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Full title: Motion for Omnibus Objection to Claim(s) / Seventh Omnibus Claims Objection to Proofs of Claim (Wrong Debtor Claims) filed by Timothy E. Graulich on behalf of Grupo Aeromexico, S.A.B. de C.V. with hearing to be held on 7/8/2021 at 11:00 AM at Courtroom 623 (SCC) Responses due by 7/6/2021,. (Attachments: # (1) Exhibit A - Objection # (2) Exhibit B - Omnibus Claims Hearing Procedures) (Graulich, Timothy)

Document posted on Jun 2, 2021 in the bankruptcy, 5 pages and 0 tables.

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(“Grupo Aeroméxico”) and its affiliates that are debtors and debtors in possession in the above-captioned chapter 11 cases (collectively, the “Debtors”) filed their Seventh Omnibus Claims Objection to Proofs of Claim (Wrong Debtor Claims)The Objection requests that the Bankruptcy 1 The Debtors in these cases, along with the last four digits of each Debtor’s registration number in the applicable jurisdiction, are as follows: Grupo Aeroméxico, S.A.B. de C.V. 286676; Aerovías de México, S.A. de C.V. 108984; Aerolitoral, S.A. de C.V. 217315; and Aerovías Empresa de Cargo, S.A. de C.V. 437094-1. other evidence of the Claim, to the extent not included with the Proof of Claim previously filed with the Bankruptcy Court, upon which you will rely in opposing the Objection; (v) the address(es) to which the Debtors must return any reply to your Response, if different from that presented in the Proof of Claim; and (vi) the name, address, and telephone number of the person (which may be you or your legal representative) possessing ultimate authority to reconcile, settle, or otherwise resolve the Claim on your behalf., Case No. 20-11563 (SCC), in accordance with the Bankruptcy Court’s General Order M-399 (available on the Bankruptcy Court’s website at http://www.nysb.uscourts.gov), by registered users of the Bankruptcy Court’s electronic case filing system, (b) sent to the chambers of the Honorable Judge Shelley C. Chapman, United States Bankruptcy Court, One Bowling Green, New York, New York 10004; and (c) served (via email or otherwise) so as to be actually received on or before the Response Deadline upon (i)Davis Polk & Wardwell LLP, 450 Lexington Avenue, New York, New York 10017 (Attn: Timothy Graulich (timothy.graulich@davispolk.com), Stephen D. Piraino (stephen.piraino@davispolk.com), Erik P. Jerrard (erik.jerrard@davispolk.com), and Jarret Erickson (jarret.erickson@davispolk.com)), counsel to the Debtors; and (iii) Willkie Farr & Gallagher LLP, 787 Seventh Avenue, New York, New York 10019 (Attn: Brett H. Miller (bmiller@willkie.com), Todd M. Goren (tgoren@willkie.com), Craig Damast (cdamast@willkie.com), and Debra M. Sinclair (dsinclair@willkie.com)), proposed counsel to the Official Committee of Unsecured Creditors appointed in these cases.

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THIS OBJECTION SEEKS TO RECLASSIFY CERTAIN FILED PROOFS OF CLAIM. PARTIES RECEIVING THIS NOTICE OF THE DEBTORS’ SEVENTH OMNIBUS CLAIMS OBJECTION TO PROOFS OF CLAIM SHOULD REVIEW THE OMNIBUS OBJECTION TO SEE IF THEIR NAME(S) AND/OR CLAIM(S) ARE LOCATED IN THE OMNIBUS OBJECTION AND/OR THE EXHIBIT(S) AND SCHEDULE(S) ATTACHED THERETO TO DETERMINE WHETHER THIS OBJECTION AFFECTS THEIR CLAIM(S). IF YOU HAVE QUESTIONS, PLEASE CONTACT GRUPO AEROMÉXICO’S COUNSEL, DAVIS POLK & WARDWELL LLP, AT aeromexicoclaims@dpw.com, JARRET ERICKSON (jarret.erickson@davispolk.com or +1-212-450-3632), OR ERIK P. JERRARD (+1-212-450-4769). UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: Chapter 11 GRUPO AEROMÉXICO, S.A.B. de C.V., et al., Case No. 20-11563 (SCC) Debtors.1 (Jointly Administered) NOTICE OF HEARING ON DEBTORS’ SEVENTH OMNIBUS CLAIMS OBJECTION TO PROOFS OF CLAIM (WRONG DEBTOR CLAIMS) PLEASE TAKE NOTICE that, on June 3, 2021, Grupo Aeroméxico, S.A.B. de C.V. (“Grupo Aeroméxico”) and its affiliates that are debtors and debtors in possession in the above-captioned chapter 11 cases (collectively, the “Debtors”) filed their Seventh Omnibus Claims Objection to Proofs of Claim (Wrong Debtor Claims) (the “Objection”) with the United States Bankruptcy Court for the Southern District of New York (the “Bankruptcy Court”). The Objection is annexed hereto as Exhibit A. The Objection requests that the Bankruptcy 1 The Debtors in these cases, along with the last four digits of each Debtor’s registration number in the applicable jurisdiction, are as follows: Grupo Aeroméxico, S.A.B. de C.V. 286676; Aerovías de México, S.A. de C.V. 108984; Aerolitoral, S.A. de C.V. 217315; and Aerovías Empresa de Cargo, S.A. de C.V. 437094-1. The Debtors’ corporate headquarters is located at Paseo de la Reforma No. 243, piso 25 Colonia Cuauhtémoc, Mexico City, C.P. 06500.

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Court reclassify one or more of your Claims2 listed on Schedule 1 to Exhibit 1 of the Objection annexed hereto on the grounds that such Claims have been filed against the wrong Debtor. PLEASE TAKE FURTHER NOTICE that the Court-Ordered Omnibus Claims Hearing Procedures [ECF No. 904] (the “Omnibus Claims Hearing Procedures”), annexed hereto as Exhibit B, apply and govern the Objection to your Proof(s) of Claim. The Omnibus Claims Hearing Procedures provide for certain mandatory actions by a claimant within certain time periods. Therefore, please review the Omnibus Claims Hearing Procedures carefully. Failure to comply with the Omnibus Claims Hearing Procedures may result in the disallowance and expungement of a Proof of Claim without further notice to a claimant. If you do NOT oppose the reclassification of your Claim(s) listed on Schedule 1 to Exhibit 1 of the Objection, then you do NOT need to file a written response to the Objection and you do NOT need to appear at the hearing. If you DO oppose the reclassification of your Claim(s) listed on Schedule 1 to Exhibit 1 of the Objection, then you MUST file with the Bankruptcy Court and serve on the parties listed below a written response to the Objection (a “Response”) so that it is received on or before July 6, 2021, at 4:00 p.m. (prevailing Eastern Time) (the “Response Deadline”). Your Response, if any, must contain at a minimum the following: (i) a caption setting forth the name of the Bankruptcy Court, the names of the Debtors, the case number, and title of the Objection to which the response is directed; (ii) the name of the claimant and description of the basis for the amount of the Claim; (iii) a concise statement setting forth the reasons why the Claim should not be reclassified for the reasons set forth in the Objection, including, but not limited to, the specific factual and legal bases upon which you will rely in opposing the Objection; (iv) all documentation or 2 Each capitalized term used herein but not otherwise defined herein shall have the meaning ascribed to it in the Objection.

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other evidence of the Claim, to the extent not included with the Proof of Claim previously filed with the Bankruptcy Court, upon which you will rely in opposing the Objection; (v) the address(es) to which the Debtors must return any reply to your Response, if different from that presented in the Proof of Claim; and (vi) the name, address, and telephone number of the person (which may be you or your legal representative) possessing ultimate authority to reconcile, settle, or otherwise resolve the Claim on your behalf. The Bankruptcy Court will consider a Response only if the Response is timely filed, served, and received. A Response will be deemed timely filed, served, and received only if prior to the Response Deadline, the Response is (a) filed electronically with the Bankruptcy Court on the docket of In re Grupo Aeroméxico, S.A.B. de C.V., et al., Case No. 20-11563 (SCC), in accordance with the Bankruptcy Court’s General Order M-399 (available on the Bankruptcy Court’s website at http://www.nysb.uscourts.gov), by registered users of the Bankruptcy Court’s electronic case filing system, (b) sent to the chambers of the Honorable Judge Shelley C. Chapman, United States Bankruptcy Court, One Bowling Green, New York, New York 10004; and (c) served (via email or otherwise) so as to be actually received on or before the Response Deadline upon (i) Davis Polk & Wardwell LLP, 450 Lexington Avenue, New York, New York 10017 (Attn: Timothy Graulich (timothy.graulich@davispolk.com), Stephen D. Piraino (stephen.piraino@davispolk.com), Erik P. Jerrard (erik.jerrard@davispolk.com), and Jarret Erickson (jarret.erickson@davispolk.com)), counsel to the Debtors; and (iii) Willkie Farr & Gallagher LLP, 787 Seventh Avenue, New York, New York 10019 (Attn: Brett H. Miller (bmiller@willkie.com), Todd M. Goren (tgoren@willkie.com), Craig Damast (cdamast@willkie.com), and Debra M. Sinclair (dsinclair@willkie.com)), proposed counsel to the Official Committee of Unsecured Creditors appointed in these cases. Except as otherwise permitted under the Omnibus Claims Hearing Procedures, a hearing (the

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“Hearing”) will be held on July 8, 2021, at 11:00 a.m. (prevailing Eastern Time), to consider the Objection. The Hearing will be held in the United States Bankruptcy Court for the Southern District of New York. If you file a written Response to the Objection, you should plan to appear at the Hearing. The Debtors, however, reserve the right to continue the Hearing on the Objection with respect to your claim(s). If the Debtors do continue the Hearing with respect to your Claim(s), then the Hearing will be held at a later date. If the Debtors do not continue the Hearing with respect to your Claim(s), then the Hearing on the Objection will be conducted on the above date. The Debtors have the right to further object to your Claim(s) listed on Schedule 1 to Exhibit 1 of the Proposed Order (or to any other Claims you may have filed) at a later date on grounds not asserted in the Objection. You will receive a separate notice of any such objections. Responding parties shall attend the Hearing telephonically so long as General Order M-543 is in effect or unless otherwise ordered by the Bankruptcy Court. You may participate in the Hearing telephonically by making arrangements through CourtSolutions, LLC (www.court-solutions.com). Instructions to register for CourtSolutions, LLC are attached to General Order M-543.3 If you wish to view the complete Objection, you can do so for free at https://dm.epiq11.com/aeromexico. CLAIMANTS SHOULD NOT CONTACT THE CLERK OF THE BANKRUPTCY COURT TO DISCUSS THE MERITS OF THEIR CLAIMS. [Remainder of Page Intentionally Left Blank] 3 A copy of General Order M-543 can be obtained by visiting http://www.nysb.uscourts.gov/news/court-operations-under-exigent-circumstances-created-covid-19.

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Dated: June 3, 2021 New York, New York DAVIS POLK & WARDWELL LLP By: /s/ Timothy Graulich 450 Lexington Avenue New York, New York 10017 Telephone: (212) 450-4000 Facsimile: (212) 701-5800 Marshall S. Huebner Timothy Graulich James I. McClammy Stephen D. Piraino (admitted pro hac vice) Counsel to the Debtors and Debtors in Possession

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