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Full title: Tenth Monthly Fee Statement of Santamarina y Steta, S.C. for Compensation for Services Incurred as Mexican Counsel to the Official Committee of Unsecured Creditors for the Period from August 1, 2021 through August 31, 2021 Filed by Brett H. Miller on behalf of Santamarina y Steta, S.C.. (Miller, Brett)

Document posted on Sep 30, 2021 in the bankruptcy, 21 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses filed under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases, effective as of November 1, 2013 (the “U.S. Trustee Guidelines”), the Order Authorizing the Retention and Employment of Santamarina y Steta, S.C. as Mexican Counsel to the Official Committee of Unsecured Creditors Nunc Pro Tunc to November 10, 2020, dated December 10, 2020 [ECF No.Accordingly, S+S reserves the right to make further application to this Court for allowance of such fees and expenses incurred during the Fee Period, but not included herein.Timothy Graulich and Stephen Piraino, Email: timothy.graulich@davispolk.com, stephen.piraino@davispolk.com; (iii) the Office of the United States Trustee, U.S. Federal Office Building, 201 Varick Street, Suite 1006, New York, New York 10014, Attn.:No. 345, 2nd and 3rd floor, Col. Chapultepec Polanco, 1560, Mexico City, Mexico (Attn: Jorge Alejandro WHEREFORE, S+S respectfully requests that allowance be made for compensation in the amount of $96,927.28 for the actual, reasonable and necessary legal services rendered to the Committee during the Fee Period, less a twenty percent (20%) holdback in the amount of $19,385.45, for a total fee request of $77,541.83, and further requests such other and further relief as this Court deems necessary and just.

List of Tables

Document Contents

Objection Deadline: October 18, 2021 SANTAMARINA Y STETA, S.C. Jorge A. León Orantes B. Juan Carlos Machorro G. Campos Elíseos No. 345, 2nd and 3rd Floor Col. Chapultepec Polanco 11550 Mexico City, Mexico Telephone: (+52) 55-5279-5400 jleon@s-s.mx jmachorro@s-s.mx Mexican Counsel to the Official Committee of Unsecured Creditors 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) ) TENTH MONTHLY FEE STATEMENT OF SANTAMARINA Y STETA, S.C. FOR COMPENSATION FOR SERVICES INCURRED AS MEXICAN COUNSEL TO THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR THE PERIOD FROM AUGUST 1, 2021 THROUGH AUGUST 31, 2021
Table 1 on page 1. Back to List of Tables
Name of Applicant: Santamarina y Steta, S.C.
Authorized to Provide Professional Services to: The Official Committee of
Unsecured Creditors
Date of Retention: December 10, 2020 nunc pro tunc to
November 10, 2020 [ECF No. 714]
Period for which Compensation
and Reimbursement is Sought:
August 1, 2021 through
August 31 30, 2021
Amount of Compensation Sought as
Actual, Reasonable and Necessary:
$96,927.28 (80% = $77,541.83)
1 The Debtors in these cases, along with 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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Table 1 on page 2. Back to List of Tables
Amount of Expense Reimbursement Sought
as Actual, Reasonable and Necessary:
$0.00
Total Compensation and Expenses to be Paid
Under Interim Compensation Order:
$96,927.28
This is a(n): X monthly interim_____ final application. No prior application was filed for this Fee Period.2 2 Notice of this Monthly Fee Statement (as defined herein) shall be served in accordance with the Interim Compensation Order (as defined herein), and objections to the relief requested in this Monthly Fee Statement shall be addressed in accordance with the Interim Compensation Order.

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Pursuant to sections 327, 330, and 331 of chapter 11 of title 11 of the United States Code (the “Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), Rule 2016-1 of the Local Bankruptcy Rules for the United States Bankruptcy Court for the Southern District of New York (the “Local Rules”), the United States Trustee’s Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses filed under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases, effective as of November 1, 2013 (the “U.S. Trustee Guidelines”), the Order Authorizing the Retention and Employment of Santamarina y Steta, S.C. as Mexican Counsel to the Official Committee of Unsecured Creditors Nunc Pro Tunc to November 10, 2020, dated December 10, 2020 [ECF No. 714] (the “Retention Order”), and the Order Pursuant to 11 U.S.C. §§ 105(a) and 331 Establishing Procedures for Monthly and Interim Compensation and Reimbursement of Expenses for Retained Professionals, dated September 8, 2020 [Docket No. 360] (the “Interim Compensation Order”), the law firm of Santamarina y Steta, S.C. (“S+S” or the “Firm”), Mexican counsel to the Official Committee of Unsecured Creditors (the “Committee”), hereby submits this monthly fee statement (this “Monthly Fee Statement”) for services rendered for the period from August 1, 2021 through and including August 31, 2021 (the “Fee Period”). By this Monthly Fee Statement, S+S seeks compensation in the amount of $96,927.28 for the actual, reasonable and necessary legal services rendered to the Committee during the Fee Period, less a twenty percent (20%) holdback in the amount of $19,385.45, for a total fee request of $77,541.83.3 3 As an accommodation to the Committee, and consistent with applicable billing guidelines, S+S is not seeking payment for time spent reviewing its time entries for confidential information and compliance with billing guidelines.

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Itemization of Services Rendered and Disbursements Incurred 1. In support of this Monthly Fee Statement, attached are the following exhibits:  Exhibit A is a schedule of the number of hours expended and fees incurred (on an aggregate basis) by the Firm’s attorneys during the Fee Period with respect to each of the project categories established by S+S in accordance with its internal billing procedures.  Exhibit B is a schedule providing certain information regarding the Firm’s attorneys for whose work on these chapter 11 cases compensation is sought in this Monthly Fee Statement. The Firm’s attorneys have expended a total of 201.10 hours and incurred $96,927.28 in fees in connection with these chapter 11 cases during the Fee Period.  Exhibit C consists of the Firm’s time detail and records of fees and expenses incurred during the Fee Period. The time records are organized by project category and provide detailed daily entries describing the time spent by each attorney. Representations 2. Although every effort has been made to include all fees and expenses incurred by the Firm during the Fee Period, some fees and expenses might not be included in this Monthly Fee Statement due to delays caused in connection with accounting and processing of such time and expenses. Accordingly, S+S reserves the right to make further application to this Court for allowance of such fees and expenses incurred during the Fee Period, but not included herein. Notice and Objection Procedures 3. Pursuant to the Interim Compensation Order, notice of this Monthly Fee Statement will be served upon the following parties (collectively, the “Fee Notice Parties”): (i) Grupo Aeroméxico, S.A.B. de C.V., Paseo de la Reforma No. 243, piso 25 Colonia Cuauhtémoc, Mexico City, C.P. 06500, Attn.: Daniel Martinez Martinez and Patricia Bobadilla, Email: dmartinezm@aeromexico.com, mbobadilla@aeromexico.com; (ii) counsel to the Debtors, Davis Polk & Wardwell LLP, 450 Lexington Avenue, New York, New York 10017, Attn.: Timothy Graulich and Stephen Piraino, Email: timothy.graulich@davispolk.com,

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stephen.piraino@davispolk.com; (iii) the Office of the United States Trustee, U.S. Federal Office Building, 201 Varick Street, Suite 1006, New York, New York 10014, Attn.: Andrea Beth Schwartz, Email: andrea.b.schwartz@usdoj.gov; (iv) Counsel to the DIP Lender, Cleary Gottlieb Steen & Hamilton LLP, One Liberty Plaza, New York, NY 10006, Attn.: Richard J. Cooper, Luke A. Barefoot, Thomas S. Kessler, Email: rcooper@cgsh.com, lbarefoot@cgsh.com, tkessler@cgsh.com; and (v) anyone else the Court may designate. S+S submits that, in light of the nature of the relief requested, no other or further notice need be given. 4. Objections to the Monthly Fee Statement, if any, must be filed and served upon Santamarina y Steta, S.C., Campos Elíseos No. 345, 2nd and 3rd floor, Col. Chapultepec Polanco, 1560, Mexico City, Mexico (Attn: Jorge Alejandro León Orantes Baena; Email: jleon@s-s.mx), by no later than October 18, 2021 (the “Objection Deadline”). Objections to this Monthly Fee Statement, if any, must set forth the nature of the objection and the specific amount of fees or expenses at issue. 5. If no objection to this Monthly Fee Statement is received by the Objection Deadline, the Debtors shall promptly pay S+S 80% of the fees identified in this Monthly Fee Statement. To the extent that an objection to this Monthly Fee Statement is received by the Objection Deadline, the Debtors shall withhold payment of that portion of this Monthly Fee Statement to which the objection is directed and promptly pay the remainder of the fees and expenses in the percentages set forth above. To the extent such objection is not resolved, it shall be preserved and scheduled for consideration at the next interim fee application hearing. [Remainder of Page Left Intentionally Blank]

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WHEREFORE, S+S respectfully requests that allowance be made for compensation in the amount of $96,927.28 for the actual, reasonable and necessary legal services rendered to the Committee during the Fee Period, less a twenty percent (20%) holdback in the amount of $19,385.45, for a total fee request of $77,541.83, and further requests such other and further relief as this Court deems necessary and just. Dated: October 1, 2021 SANTAMARINA Y STETA, S.C. Mexico City, Mexico /s/ Jorge A. Leon Orantes B. Jorge A. Leon Orantes B. Juan Carlos Machorro Campos Elíseos No. 345, 2nd and 3rd Floor Col. Chapultepec Polanco 11550 Mexico City, Mexico Telephone: (+52) 55-5279-5400 jleon@s-s.mx jmachorro@s-s.mx Mexican Counsel to the Official Committee of Unsecured Creditors

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Exhibit A

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Statement of Fees By Project Category
Table 1 on page 8. Back to List of Tables
Project
Category
Number
Project Category Total
Hours
Billed
Total Fees
Requested
0001 Meetings and communications with Committee
professionals
30.10 $14,795.00
0002 Analysis and preparation of documents on Mexican
law issues
155.80 $62,255.00
0004 Employment and Fee Applications 1.00 $240.00
0006 Meetings and communications with Committee 14.20 $6,268.00
Total Incurred None 201.10 $83,558.00
Value Added Tax (16%) None None $13,369.28
Total Requested
201.10
None None $96,927.28

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Exhibit B

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Attorney and Paraprofessional Information
Table 1 on page 10. Back to List of Tables
Name Position
with the
Applicant
Year
Admitted
or No. of
Years
with Firm
Department None Hourly
Billing
Rate
Total
Hours
Billed
Total
Compensation
Partners and Of Counsel None None None None None None None
Machorro
Guerrero, Juan
Carlos
Partner 1994 Corporate $525.00 None 58.6 $30,765.00
León Orantes
Baena, Jorge
Partner 1994 Corporate $490.00 None 67.7 $33,173.00
Olvera Ferrer,
Carlos
Partner 1994 Litigation $445.00 None 3.20 $1,424.00
Chagoya Díaz,
Sergio
Partner 1998 Corporate $440.00 None 8.60 $3,784.00
Associates and Attorneys None None None None None None None
Robledo y
González Plata,
Karina
Counsel 2005 Tax $355.00 None 1.80 $639.00
Remis Cristóbal,
Andrés
Associate 2017 Aviation $240.00 None 21.9 $5,256.00
Ostos Guerresi,
Diego
Associate 2010 Corporate $230.00 None 27.6 $6,348.00
Szymanski
Curiel, Ivan
Associate 2021 Corporate $270.00 None 3.00 $810.00
Osio
Sánchez, Cynthia
Associate 2015 Litigation $160.00 None 7.60 $1,216.00
Law Clerks None None None None None None None
Carrillo
Somerville, César $180.00
Law Clerk 2020 Aviation
Adolfo
None None None None None 1.10 $143.00
Total Incurred: None None None None None 201.10 $83,558.00
Value Added Tax (16%) None None None None None None $13,369.28
Total Requested: 201.10 None None None None None None $96,927.28

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Exhibit C

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Time Detail
Table 1 on page 12. Back to List of Tables
Date Services Timekeeper Hours Value None None None None
0001 - Meetings and communications with Committee lawyers None None None None
3-Aug-2021 Conference with Mr. Marc Bilbao, from
FTI Consulting, Inc., with respect to
the issuance of shares for the
implementation of the exit procedure.
Correspondence to counsel to the
debtor on the foregoing. Attend
professionals call in anticipation and
preparation to mediation process.
Attend mediation process.
Orantes, Jorge
León
2.90 1421
3-Aug-2021 Attendance to UCC Professionals
weekly meeting and review of
information.
Machorro, Juan 1.10 577.5
5-Aug-2021 Attend conference call with Apollo as
part of the mediation procedure. Analyze
implications under Mexican law.
Correspondence to Willkie Farr &
Gallagher LLP. on the foregoing.
Orantes, Jorge
León
2.40 1176
10-Aug-2021 Attend weekly call with Morrison and
Foster to review pending matters and
steps moving forward. Attend weekly
amx professionals call. Attend UCC
Professionals standing weekly call.
Review related documentation.
Orantes, Jorge
León
2.10 1029
10-Aug-2021 Attendance to weekly call with members
of Willkie Farr and attendance to
meetings with UCC and Debtor´s
professionals and with UCC professionals
and review of information.
Machorro, Juan 2.10 1102.5
13-Aug-2021 With Mr. Juan Manuel Delgado, discuss
fiduciary duties of directors of Mexican
public company. Correspondence on the
foregoing.
Orantes, Jorge
León
0.20 98
17-Aug-2021 Attend meeting with Willkie Farr and
Morrison & Foerster LLP. ("MoFo") to
discuss pending matters and steps
moving forward. Attend recurring AMX
Professionals Call. Attend UCC
Professionals Standing Weekly Call.
Review implementation of strategy under
Mexican law. With Mr. Carlos Olvera,
review related matters.
Orantes, Jorge
León
3.20 1568
17-Aug-2021 Attendance to weekly meetings with
Willkie Farr, with UCC and Debtors
professionals, and with CC professionals,
and review of relevant information.
Machorro, Juan 2.80 1470
23-Aug-2021 Conference with Mr. Juan Manuel
Delgado to discuss the position of
Mexican counsel to the Debtor, and steps
moving forward.
Orantes, Jorge
León
0.40 196
24-Aug-2021 Attend AMX - Willkie Farr & Gallagher,
LLP. / S+S Standing Call. Attend
recurring AMX Professionals Call (Alix,
Orantes, Jorge
León
2.50 1225

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Table 1 on page 13. Back to List of Tables
FTI, Davis Polk and Rothschild). Attend
UCC Professionals Standing Weekly
Call.
24-Aug-2021 Attendance to weekly conference call
with Willkie Farr; attendance to weekly
meeting with Debtors’ and UCC
professionals, and attendance to weekly
meeting with UCC professionals, and
review of information.
Machorro, Juan 2.50 1312.5
28-Aug-2021 Attend meeting with advisors to the
AdHoc, Willkie Farr & Gallagher, LLP.
and FTI Consulting, Inc.
Orantes, Jorge
León
1.20 588
31-Aug-2021 Attend Willkie Farr & Gallagher, LLP. /
Santamarina y Steta,
S.C. Sanding Call. Further conference
with Juan Manuel Delgado. Attend AMX
Professionals Call. Attend UCC
Professionals Standing Weekly Call.
Attend meeting with Willkie Farr &
Gallagher LLP, FTI Consulting, Inc. and
AdHoc Group and advisors.
Orantes, Jorge
León
3.30 1617
31-Aug-2021 Conference call with FTI consulting and
Silverpoint in connection with
Interjet´s return to the market, air
transportation permits and slots.
Remis, Andrés 1.30 312
31-Aug-2021 Attendance to weekly meeting with UCC
and Debtors’ Professionals. Attendance
to weekly meeting with UCC
Professionls. Revie of information
prepared for the meetings. Review of
information in preparation of UCC
weekly meeting on September 1st.
Machorro, Juan 2.10 1102.5
Total: 0001 Meetings and communications with Committee lawyers None 30.10 $14,795.00
None
0002 - Analysis and preparation of documents on Mexican law issues None None None None
2-Aug-2021 Conference call with Jorge Leon Orantes
in order to discuss certain matters
regarding obligations of Aeromexico as
a public company. Review and revise
memorandum explaining the above from
a capital markets perspective
Ostos, Diego 2.10 483
2-Aug-2021 Prepare memorandum on aspects to
consider under Mexican law for the
implementation of the exit plan. Review
mediation memorandum. With Mr. Diego
Ostos, review related matters.
Orantes, Jorge
León
5.30 2597
2-Aug-2021 Review of mediation statement to be
submitted to Judge Lane. Review of draft
legal memorandum on items relevant for
the implementation of the exit process
from a Mexican legal perspective.
Review of relevant event published by
the Debtor Company in the Mexican
Stock Exchange on mediation process.
Machorro, Juan 2.30 1207.5
3-Aug-2021 Conference call with Marc Bilbao and
Jorge Leon Orantes in order to discuss the
exit plan for Aeromexico. Follow up call
Ostos, Diego 0.60 138

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with Jorge Leon Orantes.
3-Aug-2021 Review of information on mediation
process with Judge Lane. Attendance to
mediation meeting with the Judge.
Machorro, Juan 2.10 1102.5
4-Aug-2021 Coordinate preparation of presentation to
the Committee on Mexican capital
market requirements for the
implementation of the Exit Strategy.
Review relevant materials.
Orantes, Jorge
León
1.20 588
4-Aug-2021 Review of information on exit proposals
on aspects of presentation to the
committee outlining Mexican issues
regarding a public vs. private exit from
Chapter 11.
Machorro, Juan 0.80 420
5-Aug-2021 Prepare English presentation regarding
the exit options of Aeromexico.
Ostos, Diego 1.20 276
5-Aug-2021 Review status of mediation procedure.
Correspondence on the foregoing.
Orantes, Jorge
León
0.20 98
5-Aug-2021 Attendance to conference call Apollo and
professionals. Review of information.
Correspondence.
Machorro, Juan 1.30 682.5
6-Aug-2021 Prepare new version of the
presentation withe the comments
discussed with Jorge León Orantes.
Conference call with Aeromexico's
Mexican counsel in order to discuss next
steps in the transaction.
Ostos, Diego 2.50 575
6-Aug-2021 Conference with Mexican counsel to the
debtor to discuss securities aspects
related to the implementation of the
capitalization and procedures with the
National Banking and Securities
Commission and with the Foreign
Investment Commission.
Orantes, Jorge
León
0.60 294
6-Aug-2021 Review presentation to be made to the
Committee on the regulation of the
capitalization and securities markets
regulations. Prepare adjustments.
Orantes, Jorge
León
1.10 539
6-Aug-2021 Review of mediation order. Machorro, Juan 0.30 157.5
7-Aug-2021 Review of objection to the Debtors’
737 MAX motion filed with the court.
Machorro, Juan 0.30 157.5
9-Aug-2021 Continue preparing the presentation for
the Committee. Review the bids in order
to prepare such presentation. Conference
calls with Mr. Jorge León Orantes in
order to discuss the topics of the
presentation.
Ostos, Diego 3.10 713
9-Aug-2021 Review presentation to be made to the
committee with respect to the public
offering and other capital market
requirements under Mexican law for their
implementation of the exit. Prepare
changes. Review proposal made by group
of creditors represented by Gibson, Dunn
& Crutcher LLP.
Orantes, Jorge
León
4.60 2254
10-Aug-2021 Continue preparing the presentation for
the Committee. Review and revise the
final version of the presentation.
Ostos, Diego 1.10 253

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10-Aug-2021 Final adjustments to presentation to UCC.
Review April and May authorizations
issued by the National Banking and
National Commission of Foreign
Investments modifying the neutral
investments regime. Correspondence to
the working group on the foregoing.
Orantes, Jorge
León
2.90 1421
10-Aug-2021 Review of information sent by Debtors’
Mexican counsel regarding applications
submitted to the Mexican foreign
investment authorities and response by
the authorities, as well as legal
memoranda prepared by said counsel on
aspects of foreign investment regulation
for airlines in Mexico. Review of
presentation for the UCC meeting on a
private versus a public exit according to
Mexican regulation.
Machorro, Juan 2.10 1102.5
13-Aug-2021 Payment of duties regarding pending
title search requests before the Mexican
Aeronautic Registry.
Carrillo, César 1.10 143
16-Aug-2021 With Mrs. Karina Robledo, discuss tax
aspects related to sale of shares and
special treatment for public companies.
Orantes, Jorge
León
0.20 98
17-Aug-2021 Review of information on
mediation process and attendance to
mediation hearing.
Machorro, Juan 1.10 577.5
17-Aug-2021 Prepare tax note on the transfer of shares. Robledo, Karina 1.80 639
18-Aug-2021 Attention conferences calls with Jorge
León Orantes and Cynthia Osio in
connection with advice requested by
client concerning possibility of execution
in Mexico about Chapter 11 trustee.
Review doctrine and judicial criteria over
the same matter.
Olvera, Carlos 2.10 934.5
18-Aug-2021 Review and analyze statutory provisions
and judicial criteria applicable to: a)
international cooperation in insolvency
proceedings and potential scenarios
surrounding the appointment of a
Chapter 11 trustee and its enforcement in
Mexico, and b) a potential claim against
directors for lack of diligence and loyalty.
Drafting of memo for the client and
attention internal conference call with
Mr. Carlos Olvera in this regard.
Osio, Cynthia 4.50 720
18-Aug-2021 With Mr. Carlos Olvera, analyze
implementation of exit strategy under
Mexican law.
Orantes, Jorge
León
0.50 245
18-Aug-2021 Review analysis on tax treatment
applicable to the transfer of shares.
Prepare adjustments. With Mrs. Karina
Robledo, review related matters.
Orantes, Jorge
León
0.90 441
18-Aug-2021 Review of information on aspects of
mediation process
Machorro, Juan 0.50 262.5
19-Aug-2021 Attention virtual meetings with Cynthia
Osio, Jorge León Orantes, Diego Ostos,
Andrés Remis and Juan Carlos Machorro
Olvera, Carlos 1.10 489.5

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about some queries in connection with
the advice requested by the client.
Preparation final note about this matter
with Cynthia Osio. Follow upo of the
latest judicial criteria over the same
matter.
19-Aug-2021 Attention conference calls and
exchange communications with
Messrs. Carlos Olvera, Jorge León-
Orantes, Juan Carlos Machorro,
Diego Ostos and Andrés Remis,
regarding potential scenarios
surrounding the appointment of a
Chapter 11 trustee and its
enforcement in Mexico, and
b) a potential claim against directors
for lack of diligence and loyalty.
Drafting of additions and modifications
to memo for the client.
Osio, Cynthia 3.10 496
19-Aug-2021 Review and revise the memorandum
regarding the feasibility of enforcing in
Mexico a potential appointment of a
trustee by the US Court.
Ostos, Diego 1.10 253
19-Aug-2021 Review memorandum of designation
of trustee and alternatives under
Mexican law, as well as fiduciary duties.
With Ms. Cinthia Osio and Mr. Carlos
Olvera, review related matters. Prepare
adjustments.
Orantes, Jorge
León
3.10 1519
19-Aug-2021 Review of information on aspects of
mediation process and existing
alternatives. Review of legal
memorandum on aspects of Mexican
laws regulating the securities market and
insolvency related matters.
Machorro, Juan 2.50 1312.5
20-Aug-2021 Review the Exit Financing
Termsheet of the BSPO Proposal.
Ostos, Diego 0.40 92
20-Aug-2021 Further adjustments to memorandum on
implementation of management
structures under Mexican law.
Correspondence on equity
participation rights and alternatives.
Orantes, Jorge
León
2.10 1029
20-Aug-2021 Review of information on alternatives for
merger/liquidation.
Machorro, Juan 2.10 1102.5
21-Aug-2021 Analysis of term sheet provided by
combined group. Review applicable
legal provisions. Correspondence to the
working group on the foregoing.
Orantes, Jorge
León
1.60 784
21-Aug-2021 Review of information on Joint
Bondholder/BSPO and Claimholder
proposal, information prepared by FTI
and draft letter to the restructuring
committee of the company’s board of
directors urging them to accept the
proposal.
Machorro, Juan 1.30 682.5
22-Aug-2021 Review of changes to draft letter to the
restructuring committee of the
Machorro, Juan 0.50 262.5

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Table 1 on page 17. Back to List of Tables
company’s board of directors urging
them to accept the proposal.
Correspondence.
24-Aug-2021 Review of contractual aspects in light of
the debtor’s decision towards the election
of the final financing under Chapter 11.
Preparation of a legal memorandum in
that regard.
Remis, Andrés 4.30 1032
24-Aug-2021 Prepare legal analysis regarding
applications of Mexican Securities
Market Law.
Ostos, Diego 4.10 943
24-Aug-2021 Analysis of contractual and regulatory
issues related to approval of plan by
Shareholders. With Messrs. Diego Ostos
and Andrés Remis, review related
matters.
Orantes, Jorge
León
0.70 343
24-Aug-2021 Continued review of information on
Joint Proposal; review of information on
Mexican securities laws and foreign
investment regulation in light of
current status of negotiations and
behavior of participants. Preparation of
legal note for the UCC Professionals.
Machorro, Juan 4.10 2152.5
25-Aug-2021 Conference calls with Messrs. Leon
Orantes and Machorro in order to discuss
the findings and interpretation of certain
precepts of the Mexican Law.
Ostos, Diego 1.10 253
25-Aug-2021 Analyze alternatives under Mexican
law,considering pondering of different
exit options by the debtor. Review
applicable legal provisions.
Orantes, Jorge
León
1.10 539
25-Aug-2021 Review of information on status of
mediation process and related
information; review on status of review
of proposals; review of correspondence
and information on aspects of DIP
financing documentation, and
correspondence.
Machorro, Juan 1.30 682.5
26-Aug-2021 Review of certain exit-financing related
contracts and preparation of a legal
memorandum in that regard.
Remis, Andrés 3.50 840
26-Aug-2021 Review status of approval by the Board
of the Debtor. Review adjustments to
Commitment proposals. Analyze
alternatives for delivering shares in
payment of services. Attend conferences
with Willkie Farr & Gallagher LLP. and
FTI Consulting Inc. Analysis of
Commitments under resolutions of
Mexican Federal Competition
Commission. Review regulatory
considerations. Attend meeting with Mr.
Ross Faldetta, from FTI Consulting Inc.
to discuss interjet procedure.
Orantes, Jorge
León
4.40 2156
26-Aug-2021 Continued review of information on debt
commitment letters, mediation process,
Mexican aspects of competition law and
aviation regulatory matters and
Machorro, Juan 2.30 1207.5

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preparation of legal note, and status of
insolvency proceedings of Interjet.
Correspondence with working group.
26-Aug-2021 (i) Review resolutions issued by the
Federal Economic Competition
Commission on the GAM/DELTA cases;
(ii) internal meeting; (iii) Prepare
communication to the client.
Szymanski, Iván 2.50 675
27-Aug-2021 Review of aspects in connection with the
air transportation services of Interjet and
the slots assigned to the airline during the
2020 winter season.
Remis, Andrés 4.10 984
27-Aug-2021 Review of information prepared on on
Delta/Aeromexico synergies; review of
information on debt commitment letters
and mediation process; review of
information on status of insolvency
proceedings of Interjet. Conferences,
virtual meetings and correspondence with
working group.
Machorro, Juan 3.10 1627.5
27-Aug-2021 Notes on competition law issues
regarding the merger review procedure in
Mexico.
Szymanski, Iván 0.50 135
28-Aug-2021 Prepare communication to FTI
Consulting, Inc. with respectto to
antitrust approvals. Review antecedents.
Prepare adjustments. With Messrs. Juan
Carlos Machorro and Iván Szymanski,
review related matters.
Orantes, Jorge
León
1.60 784
28-Aug-2021 Continued review of aspects in
connection with the air transportation
services of Interjet and the slots assigned
to the airline during the 2020 winter
season.
Remis, Andrés 2.10 504
29-Aug-2021 Review of information on aspects of
mediation process and information shared
by Willkie Farr; review of information on
Debtors and correspondence.
Machorro, Juan 2.10 1102.5
29-Aug-2021 Review of Delta related analysis and
underlying documents, and review of new
information on the matter prepared by
FTI. Attendance to conference call with
working group on said information.
Correspondence with working group on
aspects of Mexican competition
regulation.
Machorro, Juan 2.50 1312.5
30-Aug-2021 Review and revise possible Mexican law
violations incurred by the shareholders of
Aeromexico. Conference calls with
Messrs. Jorge Leon Orantes, Juan Carlos
Machorro and Sergio Chagoya
regarding the above. Prepare
communications with the Mexican Law
legal analysis . Conference call with
Willkie regarding the above matters.
Ostos, Diego 5.50 1265
30-Aug-2021 Analysis of possible liabilities under
Mexican law with respect to group of
Shareholders. Review applicable legal
Orantes, Jorge
León
4.70 2303

18

Table 1 on page 19. Back to List of Tables
provisions. Prepare correspondence.
Attend conference with Willkie Farr &
Gallagher, LLP. Further conference with
Mr. Juan Manuel Delgado. Review order
requesting termination of exclusivity.
Prepare comments.
30-Aug-2021 Analysis of possible liabilities under
Mexican law with respect to group of
shareholders. Review applicable legal
provisions. Prepare correspondence.
Orantes, Jorge
León
4.30 2107
30-Aug-2021 Continued review of Interjet´s air
transportation services and slots.
Preparation of legal memorandum in that
regard.
Remis, Andrés 3.30 792
30-Aug-2021 Review of information on
Delta/Aeromexico analysis. Review of
draft motion to terminate exclusivity.
Attendance to working session
(conference call) with Willkie Farr.
Correspondence with working group.
Review of applicable legal provision on
the Mexican securities and commercial
laws and preparation of legal notes.
Preparation of legal memorandum on
Mexican legal aspects on status of
Interjet’s insolvency, operating
concession and slots at the Mexico City
Airport.
Machorro, Juan 4.50 2362.5
30-Aug-2021 Legal analysis of the Mexican applicable
legal framework to a possible
submission to the Mexican Banking
and Securities Commission.
Chagoya, Sergio 4.50 1980
31-Aug-2021 Review the motion prepared by Willkie
in order to analize the possible infractions
by the Shareholders of Aeromexico to the
Mexican Securities Law. Conference call
with Sergio Chagoya in order to
analize the possibility to file a
document before the CNBV.
Ostos, Diego 1.50 345
31-Aug-2021 Status negotiations. Memo on Interjet.
Correspondence on Foreign Investment
restrictions and issuance of series "N"
shares. Further consideration of possible
further actions that could be implemented
in Mexico.
Orantes, Jorge
León
2.30 1127
31-Aug-2021 Review of Mexican federal aviation
regulations regarding the issuing of slots
at Mexico City International Airport.
Preparation of legal memorandum in that
regard.
Remis, Andrés 2.30 552
31-Aug-2021 Continued review of information on
Delta/Aeromexico analysis and
attendance to conference call with
working group. Continued review of draft
motion to terminate exclusivity and
incorporation of comments and
suggestions as regards aspects of
applicable Mexican law and
Machorro, Juan 6.10 3202.5

19

Table 1 on page 20. Back to List of Tables
regulation. Correspondence with working
group. Continue review of applicable
legal provision on the Mexican
securities and commercial laws and
preparation of legal notes. Review of
aspects of Mexican aviation regulation
and rules for the assignment and
operation of slots at the Mexico City
International Airport, attendance to
conference call with working group
and preparation of legal memorandum
on the grounds of said assignment and
operation of slots at the Mexico City
International Airport. Correspondence
with working group. Review of
communication by Davis Polk on update
of process relating delivery of Final
Valuation Materials.
31-Aug-2021 Review of the draft of the Motion for the
termination of the exclusivities of the
Creditors in connection with our
securities regulation analysis. Prepare
internal document with our conclusions
on that regard.
Chagoya, Sergio 4.10 1804
Total: 0002 Analysis and preparation of documents on Mexican law
issues
None 155.8 $62,255.00
None
0004 – Employment and Fee Applications None None None None
Preparation of July monthly fee
11-Aug-2021 Remis, Andrés 1.00 240
statement.
None None None None
Employment and Fee Applications
Total: 0004 1.00 $240
None None None None
0006 - Meetings and communications with Committee None None None None
4-Aug-2021 Attend weekly call with the committee.
Review relevant materials.
Orantes, Jorge
León
1.10 539
4-Aug-2021 Attendance to UCC weekly
meeting and review of information.
Machorro, Juan 1.10 577.5
11-Aug-2021 Attendance to the Unsecured Creditors
Committee.
Ostos, Diego 1.10 253
11-Aug-2021 Attend weekly call with the committee.
Review relevant materials in a dissipation
to presentation on Mexican law issues.
Further conference with Mr. Juan Manuel
Delgado on the foregoing. Consider
alternatives.
Orantes, Jorge
León
1.90 931
11-Aug-2021 Attendance to weekly UCC
meeting and review of information.
Machorro, Juan 1.30 682.5
18-Aug-2021 Attendance to Unsecured Creditors
Committee.
Ostos, Diego 1.10 253
18-Aug-2021 Attend meeting with the Committee.
Review materials for such meeting.
Orantes, Jorge
León
1.10 539
18-Aug-2021 Attendance to weekly UCC meeting and
review of relevant information.
Machorro, Juan 1.10 577.5
20-Aug-2021 Attend meeting with the Committee. Orantes, Jorge
León
0.70 343
25-Aug-2021 Attendance to the Unsecured Creditors
Committee.
Ostos, Diego 1.10 253
25-Aug-2021 Attend meeting with the Committee. Orantes, Jorge 1.30 637

20

Table 1 on page 21. Back to List of Tables
Review relevant materials. León
25-Aug-2021 Attendance to weekly UCC
Machorro, Juan
meeting and review of information.
1.30 682.5
Total: 0006 Meetings and communications with Committee 14.20 $6,268.00
Current Fees None None $83,558.00
Value Added Tax (16%) None None $13,369.28
Total Current Fees None None $96,927.28

21