. Bankruptcy Court in Houston, iHeart lawyers said the bonuses — earmarked for 11 executives — are needed to motivate its top managers.

Without the bonuses "in a highly competitive and challenging industry," compensation for top executives would fall well below peer companies and that "could significantly undermine" iHeart's ability to motivate senior management, court filings said.

Among those in line for a bonus is Chief Executive Robert Pittman. The MTV co-founder, who has led iHeart since 2011, collected more than $14 million in the 12 months leading up to the company's bankruptcy filing.

Bankruptcy law prohibits bonuses that reward executives for simply sticking with companies, but it does allow for incentives tied to hard-to-reach milestones.

iHeart bonuses are based largely on cash generated from operations, court papers show. It includes only income from regular operations, ignoring items such as gains or losses on asset sales or on financing activities, interest or tax changes.

"With confirmation of the debtors' plan of reorganization and a path to emergence from chapter 11 in sight, maintaining a highly motivated workforce is as important as ever," iHeart's lawyers said. A hearing to consider approval if iHeartMedia's reorganization, paving the way for the company's exit from chapter 11, is slated for Dec. 11.

iHeart says it expects total 2019 bonus payouts to the top executives of $22.1 million. But if the San Antonio-based company hit its top targets the insiders' incentive plan could cost as much as $33.2 million next year.

iHeart is also asking Judge Marvin Isgur to approve an incentive plan for 815 lower-ranking employees that could pay out $60 million next year. That total adds about 100 more employees than participated in a 2018 plan, an increase the company attributed to recent acquisitions and new hires.