The case will be heard in court on Wednesday, and if approved will see Swindon be placed into administraction for a second time, which is not normally allowed.
Bob Holt plans to return out of administration after the end of the season, at the end of April.
Sir Seton Wills has offered Swindon another £1,000,000 but the club is having problems getting this money into the club in time.
Bob Holt said: "Clearly the club does not have enough funds to trade on its own.
"It needs the injection of funds from a third party. Those funds have been available for some time, but we have been unable to put them in."