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Full title: Motion for Omnibus Objection to Claim(s) / Debtors' Twentieth Omnibus Claims Objection to Proofs of Claim (Amended and Duplicate Claims) filed by Timothy E. Graulich on behalf of Grupo Aeromexico, S.A.B. de C.V. with hearing to be held on 11/16/2021 at 11:00 AM at Courtroom 623 (SCC) Responses due by 11/4/2021,. (Graulich, Timothy)

Document posted on Oct 3, 2021 in the bankruptcy, 43 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 Twentieth Omnibus Claims Objection to Proofs of Claim (Amended and Duplicate Claims)By this Objection, the Debtors object to the Claims listed on Schedule 1 to the Proposed Order (“Schedule 1”) and request that such Claims be disallowed and expunged in their entirety, as such Claims (i) have been amended or superseded by other Claims filed by or on behalf of the same claimants relating to the same purported liabilities or (ii) are duplicative of other Claims filed by or on behalf of the same claimant relating to the same purported liability (collectively, the “Amended and Duplicate Claims”). Upon the objection (the “Objection”)2 of the above-captioned Debtors, pursuant to sections 105 and 502 of the Bankruptcy Code and Bankruptcy Rule 3007, seeking to disallow and expunge the Claims identified on Schedule 1 attached hereto; and upon the Sánchez Declaration, attached to the Objection as Exhibit 2; and the Court having jurisdiction to consider the matters raised in the Objection pursuant to 28 U.S.C. § 1334 and the Amended Standing Order of Reference M-431, dated January 31, 2012 (Preska, C.J.); and the Court having authority to hear the matters raised in the Objection pursuant to 28 U.S.C. § 157; and venue being proper before this Court pursuant to 28 U.S.C. § § 1408 and 1409; and consideration of the Objection and the relief requested therein being a core proceeding that the Court can determine pursuant to 28 U.S.C. § 157(b)(2); and due and proper notice of the Objection and opportunity for a hearing on the Objection having been given to the parties listed therein, and it appearing that no other or further notice need be provided; and the Court having reviewed and considered the Objection; and the Court having the opportunity to hold a 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. All Claims identified on Schedule 1 annexed hereto as a “Surviving Claim” will be unaffected by the relief granted herein, and the claimants’ rights to assert the liabilities in connection with the Surviving Claims against the applicable Debtor’s estate will be preserved, subject to the Debtors’ reservations of their rights to object to such Surviving Claims on all grounds, whether legal, factual, procedural, substantive, or non-substantive.For a non-evidentiary hearing to address whether the Contested Claim has failed to state a claim against the Debtors that can be allowed and should be dismissed pursuant to Bankruptcy Rule 7012 (a “Sufficiency Hearing”), unless the Debtors serve the claimant with

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THIS OBJECTION SEEKS TO DISALLOW AND EXPUNGE CERTAIN FILED PROOFS OF CLAIM. PARTIES RECEIVING THIS NOTICE OF THE DEBTORS’ TWENTIETH 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 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, RICHARD J. STEINBERG (richard.steinberg@davispolk.com or +1-646-460-1954), OR MOSHE MELCER (moshe.melcer@davispolk.com or +1-732-606-3155). 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’ TWENTIETH OMNIBUS CLAIMS OBJECTION TO PROOFS OF CLAIM (AMENDED AND DUPLICATE CLAIMS) PLEASE TAKE NOTICE that, on October 4, 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 Twentieth Omnibus Claims Objection to Proofs of Claim (Amended and Duplicate 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 disallow and expunge one or more of your Claims2 listed on Schedule 1 to Exhibit 1 of the Objection on the grounds that such Claims have been amended or superseded by other Claims, or are duplicative of other Claims filed by or on behalf of the same claimants relating to the same purported liabilities. By this Objection, the Debtors seek disallowance and expungement of each of the Claims listed on Schedule 1 to Exhibit 1 of the Objection in order to limit each claimant to a single Claim and recovery against the applicable Debtor’s estate arising from the same alleged liability. Any Claim that the Bankruptcy Court expunges and disallows will be treated as if it had not been filed and you will not be entitled to any distribution on account thereof. 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 disallowance and expungement 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 (as defined below). If you DO oppose the disallowance and expungement 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 November 4, 2021 at 4:00 p.m. (prevailing Eastern Time) (the “Response Deadline”). 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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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 disallowed and expunged 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 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 (“ECF”) 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),

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Erik P. Jerrard (erik.jerrard@davispolk.com), and Richard J. Steinberg (richard.steinberg@davispolk.com)), counsel to the Debtors and (ii) 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)), 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 “Hearing”) will be held on November 16, 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 object to your Claim(s) listed on Schedule 1 to Exhibit 1 of the Objection (or to any other Claims you may have filed) at a later date on grounds not asserted in the Objection unless the Bankruptcy Court disallows and expunges your Claim(s). You will receive a separate notice of any such objection. 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

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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. Dated: October 4, 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 Erik Jerrard (admitted pro hac vice) Counsel to the Debtors and Debtors in Possession 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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Exhibit A Objection

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DAVIS POLK & WARDWELL LLP 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 Erik Jerrard (admitted pro hac vice) Counsel to the Debtors and Debtors in Possession 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) DEBTORS’ TWENTIETH OMNIBUS CLAIMS OBJECTION TO PROOFS OF CLAIM (AMENDED AND DUPLICATE CLAIMS) * * * TO THE CLAIMANTS LISTED ON SCHEDULE 1 TO THE PROPOSED ORDER (ATTACHED HERETO AS EXHIBIT 1): YOUR RIGHTS MAY BE AFFECTED BY THIS OBJECTION (AS DEFINED HEREIN) AND BY ANY FURTHER OBJECTION(S) THAT MAY BE FILED BY THE DEBTORS. THE RELIEF SOUGHT HEREIN IS WITHOUT PREJUDICE TO THE DEBTORS’ RIGHTS TO PURSUE FURTHER SUBSTANTIVE OR NON-SUBSTANTIVE OBJECTIONS AGAINST THE CLAIMS LISTED ON SCHEDULE 1 TO THE PROPOSED ORDER. CLAIMANTS RECEIVING THIS OBJECTION SHOULD LOCATE THEIR NAMES AND CLAIMS ON SCHEDULE 1 TO THE PROPOSED ORDER. * * * Grupo Aeroméxico S.A.B. de C.V. (“Grupo Aeroméxico”) and its affiliates that are debtors and debtors in possession in these proceedings (collectively, the “Debtors”) hereby file this 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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Twentieth Omnibus Claims Objection to Proofs of Claim (Amended and Duplicate Claims) (the “Objection”), pursuant to the Order Approving (I) Omnibus Claims Objection Procedures, (II) Omnibus Claims Settlement Procedures and (III) Omnibus Claims Hearing Procedures [ECF No. 904] (the “Claims Objections Procedures Order”). This Objection is supported by the Declaration of Ricardo Javier Sánchez Baker in Support of the Twentieth Omnibus Claims Objection to Proofs of Claim (Amended and Duplicate Claims) (the “Sánchez Declaration”), attached hereto as Exhibit 2 and incorporated herein by reference. In further support of the Objection, the Debtors respectfully state as follows: Relief Requested 1. By this Objection, and pursuant to sections 105 and 502 of title 11 of the United States Code (the “Bankruptcy Code”), rule 3007 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and the Claims Objections Procedures Order, the Debtors seek entry of an order, substantially in the form attached hereto as Exhibit 1 (the “Proposed Order” and, if entered, the “Order”), disallowing and expunging each of the claims identified on Schedule 1 to the Proposed Order, as set forth therein.2 Jurisdiction and Venue 2. The United States Bankruptcy Court for the Southern District of New York (the “Court”) has jurisdiction to consider this matter pursuant to 28 U.S.C. §§ 157 and 1334, and the Amended Standing Order of Reference M-431, dated January 31, 2012 (Preska, C.J.). This is a core proceeding pursuant to 28 U.S.C. § 157(b)(2) and, pursuant to Bankruptcy Rule 7008, the Debtors consent to entry of a final order by the Court in connection with this Objection to the extent that it is 2 Schedule 1 to the Proposed Order is incorporated herein by reference. 2

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later determined that the Court, absent consent of the parties, cannot enter a final order or judgment consistent with Article III of the United States Constitution. 3. The legal predicates for the relief requested herein are sections 105 and 502 of the Bankruptcy Code, and Bankruptcy Rule 3007. 4. Venue is proper before the Court pursuant to 28 U.S.C. §§ 1408 and 1409. Background A. General Background 5. On June 30, 2020 (the “Petition Date”), the Debtors each commenced in this Court a voluntary case (the “Chapter 11 Cases”) under chapter 11 of title 11 of the United States Code. The Debtors are authorized to continue to operate their businesses and manage their properties as debtors in possession pursuant to Bankruptcy Code §§ 1107(a) and 1108. 6. The Debtors’ Chapter 11 Cases are being jointly administered for procedural purposes only pursuant to Bankruptcy Rule 1015(b). 7. On July 13, 2020, the United States Trustee formed an Official Committee of Unsecured Creditors (the “Creditors’ Committee”) in the Chapter 11 Cases. No trustee or examiner has been appointed in the Chapter 11 Cases. 8. The Court entered a (i) Final Order Authorizing (I) Debtors to Honor Prepetition Obligations to Customers and Related Third Parties and to Otherwise Continue Customer Programs, (II) Relief from Stay to Permit Setoff in Connection with the Customer Programs and (III) Financial Institutions to Honor and Process Related Checks and Transfers [ECF No. 205] (the “Customer Programs Order”); (ii) Final Order Authorizing (I) Debtors to Pay Certain Prepetition Taxes, Governmental Assessments and Fees and (II) Financial Institutions to Honor and Process Related Checks and Transfers on July 29, 2020 [ECF No. 206] (the “Taxes Order”); (iii) Final 3

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Order Authorizing (I) Debtors to (A) Pay Prepetition Wages, Salaries, Employee Benefits and Other Compensation and (B) Maintain Employee Benefits Programs and Pay Related Administrative Obligations, (II) Employees and Retirees to Proceed With Outstanding Workers’ Compensation Claims And (III) Financial Institutions to Honor and Process Related Checks and Transfers on July 30, 2020 [ECF No. 216] (the “Wages Order”); and (iv) Final Order Authorizing (I) Payment of Certain Prepetition Claims of Critical Vendors and Foreign Vendors and (II) Financial Institutions to Honor and Process Related Checks and Transfers on August 20, 2020 [ECF No. 309] (the “Critical Vendors Order” and together with the Customer Programs Order, Taxes Order, and Wages Order, the “First Day Orders”). 9. Detailed information regarding the Debtors’ business, capital structure, and the circumstances leading to the commencement of these Chapter 11 Cases, is set forth in the Declaration of Ricardo Javier Sánchez Baker in Support of the Debtors’ Chapter 11 Petitions and First Day Pleadings [ECF No. 20], filed with the Court on the Petition Date. B. Claims Resolution Process in the Chapter 11 Cases 10. On July 2, 2020, the Court entered an Order Authorizing Debtors to Retain and Employ Epiq Corporate Restructuring, LLC as Claims and Noticing Agent Nunc Pro Tunc to the Petition Date [ECF No. 47], thereby appointing Epiq Corporate Restructuring, LLC (“Epiq”) as the Debtors’ claims and noticing agent in these Chapter 11 Cases. 11. On August 25, 2020, the Debtors filed their respective schedules of assets and liabilities [ECF Nos. 326, 328, 330, 332] and statements of financial affairs [ECF Nos. 327, 329, 331, 333] (collectively, the “Chapter 11 Schedules” and “Statements,” respectively). On August 28, 2020, the Debtors filed an amendment to the Statement filed by Debtor Aerovías de México, S.A. de C.V. [ECF No. 342]. The Debtors filed amendments to certain of the Debtors’ Chapter 11 4

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Schedules on December 17, 2020 [ECF Nos. 737–40] as well as on January 15, 2021 [ECF Nos. 808–10]. 12. On November 18, 2020, the Court entered an Order (I) Establishing Deadline for Filing Proofs of Claim and Procedures Relating Thereto and (II) Approving the Form and Manner of Notice Thereof [ECF No. 648] (the “Bar Date Order”) establishing January 15, 2021 at 5:00 p.m. (prevailing Pacific Time) as the General Bar Date (as defined in the Bar Date Order) (the “Bar Date”). 13. On December 11, 2020, Epiq duly served the Notice of Deadline Requiring Filing of Proofs of Claim on or Before January 15, 2021 [ECF No. 778] (the “Bar Date Notice”). Between December 14, 2020 and December 16, 2020, the Debtors caused the Bar Date Notice to be published in the New York Times International Edition, the New York Times, and the Wall Street Journal. See Noblesala Aff., ECF No. 759; Noblesala Aff., ECF No. 760; Bell Aff., ECF No. 761. 14. In the ordinary course of business, the Debtors maintain books and records (the “Books and Records”) that reflect, among other things, the Debtors’ liabilities and the amounts thereof owed to their creditors. 15. The Debtors’ claims register (the “Claims Register”), prepared and maintained by Epiq, reflects that approximately 6,053 proofs of claim (collectively, the “Proofs of Claim”) have been filed in the Chapter 11 Cases asserting claims against the Debtors (each a “Claim,” and collectively, the “Claims”). The Debtors and their advisors are continuing to comprehensively review and reconcile all Claims, including both the Claims listed on the Debtors’ Chapter 11 Schedules and the Claims asserted in the Proofs of Claim (including any supporting documentation) filed in the Chapter 11 Cases. The Debtors and their advisors are also comparing the Claims 5

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asserted in the Proofs of Claims with the Debtors’ Books and Records to determine the validity of the asserted Claims. 16. This reconciliation process includes identifying particular categories of Claims that the Debtors believe should be modified, reduced, reclassified, disallowed, and/or expunged. To avoid a possible double recovery or otherwise improper recovery by claimants, the Debtors will continue to file omnibus objections to such categories of Claims if and where warranted. This Objection is one such omnibus objection. 17. On February 17, 2021, the Court entered the Claims Objections Procedures Order [ECF No. 904]. Subsequently, the Court has sustained 18 omnibus claims objections filed by the Debtors in accordance the Claims Objections Procedures Order. See ECF Nos. 1086–87, 1102, 1207–08, 1403–04, 1575, 1577–78, 1580–85, 1755, 1771. 18. The Debtors submit that this Objection, and the notice provided to claimants in connection hereto, are consistent with the Claims Objections Procedures Order, the Bankruptcy Code, and the Bankruptcy Rules. Basis for Relief 19. Pursuant to section 101 of the Bankruptcy Code, a creditor holds a claim against a bankruptcy estate only to the extent that (a) it has a “right to payment” for the asserted liabilities and (b) the claim is otherwise allowable. 11 U.S.C. §§ 101(5) and 101(10). 20. When asserting a claim against a bankrupt estate, a claimant must allege facts that, if true, would support a finding that the debtor is legally liable to the claimant. See In re Lehman Bros. Holdings, Inc., 602 B.R. 564, 574 (Bankr. S.D.N.Y. 2019); In re Int’l Match Corp., 69 F.2d 73, 76 (2d Cir. 1934) (finding that a proof of claim should at least allege facts from which legal liability can be seen to exist). Where the claimant alleges sufficient facts to support its claim, its claim is 6

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afforded prima facie validity. See In re Lehman Bros., 602 B.R. at 574. A party wishing to dispute such a claim must produce evidence in sufficient force to negate the claim’s prima facie validity. See In re Dreier LLP, 544 B.R. 760, 766 (Bankr. S.D.N.Y. 2016), aff’d, No. 08-15051 (SMB), 2016 WL 3920358 (S.D.N.Y. July 15, 2016), aff’d, 683 F. App’x 78 (2d Cir. 2017) (quoting Creamer v. Motors Liquidation Co. GUC Trust (In re Motors Liquidation Co.), No. 12 CIV. 6074 (RJS), 2013 WL 5549643, at *3 (S.D.N.Y. Sept. 26, 2013) (in turn quoting In re Allegheny Int’l, Inc., 954 F.2d 167, 173 (3d Cir. 1992))). In practice, the objecting party must produce evidence that would refute at least one of the allegations essential to the claim’s legal sufficiency. See In re Dreier, 544 B.R. at 766. Once the objecting party produces such evidence, the burden shifts back to the claimant to prove the validity of his or her claim by a preponderance of the evidence. See id. 21. A court should not deem a claim to be allowable if it is “unenforceable against the debtor and property of the debtor, under any agreement or applicable law.” 11. U.S.C. § 502(b)(1). A debtor may file an omnibus claims objection if all the claims being objected to fall under one of several listed categories as described in the Bankruptcy Rules and the Claims Objections Procedures Order, including claims that have been subsequently amended or are otherwise duplicative of other claims. See Fed. R. Bankr. P. 3007(d); Claims Obj. Proc. Order, ¶ 2(a), ECF No. 904. Objection 22. By this Objection, the Debtors object to the Claims listed on Schedule 1 to the Proposed Order (“Schedule 1”) and request that such Claims be disallowed and expunged in their entirety, as such Claims (i) have been amended or superseded by other Claims filed by or on behalf of the same claimants relating to the same purported liabilities or (ii) are duplicative of other Claims filed by or on behalf of the same claimant relating to the same purported liability (collectively, the “Amended and Duplicate Claims”). 7

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23. A debtor cannot be required to pay the same claim multiple times. See, e.g., Phelan v. Local 305 of United Ass’n of Journeymen & Apprentices of Plumbing and Pipefitting Indus. of U.S. & Can., 973 F.2d 1050, 1063 (2d Cir. 1992); see also In re Finley, Kumble, Wagner, Heine, Underberg, Manley, Myerson & Carey, 160 B.R. 882, 894 (Bankr. S.D.N.Y. 1993) (“In bankruptcy, multiple recoveries for an identical injury are generally disallowed.”). This Court has routinely sustained objections to amended, superseded, and duplicative claims. See, e.g., In re LATAM Airlines Group S.A., No. 20-11254 (JLG) (Bankr. S.D.N.Y. Aug 3, 2021) [ECF No. 2846]; In re Centric Brands, Inc., No. 20-22637 (SHL) (Bankr. S.D.N.Y. June 15, 2021) [ECF No. 926]; In re Ditech Holding Corp., No. 19-10412 (JLG) (Bankr. S.D.N.Y. Apr. 12, 2021) [ECF No. 3317]; In re Windstream Holdings, Inc., No. 19-22397 (RDD) (Bankr. S.D.N.Y. Dec. 21, 2020) [ECF No. 2758]. 24. If the Amended and Duplicate Claims identified on Schedule 1 are not disallowed, the claimants identified therein may obtain double recovery on account of the same alleged liability, at the expense of the Debtors and other creditors. By this Objection, the Debtors seek disallowance and expungement of the Amended and Duplicate Claims in order to limit each claimant to a single Claim and recovery against the applicable Debtor’s estate arising from the same alleged liability. 25. For each of the Amended and Duplicate Claims, the Debtors have identified a surviving Claim (“Surviving Claim”), which asserts the same liability and is identified on Schedule 1 in the applicable row labeled “Surviving Claim.” Surviving Claims will be unaffected by the relief requested in this Objection, and each claimant’s rights to assert these liabilities against the applicable Debtor’s estate will be preserved, subject to the Debtors’ reservations of their rights to object to such Surviving Claims and other Claims on all grounds, whether legal, factual, procedural, substantive, or non-substantive. 8

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Separate Contested Matters 26. Each of the Claims and the Objection with respect thereto constitutes a separate contested matter as contemplated by Bankruptcy Rule 9014. The Debtors request that any order entered by this Court with respect to the Debtors’ request for disallowance and expungement herein shall be deemed a separate order with respect to each Claim. Response to Omnibus Objections 27. To contest this Objection, a claimant must file and serve a written response to this Objection (a “Response”) so that it is received no later than the deadline set forth in the accompanying notice (the “Response Deadline”). All Responses shall be filed electronically with the 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 Court’s General Order M-399 (available on the Court’s website at http://www.nysb.uscourts.gov), by registered users of the Court’s electronic case filing (“ECF”) system, and served (via email or otherwise) so as to be actually received on or before the Response Deadline upon: 9

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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) Richard J. Steinberg (richard.steinberg@davispolk.com) Counsel to the Debtors -and- 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) Debra M. Sinclair (dsinclair@willkie.com) Counsel to the Creditors’ Committee. 28. Every Response to this Objection must contain, at a minimum, the following information: a. 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; b. The name of the claimant and a description of the basis for the amount of the Claim; c. A concise statement setting forth the reasons why the Claim should not be disallowed, expunged, reduced, or reclassified for the reasons set forth in the Objection, including, but not limited to, the specific factual and legal bases upon which will be relied on in opposing the Objection; d. All documentation or other evidence of the Claim, to the extent not included with the Proof of Claim previously filed with the Bankruptcy Court, upon which will be relied on in opposing the Objection; e. The address(es) to which the Debtors must return any reply to the Response, if different from that presented in the Proof of Claim; and f. The name, address, and telephone number of the person (which may be the 10

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claimant or their legal representative) possessing ultimate authority to reconcile, settle, or otherwise resolve the Claim on the claimant’s behalf. 29. If a claimant fails to file and serve a timely Response by the Response Deadline, the Debtors may present to the Court an appropriate order disallowing and expunging their Claim(s), without further notice or a hearing. Reservation of Rights 30. The Debtors expressly reserve the right to amend, modify, or supplement this Objection, including, without limitation, to modify the currency associated with each Claim set forth on Schedule 1. The Debtors further reserve their right to object to the Amended and Duplicate Claims on any other grounds that the Debtors discover or elect to pursue, unless such Claims are disallowed and expunged from the Claims Register. The Debtors reserve their right to assert substantive and/or one or more additional non-substantive objections to the Claims subject to this Objection at a later time. 31. Notwithstanding anything contained in this Objection or the exhibits or schedule attached hereto, nothing herein shall be construed as a waiver of any rights that the Debtors may have to (i) commence avoidance actions under the applicable sections of the Bankruptcy Code, including, but not limited to, sections 547 and 548 of the Bankruptcy Code, against the claimants subject to this Objection, (ii) enforce the Debtors’ rights of setoff against the claimants relating to such avoidance actions, or (iii) seek disallowance pursuant to section 502(d) of the Bankruptcy Code of Claims of the claimants that are subject to such avoidance actions. Notice 32. Notice of this Objection will be given to (i) the United States Trustee for the Southern District of New York; (ii) each party listed on Schedule 1; (iii) each party listed in paragraph 2(h) of 11

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the Claims Objections Procedures Order; and (iv) all parties requesting notice pursuant to Bankruptcy Rule 2002. The Debtors submit that, under the circumstances, no other or further notice is required. No Prior Request 33. The Debtors have not previously sought the relief requested herein from the Court or any other court. [Remainder of Page Intentionally Left Blank] 12

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WHEREFORE, the Debtors respectfully request entry of the Proposed Order, substantially in the form attached hereto as Exhibit 1, granting the relief requested herein, and such other and further relief as the Court deems just and proper. Dated: October 4, 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 Erik Jerrard (admitted pro hac vice) Counsel to the Debtors and Debtors in Possession 13

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Exhibit 1 to Objection Proposed Order

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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) ORDER GRANTING DEBTORS’ TWENTIETH OMNIBUS CLAIMS OBJECTION TO PROOFS OF CLAIM (AMENDED AND DUPLICATE CLAIMS) Upon the objection (the “Objection”)2 of the above-captioned Debtors, pursuant to sections 105 and 502 of the Bankruptcy Code and Bankruptcy Rule 3007, seeking to disallow and expunge the Claims identified on Schedule 1 attached hereto; and upon the Sánchez Declaration, attached to the Objection as Exhibit 2; and the Court having jurisdiction to consider the matters raised in the Objection pursuant to 28 U.S.C. § 1334 and the Amended Standing Order of Reference M-431, dated January 31, 2012 (Preska, C.J.); and the Court having authority to hear the matters raised in the Objection pursuant to 28 U.S.C. § 157; and venue being proper before this Court pursuant to 28 U.S.C. § § 1408 and 1409; and consideration of the Objection and the relief requested therein being a core proceeding that the Court can determine pursuant to 28 U.S.C. § 157(b)(2); and due and proper notice of the Objection and opportunity for a hearing on the Objection having been given to the parties listed therein, and it appearing that no other or further notice need be provided; and the Court having reviewed and considered the Objection; and the Court having the opportunity to hold a 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. 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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hearing on the Objection; and the Court having determined that the legal and factual bases set forth in the Objection establish just cause for the relief granted herein; and the Court having found that the relief granted herein being in the best interests of the Debtors, their creditors, and all other parties in interest; and upon all of the proceedings had before the Court; and after due deliberation and sufficient cause appearing therefor, IT IS HEREBY ORDERED THAT: 1. The Objection is hereby granted as set forth herein. 2. The Amended and Duplicate Claims identified on Schedule 1 annexed hereto are hereby disallowed and expunged in their entirety. 3. All Claims identified on Schedule 1 annexed hereto as a “Surviving Claim” will be unaffected by the relief granted herein, and the claimants’ rights to assert the liabilities in connection with the Surviving Claims against the applicable Debtor’s estate will be preserved, subject to the Debtors’ reservations of their rights to object to such Surviving Claims on all grounds, whether legal, factual, procedural, substantive, or non-substantive. 4. This Order shall be deemed a separate Order with respect to each of the Claims identified on Schedule 1. Any stay of this Order pending appeal by any claimants whose Claims are subject to this Order shall only apply to the contested matter that involves such claimant and shall not act to stay the applicability and/or finality of this Order with respect to the other contested matters listed in the Objection or this Order. 5. The Debtors, Epiq Corporate Restructuring, LLC, and the Clerk of this Court are authorized to take, or refrain from taking, any action necessary or appropriate to implement the terms of, and the relief granted in, this Order without seeking further order of the Court.

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6. Notwithstanding any Bankruptcy Rule, the Local Bankruptcy Rules for the Southern District of New York, or otherwise, the terms and conditions of this Order shall be immediately effective and enforceable upon its entry. 7. This Court shall retain jurisdiction to hear and determine all matters arising from, arising under, or related to the Chapter 11 Cases, to the fullest extent permitted by law, including, without limitation, to enforce this Order. Dated: New York, New York _____________, 2021 THE HONORABLE SHELLEY C. CHAPMAN UNITED STATES BANKRUPTCY JUDGE

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Schedule 1 Amended and Duplicate Claims

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Amended & Duplicate Claims Claim # Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliqui13271 Aerovías de México, S.A. de C.V. WON, AN HYE 0.00 0.00 0.00 960.30 960.30 USD N4F, 44, SANGAM-RO 39-GIL, GANGDONG-GU, SEOUL 05357 SOUTH KOREA Date Filed: 1/13/2021 Surviving 11405 Aerovías de México, S.A. de C.V. AN, HYE WON 0.00 0.00 0.00 2,880.89 2,880.89 USD NClaim: 4F,44, SANGAM-RO 39-GIL, GANGDONG-GU, Date Filed: 1/3/2021 SEOUL, 05357 SOUTH KOREA 13273 Aerovías de México, S.A. de C.V. WON, AN HYE 0.00 0.00 0.00 960.30 960.30 USD N4F, 44, SANGAM-RO 39-GIL, GANGDONG-GU, SEOUL 05357 SOUTH KOREA Date Filed: 1/13/2021 Surviving 11405 Aerovías de México, S.A. de C.V. AN, HYE WON 0.00 0.00 0.00 2,880.89 2,880.89 USD NClaim: 4F,44, SANGAM-RO 39-GIL, GANGDONG-GU, Date Filed: 1/3/2021 SEOUL, 05357 SOUTH KOREA 13275 Aerovías de México, S.A. de C.V. WON, AN HYE 0.00 0.00 0.00 960.30 960.30 USD N4F, 44, SANGAM-RO 39-GIL, GANGDONG-GU, SEOUL 05357 SOUTH KOREA Date Filed: 1/13/2021 Surviving 11405 Aerovías de México, S.A. de C.V. AN, HYE WON 0.00 0.00 0.00 2,880.89 2,880.89 USD NClaim: 4F,44, SANGAM-RO 39-GIL, GANGDONG-GU, Date Filed: 1/3/2021 SEOUL, 05357 SOUTH KOREA

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Amended & Duplicate Claims Claim # Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliqui 13278 Aerovías de México, S.A. de C.V. WON, AN HYE 0.00 0.00 0.00 761.73 761.73 USD N4F, 44, SANGAM-RO 39-GIL, GANGDONG-GU, SEOUL 05357 SOUTH KOREA Date Filed: 1/13/2021 Surviving 11405 Aerovías de México, S.A. de C.V. AN, HYE WON 0.00 0.00 0.00 2,880.89 2,880.89 USD NClaim: 4F,44, SANGAM-RO 39-GIL, GANGDONG-GU, Date Filed: 12/28/2020 SEOUL, 05357 SOUTH KOREA 11481 Aerovías de México, S.A. de C.V. YANG, MIHEE 0.00 0.00 0.00 363.00 363.00 USD N10F KCMI KOFIA B/D 143 UISADANG-DAERO, YEONGDEUNGPO-GU SEOUL 07332 REPUBLIC OF KOREA Date Filed: 1/4/2021 Surviving 10928 Aerovías de México, S.A. de C.V. MIHEE, YANG 0.00 0.00 0.00 362.53 362.53 USD NClaim: 10F KCMI KOFIA BD 143 UISADANG- Date Filed: 12/27/2020 DAERO YEONGDEUNGPO-GU SEOUL 07331 SOUTH KOREA 10755 Aerovías de México, S.A. de C.V. YANG, SEOHYEON 0.00 0.00 0.00 1,136.38 1,136.38 USD N54,PUREUNMAEUL- RO,DEOGYANG-GU,GOYANG-SI 403DONG 1001HO GYEONGGI-DO 10270 SOUTH KOREA Date Filed: 12/27/2020 Surviving 10753 Aerovías de México, S.A. de C.V. CHO, MYUNGSANG 0.00 0.00 0.00 1,136.38 1,136.38 USD NClaim: 54 PUREUNMAEUL-RO DEOGYANG-GU GOYANG-SI Date Filed: 1/4/2021 403DONG 1001HO GYEONGGI-DO 10270 SOUTH KOREA

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Amended & Duplicate Claims Claim # Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliqui 11546 Aerovías de México, S.A. de C.V. YANG, YOSUNG 0.00 0.00 0.00 453.74 453.74 USD NGYEONGGI-DO, REPUBLIC OF KOREA 177, JIJEDONGSAK 2-RO, PYEONGTAEK-SI 213-1503 PYEONGTAEK 17841 SOUTH KOREA Date Filed: 1/4/2021 Surviving 11507 Aerovías de México, S.A. de C.V. BACK, SUJIN 0.00 0.00 0.00 453.74 453.74 USD NClaim: PYEONGTAEK-SI, 177, JIJEDONGSAK 2-RO, Date Filed: 1/3/2021 213-1503 PYEONGTAEK-SI,GYEONGGI-DO 17841 SOUTH KOREA 11418 Aerovías de México, S.A. de C.V. YEO, SEOLHWA 0.00 0.00 0.00 347.27 347.27 USD N104/2402, 20 MUNSEONG-RO, GOA-EUP GUMI-SI 39147 SOUTH KOREA Date Filed: 1/3/2021 Surviving 11397 Aerovías de México, S.A. de C.V. KIM, JIHYUN 0.00 0.00 0.00 347.27 347.27 USD NClaim: 104/2402, 20 MUNSEONG-RO, GOA-EUP Date Filed: 1/11/2021 GUMI-SI 39147 SOUTH KOREA 12632 Aerovías de México, S.A. de C.V. YIM, GIHAK 0.00 0.00 0.00 484.32 484.32 USD N12, SEONGDEOKJEONG 15-GIL, SEONGDONG-GU SEOUL 04775 REPUBLIC OF KOREA Date Filed: 1/11/2021 Surviving 12622 Aerovías de México, S.A. de C.V. JO, HYEBIN 0.00 0.00 0.00 484.32 484.32 USD NClaim: 300, CHEONGNA CANAL-RO, SEO-GU Date Filed: 1/3/2021 INCHEON 22762 REPUBLIC OF KOREA

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Amended & Duplicate Claims Claim # Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliqui 12463 Aerovías de México, S.A. de C.V. YONGMIN JEON AND JUWON 0.00 0.00 0.00 2,577.65 2,577.65 USD NCHOI 1002HO 370 CHUNGNYEOL-DAERO DONGNAE-GU BUSAN-SI 47889 SOUTH KOREA Date Filed: 1/10/2021 Surviving 11389 Aerovías De México, S.A. De JUWON CHOI AND YONGMIN 0.00 0.00 0.00 2,577.64 2,577.64 USD NClaim: C.V. JEON 1002, 370, CHUNGNYEOL-DAERO Date Filed: 1/7/2021 DONGNAE-GU BUSAN-SI 47889 SOUTH KOREA 12036 Aerovías de México, S.A. de C.V. YOO, JIHEE 0.00 0.00 0.00 654.47 654.47 USD N4-6F, 143, CHANGGYEONGGUNG-RO, JONGNO-GU SEOUL 03136 REPUBLIC OF KOREA Date Filed: 1/7/2021 Surviving 12023 Aerovías de México, S.A. de C.V. CHA, JAESEUNG 0.00 0.00 0.00 326.20 326.20 USD NClaim: 48, DONGIL-RO 215-GIL, NOWON-GU Date Filed: 1/11/2021 305-1104 SEOUL 01761 SOUTH KOREA 12652 Aerovías de México, S.A. de C.V. YOO, MIHYUN 0.00 0.00 0.00 616.05 616.05 USD N19-27, SUPURAN-GIL, SIHEUNG- SI 1606-1802 GYEONGGI-DO 14986 SOUTH KOREA Date Filed: 1/11/2021 Surviving 12651 Aerovías de México, S.A. de C.V. HEO, SEULKI 0.00 0.00 0.00 616.05 616.05 USD NClaim: 19-27, SUPURAN-GIL, SIHEUNG- SI Date Filed: 1/13/2021 1606-1802 GYEONGGI-DO 14986 SOUTH KOREA

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Amended & Duplicate Claims Claim # Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliqui 13291 Aerovías de México, S.A. de C.V. YOO, SENA 0.00 0.00 0.00 1,200.00 1,200.00 USD N81, CHEONGMYEONGBUK-RO, YEONGTONG, SUWON GYEONGGI-DO 16709 SOUTH KOREA Date Filed: 1/13/2021 Surviving 13283 Aerovías de México, S.A. de C.V. KIM, DONGMIN 0.00 0.00 0.00 1,200.00 1,200.00 USD NClaim: 81, CHEONGMYEONGBUK-RO, YEONGTONG Date Filed: 1/6/2021 SUWON-SI, GYEONGGI-DO 16709 SOUTH KOREA 11993 Aerovías de México, S.A. de C.V. YOO, SUNG MIN 0.00 0.00 0.00 834.24 834.24 USD N86, DONGIL-RO 227-GIL, NOWON-GU, SEOUL 1618-1001 SEOUL 01618 SOUTH KOREA Date Filed: 1/7/2021 Surviving 11985 Aerovías de México, S.A. de C.V. YA, KANG MI 0.00 0.00 0.00 834.24 834.24 USD NClaim: 86, DONGIL-RO 227-GIL, NOWON-GU, SEOUL Date Filed: 1/3/2021 1618-1001 SEOUL 01618 SOUTH KOREA 11379 Aerovías de México, S.A. de C.V. YOO,JIHYUN 0.00 0.00 0.00 1,497.36 1,497.36 USD NGWANGMYEONG DONG 276-3 GWANGMYEONG SI 14290 SOUTH KOREA Date Filed: 1/3/2021 Surviving 11374 Aerovías de México, S.A. de C.V. JIHYUN, YOO 0.00 0.00 0.00 0.00 0.00 USD YeClaim: GWANGMYEONG-DONG 276-3 GWANGMYEONG-SI 14290 Date Filed: 1/4/2021 SOUTH KOREA

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Amended & Duplicate Claims Claim # Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliqui 11641 Aerovías de México, S.A. de C.V. YOON, JIMIN 0.00 0.00 0.00 446.18 446.18 USD N69, POIL-RO, UIWANG-SI GYEONGGI-DO 16022 REPUBLIC OF KOREA Date Filed: 1/4/2021 Surviving 11494 Aerovías de México, S.A. de C.V. YANG, EUNYOUNG 0.00 0.00 0.00 446.18 446.18 USD NClaim: 712DONG, 204HO, 63, GWANPYEONG-RO Date Filed: 1/5/2021 138BEON-GIL, DONGAN-GU ANYANG-SI GYEONGGI-DO, 14068 REPUBLIC OF KOREA 11701 Aerovías de México, S.A. de C.V. YOON, SUJIN 0.00 0.00 0.00 950.15 950.15 USD NE101-1202 10, WONSEON 1-RO, DANWON- GU ANSAN-SI, GYEONGGI-DO 15388 SOUTH KOREA Date Filed: 1/5/2021 Surviving 11696 Aerovías de México, S.A. de C.V. YOON, SUJIN 0.00 0.00 0.00 950.15 950.15 USD NClaim: E101-1202 10, WONSEON 1-RO, DANWON- Date Filed: 1/5/2021 GU ANSAN-SI, GYEONGGI-DO 15388 SOUTH KOREA 11705 Aerovías de México, S.A. de C.V. YOON, SUJIN 0.00 0.00 0.00 530.23 530.23 USD NE101-1202 10, WONSEON 1-RO, DANWON- GU ANSAN-SI, GYEONGGI-DO 15388 SOUTH KOREA Date Filed: 1/5/2021 Surviving 11695 Aerovías de México, S.A. de C.V. YOON, SUJIN 0.00 0.00 0.00 530.23 530.23 USD NClaim: E101-1202 10, WONSEON 1-RO, DANWON- Date Filed: 1/5/2021 GU ANSAN-SI, GYEONGGI-DO 15388 SOUTH KOREA

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Amended & Duplicate Claims Claim # Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliqui 11701 Aerovías de México, S.A. de C.V. YOON, SUJIN 0.00 0.00 0.00 950.15 950.15 USD NE101-1202 10, WONSEON 1-RO, DANWON- GU ANSAN-SI, GYEONGGI-DO 15388 SOUTH KOREA Date Filed: 1/5/2021 Surviving 11696 Aerovías de México, S.A. de C.V. YOON, SUJIN 0.00 0.00 0.00 950.15 950.15 USD NClaim: E101-1202 10, WONSEON 1-RO, DANWON- Date Filed: 1/5/2021 GU ANSAN-SI, GYEONGGI-DO 15388 SOUTH KOREA 11705 Aerovías de México, S.A. de C.V. YOON, SUJIN 0.00 0.00 0.00 530.23 530.23 USD NE101-1202 10, WONSEON 1-RO, DANWON- GU ANSAN-SI, GYEONGGI-DO 15388 SOUTH KOREA Date Filed: 1/5/2021 Surviving 11695 Aerovías de México, S.A. de C.V. YOON, SUJIN 0.00 0.00 0.00 530.23 530.23 USD NClaim: E101-1202 10, WONSEON 1-RO, DANWON- Date Filed: 1/10/2021 GU ANSAN-SI, GYEONGGI-DO 15388 SOUTH KOREA 12540 Aerovías de México, S.A. de C.V. YOON, YEOWOOK 0.00 0.00 0.00 961.15 961.15 USD N38 NAMYANG-RO 621 BEON-GIL 102-910 HWASEONG-SI 18270 SOUTH KOREA Date Filed: 1/10/2021 Surviving 12530 Aerovías de México, S.A. de C.V. YOON, YEOWOOK 0.00 0.00 0.00 961.15 961.15 USD NClaim: 38 NAMYANG-RO 621 BEON-GIL 102-910 Date Filed: 1/10/2021 HWASEONG-SI 18270 SOUTH KOREA

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Amended & Duplicate Claims Claim # Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliqui 12541 Aerovías de México, S.A. de C.V. YOON, YEOWOOK 0.00 0.00 0.00 961.15 961.15 USD N38 NAMYANG-RO 621 BEON-GIL 102-910 HWASEONG-SI 18270 SOUTH KOREA Date Filed: 1/10/2021 Surviving 12537 Aerovías de México, S.A. de C.V. YOON, YEOWOOK 0.00 0.00 0.00 961.15 961.15 USD NClaim: 38 NAMYANG-RO 621 BEON-GIL 102-910 Date Filed: 1/10/2021 HWASEONG-SI 18270 SOUTH KOREA 12542 Aerovías de México, S.A. de C.V. YOON, YEOWOOK 0.00 0.00 0.00 961.15 961.15 USD N38 NAMYANG-RO 621 BEON-GIL 102-910 HWASEONG-SI 18270 SOUTH KOREA Date Filed: 1/10/2021 Surviving 12538 Aerovías de México, S.A. de C.V. YOON, YEOWOOK 0.00 0.00 0.00 961.15 961.15 USD NClaim: 38 NAMYANG-RO 621 BEON-GIL 102-910 Date Filed: 1/10/2021 HWASEONG-SI 18270 SOUTH KOREA 12540 Aerovías de México, S.A. de C.V. YOON, YEOWOOK 0.00 0.00 0.00 961.15 961.15 USD N38 NAMYANG-RO 621 BEON-GIL 102-910 HWASEONG-SI 18270 SOUTH KOREA Date Filed: 1/10/2021 Surviving 12530 Aerovías de México, S.A. de C.V. YOON, YEOWOOK 0.00 0.00 0.00 961.15 961.15 USD NClaim: 38 NAMYANG-RO 621 BEON-GIL 102-910 Date Filed: 1/10/2021 HWASEONG-SI 18270 SOUTH KOREA

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Amended & Duplicate Claims Claim # Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliqui 12541 Aerovías de México, S.A. de C.V. YOON, YEOWOOK 0.00 0.00 0.00 961.15 961.15 USD N38 NAMYANG-RO 621 BEON-GIL 102-910 HWASEONG-SI 18270 SOUTH KOREA Date Filed: 1/10/2021 Surviving 12537 Aerovías de México, S.A. de C.V. YOON, YEOWOOK 0.00 0.00 0.00 961.15 961.15 USD NClaim: 38 NAMYANG-RO 621 BEON-GIL 102-910 Date Filed: 1/10/2021 HWASEONG-SI 18270 SOUTH KOREA 12542 Aerovías de México, S.A. de C.V. YOON, YEOWOOK 0.00 0.00 0.00 961.15 961.15 USD N38 NAMYANG-RO 621 BEON-GIL 102-910 HWASEONG-SI 18270 SOUTH KOREA Date Filed: 1/10/2021 Surviving 12538 Aerovías de México, S.A. de C.V. YOON, YEOWOOK 0.00 0.00 0.00 961.15 961.15 USD NClaim: 38 NAMYANG-RO 621 BEON-GIL 102-910 Date Filed: 1/13/2021 HWASEONG-SI 18270 SOUTH KOREA 13400 Aerovías de México, S.A. de C.V. YOU, KIM IN 0.00 0.00 0.00 443.84 443.84 USD N202DONG 1405HO,332,ANAJI-RO, GYEYANG-GU INCHEON, 21122 REPUBLIC OF KOREA Date Filed: 1/13/2021 Surviving 13398 Aerovías de México, S.A. de C.V. KIM,JI HUN 0.00 0.00 0.00 443.84 443.84 USD NClaim: 202DONG 1405HO,332,ANAJI-RO, GYEYANG-GU Date Filed: 12/31/2020 INCHEON, 21122 REPUBLIC OF KOREA

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Amended & Duplicate Claims Claim # Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliqui 12020 Aerovías de México, S.A. de C.V. YUN, MYEONGEUN 0.00 0.00 0.00 919.88 919.88 USD N108-503, 26, MANYANG-RO, DONGJAK-GU SEOUL 06918 SOUTH KOREA Date Filed: 1/7/2021 Surviving 11196 Aerovías De México, S.A. De KONG, SUKMIN 0.00 0.00 0.00 1,839.78 1,839.78 USD NClaim: C.V. 108-503, 26, MANYANG-RO, DONGJAK-GU Date Filed: SEOUL 06918 SOUTH KOREA Amended & Duplicate Claim Totals Count: 28 USD 0.00 0.00 0.00 24,344.67 24,344.67

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Exhibit 2 to Objection Sánchez Declaration

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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) DECLARATION OF RICARDO JAVIER SÁNCHEZ BAKER IN SUPPORT OF THE DEBTORS’ TWENTIETH OMNIBUS CLAIMS OBJECTION TO PROOFS OF CLAIM (AMENDED AND DUPLICATE CLAIMS) I, Ricardo Javier Sánchez Baker, hereby declare that the following is true to the best of my knowledge, information and belief: Background 1. I am the Chief Financial Officer of Grupo Aeroméxico, S.A.B. de C.V. (“Grupo Aeroméxico”), and its affiliates that are debtors and debtors in possession in these proceedings (collectively, the “Debtors;” the Debtors collectively with their direct and indirect non-Debtor subsidiaries, the “Company”). I have held several other positions at the Company since 2006, including serving as advisor to the Chief Executive Officer and Director of Revenue Management. I have been the chairman of the board of directors of the SABRE Corporation, a member of the SEAT Technical Committee, and a member of the Aeromexpress, CECAM, and PLM boards of directors. I have held various positions within the Federal Public Administration (Administración Pública Federal), including deputy director general of public debt for the Ministry of Finance and Public Credit in 2003 and 2005. I hold a bachelor’s degree in economics from the Universidad 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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Iberoamericana, a diploma in finance from Instituto Tecnológico Autónomo de México, and master’s and doctorate degrees in economics from the University of California, Los Angeles. I am familiar with the day-to-day operations, business, and financial affairs of the Debtors. 2. I submitted the Declaration of Ricardo Javier Sánchez Baker in Support of the Debtors’ Chapter 11 Petitions and First Day Pleadings [ECF No. 20] (the “Sánchez First Day Declaration”). I make this declaration (the “Declaration”) in support of the Debtors’ Twentieth Omnibus Claims Objection to Proofs of Claim (Amended and Duplicate Claims) (the “Objection”). I have reviewed the Objection or have otherwise had its contents explained to me, and the Objection is, to the best of my knowledge, accurate. 3. Except as otherwise indicated, all facts set forth in the Objection and this Declaration are based upon my personal knowledge, my review of relevant documents, information provided to me by employees working under my supervision, or my opinion based upon experience, knowledge, and information concerning the operations of the Debtors and the aviation industry as a whole. If I were called upon to testify, I could and would testify to each of the facts set forth herein. 4. I am generally familiar with the Debtors’ day-to-day operations, financing arrangements, business affairs, and Books and Records2 that reflect, among other things, the Debtors’ liabilities, and the amount thereof owed to their creditors as of the Petition Date. I have read the Objection and corresponding Proposed Order, each filed contemporaneously herewith. 5. To the best of my knowledge, information, and belief, the assertions made in the Objection are accurate. In evaluating the Claims, the Debtors and other reviewing parties have reviewed the Debtors’ Books and Records, the relevant Proofs of Claim, as well as the supporting documentation provided by the claimants, and determined that the Amended and Duplicate Claims 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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should be disallowed and expunged or otherwise treated as set forth in the Objection and Proposed Order. Amended and Duplicate Claims 6. To the best of my knowledge, information, and belief, based on the Debtors’ review of the Claims Register, the Books and Records, and each Amended and Duplicate Claim, the Debtors have determined that each Amended and Duplicate Claim set forth on Schedule 1 has been amended or superseded by other Claims, or are duplicative of other Claims filed by or on behalf of the same claimants relating to the same purported liability. 7. If the Amended and Duplicate Claims identified on Schedule 1 are not disallowed and expunged, the claimants identified therein may obtain double recovery on account of the same alleged liability, at the expense of the Debtors and other creditors. 8. Furthermore, for each Amended and Duplicate Claims, the Debtors have identified a Surviving Claim that asserts the same liability and is identified on Schedule 1 in the applicable row labeled “Surviving Claims.” Accordingly, I believe it is proper for the Court to enter the Proposed Order disallowing and expunging the Amended and Duplicate Claims as set forth therein and in the Objection. Conclusion 9. I am authorized to submit this Declaration on behalf of the Debtors. In my opinion, and for the reasons set forth in this Declaration and in the Objection, disallowing and expunging the Amended and Duplicate Claims is in the best interest of the Debtors’ estates.

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10. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury under the laws of the United States that, to the best of my knowledge and after reasonable inquiry, the foregoing is true and correct. Executed: October 4, 2021 By: /s/ Ricardo Javier Sánchez Baker Ricardo Javier Sánchez Baker Chief Financial Officer

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Exhibit B Omnibus Claims Hearing Procedures

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UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: Chapter 11 GRUPO AEROMÉXICO, S.A.B. de C.V., et Case No. 20-11563 (SCC) al., (Jointly Administered) Debtors.1 COURT-ORDERED OMNIBUS CLAIMS HEARING PROCEDURES The Omnibus Claims Hearing Procedures (the “Omnibus Claims Hearing Procedures”) described herein have been ordered by the United States Bankruptcy Court for the Southern District of New York (the “Court”) to apply to the chapter 11 cases of Grupo Aeroméxico, S.A.B. de C.V. and its affiliated debtors. Omnibus Claims Hearing Procedures 1. Pursuant to the Order Establishing Certain Notice, Case Management, and Administrative Procedures, entered on July 8, 2020 [ECF No. 79] (the “Case Management Order”), the Court established periodic omnibus hearings (the “Omnibus Hearings”) in these cases. The Debtors shall schedule the return date for claims objections, omnibus or otherwise, for hearing at Omnibus Hearings or other hearings the Debtors may schedule with the Court. 2. The Court may enter an order at the scheduled hearing sustaining an objection to proofs of claim (each, a “Proof of Claim”) with respect to which no response (a “Response”)2 is 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. 2 Any information submitted in connection with a Proof of Claim shall be part of the record with respect to the relevant Claim, and any such information already submitted need not be resubmitted in connection with the Omnibus Claims Hearing Procedures.

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properly filed and served or pursuant to a certificate of no objection in accordance with the Case Management Order. 3. The hearing to consider an objection to Proofs of Claim as to which a Response is properly filed and served (each, a “Contested Claim”) shall be set for a contested hearing (each, an “Omnibus Claims Hearing”) to be scheduled by the Debtors, in their discretion, as set forth herein. 4. The Debtors shall schedule an Omnibus Claims Hearing for a Contested Claim as follows: A. For a non-evidentiary hearing to address whether the Contested Claim has failed to state a claim against the Debtors that can be allowed and should be dismissed pursuant to Bankruptcy Rule 7012 (a “Sufficiency Hearing”), unless the Debtors serve the claimant with a Notice of Merits Hearing (as defined herein), the Sufficiency Hearing shall go forward at the return date set in accordance with paragraph 1 of these Omnibus Claims Hearing Procedures. The legal standard of review that will be applied by the Court at a Sufficiency Hearing will be equivalent to the standard applied by the Court upon a motion to dismiss for failure to state a claim upon which relief can be granted. B. For an evidentiary hearing on the merits of a Contested Claim (a “Merits Hearing”), the Debtors may, in their discretion, serve upon the relevant claimant, by email or overnight delivery, with a copy to the Official Committee of Unsecured Creditors, Apollo Management Holdings, L.P., and the Ad Hoc Group of Senior Noteholders,3 and file with the Court, a notice substantially in the form attached to the Claims Objections Procedures Order as Exhibit 2 (a “Notice of Merits Hearing”) at least thirty (30) calendar days prior to the date of such Merits Hearing. The rules and procedures applicable to such Merits Hearing will be set forth in a scheduling order issued by the Court in connection therewith. 5. Discovery with respect to a Contested Claim will not be permitted until either (a) the Court has held a Sufficiency Hearing and determined that the Contested Claim states a claim that could be allowed and should not be dismissed pursuant to Bankruptcy Rule 7012 or (b) the Debtors have served on the relevant claimant a Notice of Merits Hearing with respect to the Contested Claim. 3 As identified in the Third Amended Verified Statement of the Ad Hoc Group of Senior Noteholders Pursuant to Bankruptcy Rule 2019 [ECF No. 1731].

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6. The Debtors may file and serve a reply (a “Reply”) to a Response no later than 4:00 p.m., prevailing Eastern Time, on the day that is two (2) calendar days prior to the date of the applicable hearing (which may fall on a Saturday, Sunday, or legal holiday notwithstanding Bankruptcy Rule 9006 or equivalent provisions). 7. The Debtors, in their discretion, are authorized to adjourn a hearing scheduled in accordance herewith at any time by providing notice to the Court and the claimants.

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