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Full title: Motion for Omnibus Objection to Claim(s) /Debtors' Twenty-Third Omnibus Claims Objection to Proofs of Claim (Wrong Debtor, Incorrectly Classified, and/or Foreign Currency 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, 42 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

(“Grupo Aeroméxico”) and its affiliates that are debtors and debtors in possession in the above-captioned chapter 11 cases (collectively, the “Debtors”) filed their Twenty-Third Omnibus Claims Objection to Proofs of Claim (Wrong Debtor, Incorrectly Classified, and/or Foreign Currency Claims) (the “Objection”) with the United States Bankruptcy Court for the Southern District of New York (the “Bankruptcy Court”).The Debtors object to the Claims listed on Schedule 3 as such Claims (i) were asserted in a currency other than United States dollars or Mexican pesos (the “Foreign Currency Claims”) and (ii) are Wrong Debtor Claims, as each such Claim was filed against an incorrect Debtor according to 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 modify and/or reclassify the Claims identified on Schedules 1, 2, 3, and 4 attached hereto, as described therein; 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 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. Claims identified on Schedule 2 annexed hereto are hereby modified as described therein such that each Claim is hereby (i) reassigned from the Debtor against which such Claim was originally filed to the Debtor identified in the row labeled “Modified Claim” applicable thereto on Schedule 2 and (ii) reclassified as described in the corresponding row labeled “Modified Claim” applicable thereto on Schedule 2, and, to the extent reclassified by this Order, such Claims shall not be considered secured, administrative, and/or priority 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

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RECLASSIFY CERTAIN FILED PROOFS OF CLAIM. PARTIES RECEIVING THIS N OTICE OF THE DEBTORS’ TWENTY-THIRD OMNIBUS CLAIMS OBJECTION TO P ROOFS OF CLAIM SHOULD REVIEW THE OMNIBUS OBJECTION TO SEE IF T HEIR NAME(S) AND/OR CLAIM(S) ARE LOCATED IN THE OMNIBUS OBJECTION A ND/OR THE EXHIBITS AND SCHEDULES ATTACHED THERETO TO DETERMINE W HETHER THIS OBJECTION AFFECTS THEIR CLAIM(S). I F YOU HAVE QUESTIONS, PLEASE CONTACT GRUPO AEROMÉXICO’S COUNSEL, D AVIS POLK & WARDWELL LLP, AT aeromexicoclaims@dpw.com, RICHARD J. S TEINBERG (richard.steinberg@davispolk.com or +1-646-460-1954), OR MOSHE M ELCER (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’ TWENTY-THIRD OMNIBUS CLAIMS OBJECTION TO PROOFS OF CLAIM (WRONG DEBTOR, INCORRECTLY CLASSIFIED, AND/OR FOREIGN CURRENCY 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 Twenty-Third Omnibus Claims Objection to Proofs of Claim (Wrong Debtor, Incorrectly Classified, and/or Foreign Currency Claims) (the “Objection”) with the United States Bankruptcy Court for the Southern District of New York (the “Bankruptcy Court”). 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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The Objection is annexed hereto as Exhibit A. The Objection requests that the Bankruptcy Court modify and/or reclassify one or more of your Claims2 listed on the schedules (collectively, the “Schedules”) attached to Exhibit 1 of the Objection on the grounds that such Claims: (i) have been filed against the wrong Debtor (“Wrong Debtor Claims”); (ii) in part or in full, are not entitled to the asserted status or other priority (“Incorrectly Classified Claims”); and/or (iii) were asserted in a currency other than United States dollars or Mexican pesos (“Foreign Currency Claims”). Any Claim that the Bankruptcy Court modifies and/or reclassifies will remain on the Claims Register as modified and/or reclassified. 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 modification and/or reclassification of a Proof of Claim without further notice to a claimant. If you do NOT oppose the modification and/or reclassification of your Claim(s) listed on the Schedules attached 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 modification and/or reclassification of your Claim(s) listed on the Schedules attached 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 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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received on or before November 4, 2021 at 4:00 p.m. (prevailing Eastern Time) (the “Response Deadline”). Your Response, if any, must contain at a minimum the following: (i) a caption setting forth the name of the Bankruptcy Court, the names of the Debtors, the case number, and title of the Objection to which the response is directed; (ii) the name of the claimant and description of the basis for the amount of the Claim; (iii) a concise statement setting forth the reasons why the Claim should not be disallowed, expunged, modified, reduced and/or reclassified for the reasons set forth in the Objection, including, but not limited to, the specific factual and legal bases upon which you will rely in opposing the Objection; (iv) all documentation or 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

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Polk & Wardwell LLP, 450 Lexington Avenue, New York, New York 10017 (Attn: Timothy Graulich (timothy.graulich@davispolk.com), Stephen D. Piraino (stephen.piraino@davispolk.com), Erik P. Jerrard (erik.jerrard@davispolk.com), and 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 the Schedules attached 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 objections. Responding parties shall attend the Hearing telephonically so long as General Order M-543 is in effect or unless otherwise ordered by the Bankruptcy Court. You may participate in the Hearing

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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’ TWENTY-THIRD OMNIBUS CLAIMS OBJECTION TO PROOFS OF CLAIM (WRONG DEBTOR, INCORRECTLY CLASSIFIED, AND/OR FOREIGN CURRENCY CLAIMS) * * * TO THE CLAIMANTS LISTED ON THE SCHEDULES ATTACHED TO THE PROPOSED ORDER (ATTACHED HERETO AS EXHIBIT 1): YOUR RIGHTS MAY BE AFFECTED BY THIS OBJECTION 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 THE SCHEDULES ATTACHED TO THE PROPOSED ORDER. CLAIMANTS RECEIVING THIS OBJECTION SHOULD LOCATE THEIR NAMES AND CLAIMS ON THE SCHEDULES ATTACHED TO THE PROPOSED ORDER. * * * 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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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 Twenty-Third Omnibus Claims Objection to Proofs of Claim (Wrong Debtor, Incorrectly Classified, , and/or Foreign Currency 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 Twenty-Third Omnibus Claims Objection to Proofs of Claim (Wrong Debtor, Incorrectly Classified, and/or Foreign Currency 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”), modifying and/or reclassifying each of the claims identified on the schedules attached to the Proposed Order (collectively, the “Schedules”), 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 2 The Schedules are incorporated herein by reference.

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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 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

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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 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

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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 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)

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filed in the Chapter 11 Cases. The Debtors and their advisors are also comparing the Claims 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

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be seen to exist). Where the claimant alleges sufficient facts to support its claim, its claim is 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. See Fed. R. Bankr. P. 3007(d); Claims Obj. Proc. Order, ¶ 2(a), ECF No. 904 (providing additional bases under which the Debtors may file omnibus claim objections). Objection 22. By this Objection, the Debtors object to the Claims set forth on the Schedules as follows: Schedule Objection Basis(es) 1 Wrong Debtor Claims3 3 Each capitalized term used in this paragraph 22 shall have the meaning ascribed to such term in this Objection.

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Table 1 on page 14. Back to List of Tables
2 Wrong Debtor and Incorrectly Classified Claims
3 Wrong Debtor and Foreign Currency Claims
4 Incorrectly Classified Claim
A. Wrong Debtor Claims (Schedule 1) 23. The Debtors object to the Claims listed on Schedule 1 as such Claims were each filed against an incorrect Debtor according to the Debtors’ Books and Records (“Wrong Debtor Claims”), and request that each Wrong Debtor Claim be modified as Claims against the proper Debtor. 24. 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). Moreover, the Claims Objections Procedures Order authorizes the Debtors to file omnibus claims objections to claims “filed against … the wrong Debtor.” Claims Obj. Proc. Order, ¶ 2(a)(iii). 25. After analyzing each Wrong Debtor Claim and reviewing the Books and Records, the Debtors have determined that each Wrong Debtor Claim has been filed against the incorrect Debtor. In order to preserve the integrity and accuracy of the Claims Register, and to avoid claimants from improperly receiving recoveries on a Claim, the Debtors seek to modify the Wrong Debtor Claims by reassigning the Claim from the Debtor against which such Claim was originally filed to the Debtor identified in the “Correct Debtor” column applicable thereto on Schedule 1. B. Wrong Debtor and Incorrectly Classified Claims (Schedule 2) 26. The Debtors object to the Claims listed on Schedule 2 as such Claims are (i) incorrectly classified, as each such Claim is not entitled to its asserted status or other priority (the “Incorrectly Classified Claims”) and (ii) Wrong Debtor Claims, as each such Claim was filed against an incorrect Debtor according to the Debtors’ Books and Records (collectively, the “Wrong Debtor and Incorrectly Classified Claims”).

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27. After analyzing each Wrong Debtor and Incorrectly Classified Claim set forth on Schedule 2 and any documentation provided therewith, and after reviewing the Books and Records, the Debtors have determined that each Claim (a) in part or in full, (i) does not accurately reflect the correct classification according to the Debtors’ Books and Records; (ii) was filed with insufficient documentation to support the asserted status or other priority thereon; and/or (iii) asserts a status or other priority that is not supported by the Bankruptcy Code or other applicable law and (b) has been filed against the incorrect Debtor. 28. The specific basis for objection to each Wrong Debtor and Incorrectly Classified Claim is set forth on Schedule 2 in the column labeled “Reason.” The Debtors respectfully request that the Wrong Debtor and Incorrectly Classified Claims be (i) reclassified, as set forth on Schedule 2 in the corresponding row labeled “Modified Claim,” to avoid claimants from improperly receiving recoveries on account of their Claim at the expense of the Debtors and other creditors and (ii) modified by reassigning the Claim from the Debtor against which such Claim was originally filed to the Debtor identified in the “Correct Debtor” column applicable thereto on Schedule 2. C. Wrong Debtor and Foreign Currency Claims (Schedule 3) 29. The Debtors object to the Claims listed on Schedule 3 as such Claims (i) were asserted in a currency other than United States dollars or Mexican pesos (the “Foreign Currency Claims”) and (ii) are Wrong Debtor Claims, as each such Claim was filed against an incorrect Debtor according to the Debtors’ Books and Records (collectively, the “Wrong Debtor and Foreign Currency Claims”). 30. In order to preserve the integrity and accuracy of the Claims Register, and to avoid claimants from improperly receiving recoveries on a Claim, the Debtors respectfully request that the Wrong Debtor and Foreign Currency Claims be (i) reassigned from the Debtor against which such

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Claim was originally filed to the Debtor identified in the “Correct Debtor” column applicable thereto on Schedule 3 and (ii) modified, in accordance with the conversion rate set forth in paragraph 20 herein, to reflect a Claim in United States dollars as set forth on Schedule 3 in the corresponding row labeled “Modified Claim.” D. Incorrectly Classified Claim (Schedule 4) 31. The Debtors object to the Claim listed on Schedule 4 and request that such Claim be reclassified as set forth therein as it is not entitled to the asserted status or other priority (“Incorrectly Classified Claim”). 32. The Claims Objections Procedures Order authorizes the Debtors to file omnibus claims objections to Claims for which “[t]he claimant is not entitled to the asserted secured status or other priority.” Claims Obj. Proc. Order, ¶ 2(a)(v). After analyzing the Incorrectly Classified Claim and any documentation provided therewith, and after reviewing the Books and Records, the Debtors have determined that the Incorrectly Classified Claim, in part or in full, (i) does not accurately reflect the correct classification according to the Debtors’ Books and Records; (ii) was filed with insufficient documentation to support the asserted status or other priority thereon; and/or (iii) asserts a status or other priority that is not supported by the Bankruptcy Code or other applicable law. The specific basis for objection to the Incorrectly Classified Claim is set forth on Schedule 4 in the column labeled “Reason.” 33. The Debtors respectfully request that the Incorrectly Classified Claim be reclassified as set forth on Schedule 4 in the corresponding row labeled “Modified Claim,” to avoid the claimant from improperly receiving recoveries on account of its Incorrectly Classified Claim at the expense of the Debtors and other creditors.

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Separate Contested Matters 34. 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 a request for modification and/or reclassification herein shall be deemed a separate order with respect to each Claim. Response to Omnibus Objections 35. 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: 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.

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36. 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; and 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 claimant or their legal representative) possessing ultimate authority to reconcile, settle, or otherwise resolve the Claim on the claimant’s behalf. 37. 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 modifying and/or reclassifying their Claim(s), without further notice or a hearing. Reservation of Rights 38. 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 the Schedules. The Debtors further reserve their right to object to the: (i) Wrong Debtor Claims; (ii) Wrong Debtor and Incorrectly Classified Claims; (iii) Wrong Debtor and Foreign Currency Claims; and/or (iv) Incorrectly Classified Claim, in each case, on any other grounds that the Debtors

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discover or elect to pursue. The Debtors further 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. 39. Notwithstanding anything contained in this Objection, the exhibits attached hereto, or the Schedules, 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 40. 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 the Schedules; (iii) each party listed in paragraph 2(h) of 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 41. The Debtors have not previously sought the relief requested herein from the Court or any other court. [Remainder of Page Intentionally Left Blank]

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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

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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’ TWENTY-THIRD OMNIBUS CLAIMS OBJECTION TO PROOFS OF CLAIM (WRONG DEBTOR, INCORRECTLY CLASSIFIED, AND/OR FOREIGN CURRENCY 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 modify and/or reclassify the Claims identified on Schedules 1, 2, 3, and 4 attached hereto, as described therein; 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 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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notice need be provided; and the Court having reviewed and considered the Objection; and the Court having the opportunity to hold a 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 Wrong Debtor Claims identified on Schedule 1 annexed hereto are hereby modified as described therein such that each Wrong Debtor Claim is hereby reassigned from the Debtor against which such Claim was originally filed to the Debtor identified in the column labeled “Correct Debtor” applicable thereto on Schedule 1. 3. The Wrong Debtor and Incorrectly Classified Claims identified on Schedule 2 annexed hereto are hereby modified as described therein such that each Claim is hereby (i) reassigned from the Debtor against which such Claim was originally filed to the Debtor identified in the row labeled “Modified Claim” applicable thereto on Schedule 2 and (ii) reclassified as described in the corresponding row labeled “Modified Claim” applicable thereto on Schedule 2, and, to the extent reclassified by this Order, such Claims shall not be considered secured, administrative, and/or priority Claims, as applicable, for any purpose in the Chapter 11 Cases. 4. The Wrong Debtor and Foreign Currency Claims identified on Schedule 3 annexed hereto are hereby modified as described therein such that each Claim is hereby (i) reassigned from the Debtor against which such Claim was originally filed to the Debtor identified in the row labeled “Modified Claim” applicable thereto on Schedule 3 and (ii) modified as described in the

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corresponding row labeled “Modified Claim” applicable thereto on Schedule 3. 5. The Incorrectly Classified Claim identified on Schedule 4 annexed hereto is hereby reclassified as described in the corresponding row labeled “Modified Claim” applicable thereto on Schedule 4 and, to the extent reclassified by this Order, shall not be considered secured, administrative, and/or priority Claims, as applicable, for any purpose in the Chapter 11 Cases. 6. This Order shall be deemed a separate Order with respect to each of the Claims identified on the Schedules annexed hereto. 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. 7. 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. 8. 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. 9. 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: _____________, 2021 New York, New York THE HONORABLE SHELLEY C. CHAPMAN UNITED STATES BANKRUPTCY JUDGE

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Schedule 1 Wrong Debtor Claims

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Wrong Debtor Claims Claim # Transferred Wrong Debtor Correct Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliq 14858 No Grupo Aerovías de FLIGHT CENTRE TRAVEL 0.00 0.00 0.00 0.00 0.00 USD YAeroméxico, México, S.A. de GROUP LIMITED S.A.B. de C.V. C.V. 275 GREY ST SOUTH BRISBANE Date Filed: 12/22/2020 QLD 4101 AUSTRALIA 20482 No Grupo Aerovías de FRANCO, LINDA 0.00 0.00 550.07 0.00 550.07 USD YAeroméxico, México, S.A. de AVENDAÑO S.A.B. de C.V. C.V. 178 VELOCITY WAY SAN JOSE, CA 95110 Date Filed: 1/15/2021 10341 No Grupo Aerovías de FRANCO, MARIA DE LOS 0.00 0.00 0.00 889.00 889.00 USD Aeroméxico, México, S.A. de ANGELES BUENO S.A.B. de C.V. C.V. GUAMUCHIL 617 RINCONADA 1 TIJUANA, BC 22457 Date Filed: 12/9/2020 MÉXICO 14917 No Grupo Aerovías de MACNEIL, DAVID 0.00 0.00 0.00 1,782.68 1,782.68 USD Aeroméxico, México, S.A. de 240 CAMERON ST N S.A.B. de C.V. C.V. KITCHENER ON N2H 3B4 CANADA Date Filed: 8/22/2021 10404 No Grupo Aerovías de MENDEZ, VICTOR 0.00 0.00 0.00 1,600.00 1,600.00 USD Aeroméxico, México, S.A. de 3207 JUSTIN S.A.B. de C.V. C.V. LANCASTER, CA 93535 Date Filed: 12/11/2020 14925 No Grupo Aerovías de SLYVA, BETHANY 0.00 0.00 0.00 1,300.00 1,300.00 USD Aeroméxico, México, S.A. de 15 FARRELL ST, APT 2 S.A.B. de C.V. C.V. QUINCY, MA 02169 Date Filed: 14916 No Grupo Aerovías de STONE, KATREECE 0.00 0.00 0.00 2,471.60 2,471.60 USD Aeroméxico, México, S.A. de 6460 THORNHILL DR S.A.B. de C.V. C.V. OAKLAND CA 94611 Date Filed: Wrong Debtor Claim Totals: Count: USD 7 0.00 0.00 550.07 8,043.28 8,593.35

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Schedule 2 Wrong Debtor and Incorrectly Classified Claims

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Wrong Debtor & Incorrectly Classified Claims Claim # Transferred Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliquidated Reason 217 No Grupo Aeroméxico, AMIGO TRAVEL 0.00 0.00 42,000.00 0.00 42,000.00 No InsufficieS.A.B. de C.V. 19 PARK HILL AVE USD documentati YONKERS, NY 10701 support prio Date Filed: 1/4/2021 claim Modified 217 No Aerovías de 0.00 0.00 0.00 42,000.00 42,000.00 No Claim: México, S.A. de USD C.V. 11123 No Grupo Aeroméxico, ARKAS TURIZM SEYAHAT 0.00 847.00 0.00 0.00 847.00 USD No No goods deliS.A.B. de C.V. ACENTASI AS not entitled Date Filed: 12/30/2020 ARKAS MIST KONAKRAL administrat OFIS KULE claim (§ 503( Modified 11123 No Aerovías de IZMIR 35170 0.00 0.00 0.00 847.00 847.00 USD No Claim: México, S.A. de TURKEY C.V. 20553 No Grupo Aeroméxico, FERRER, CARLA MARIN 1,332.38 0.00 0.00 0.00 1,139.52 USD No InsufficieS.A.B. de C.V. C/ ROGER DE FLOR, 193 - 195 documentati Date Filed: 9/13/2021 PISO 4 PUERTA 4 support sec BARCELONA 08013 claim Modified 20553 No Aerovías de SPAIN 0.00 0.00 0.00 1,139.52 1,139.52 USD No Claim: México, S.A. de C.V. 14854 No Grupo Aeroméxico, MISSIONARY VENTURES 0.00 1,960.96 0.00 0.00 1,960.96 USD Yes No goods deliS.A.B. de C.V. INTERNATIONAL not entitled Date Filed: 4/22/2021 1017 MAITLAND CENTER administrat COMMONS BLVD claim (§ 503( Modified 14854 No Aerovías de MAITLAND, FL 32751 0.00 0.00 0.00 1,960.96 1,960.96 USD Yes Claim: México, S.A. de C.V. 20411 No Grupo Aeroméxico, VIAJES FUENTES SL 1,038.85 0.00 0.00 0.00 1,038.85 USD Yes InsufficieS.A.B. de C.V. PLAZA DEL JUNCAL, 2 documentati Date Filed: 1/15/2021 SEVILLA - ESPAÑA ES 41005 support secSPAIN claim Modified 20411 No Aerovías de 0.00 0.00 0.00 1,038.85 1,038.85 USD Yes Claim: México, S.A. de C.V. rong Debtor & Incorrectly Classified Claims Count: USD 5 2,371.23 2,807.96 42,000.00 0.00 46,986.33 Total:

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Schedule 3 Wrong Debtor and Foreign Currency Claim

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Wrong Debtor & Foreign Currency Claim Claim # Transferred Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliqui14915 False Grupo Aeroméxico, NAKAMURA, CHIHARU 0.00 0.00 0.00 785.00 785.00 CAD NS.A.B. de C.V. 138 CHARLTON BLVD Date Filed: 1/15/2021 NORTH YORK ON M2R 2J1 CANADA Modified 14915 False Aerovías de 0.00 0.00 0.00 570.06 570.06 USD NClaim: México, S.A. de C.V. rong Debtor & Foreign Currency Claim Total: Count: CAD 1 0.00 0.00 0.00 785.00 785.00

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Schedule 4 Incorrectly Classified Claim

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Incorrectly Classified Claim Claim # Transferred Debtor Name and Address of Claimant Secured Administrative Priority Unsecured Total Unliquidated Reason 12610 No Aerovías de PARK, KWON CHUL 2,000.00 0.00 2,000.00 0.00 2,000.00 USD No InsufficieMéxico, S.A. de NO 302, 48-11 documentati Date Filed: 1/11/2021 C.V. JIJOK-RO 349 BEON-GIL support secYUSEONG-GU claim Modified 12610 No Aerovías de DAEJEON 34071, 0.00 0.00 2,000.00 0.00 2,000.00 USD No Claim: México, S.A. de REPUBLIC OF KOREA C.V. Incorrectly Classified Claim Total: Count: USD 1 2,000.00 0.00 2,000.00 0.00 2,000.00

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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’ TWENTY-THIRD OMNIBUS CLAIMS OBJECTION TO PROOFS OF CLAIM (WRONG DEBTOR, INCORRECTLY CLASSIFIED, AND/OR FOREIGN CURRENCY 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’ Twenty-Third Omnibus Claims Objection to Proofs of Claim (Wrong Debtor, Incorrectly Classified, and/or Foreign Currency 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: (i) Wrong Debtor 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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(ii) Incorrectly Classified Claims; and/or (iii) Foreign Currency Claims should be modified and/or reclassified as set forth in the Objection and Proposed Order, and I concur with this determination. Wrong Debtor 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 Wrong Debtor Claim, the Debtors have determined that each Wrong Debtor Claim has been filed against an incorrect Debtor. If the Wrong Debtor Claims are not modified, the claimants identified on Schedule 1 may improperly receive recoveries on a Claim against the incorrect Debtor. Accordingly, I believe it is proper for the Court to enter the Proposed Order modifying the Wrong Debtor Claims as set forth therein and in the Objection. Wrong Debtor and Incorrectly Classified Claims 7. To the best of my knowledge, information, and belief, based on the Debtors’ review of the Claims Register, the Books and Records, and each Claim identified on Schedule 2, the Debtors have determined that (i) such Claims have been filed against an incorrect Debtor and (ii) the claimant for each of these Claims is not, in part or in full, entitled to the asserted status or other priority identified in the Claim. If the Wrong Debtor and Incorrectly Classified Claims identified on Schedule 2 are not modified and reclassified, the claimants identified therein may improperly receive recoveries on account of the Claim at the expense of the Debtors and other creditors. Accordingly, I believe it is proper for the Court to enter the Proposed Order modifying and reclassifying the Wrong Debtor and Incorrectly Classified Claims identified on Schedule 2 as set forth therein and in the Objection.

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Wrong Debtor and Foreign Currency Claims 8. To the best of my knowledge, information, and belief, based on the Debtors’ review of the Claims Register, the Books and Records, and each Wrong Debtor and Foreign Currency Claim identified on Schedule 3, the Debtors have determined that such Claims have been (i) filed against an incorrect Debtor and (ii) asserted in a currency other than United States dollars or Mexican pesos. If the Wrong Debtor and Foreign Currency Claims identified on Schedule 3 are not modified, the claimants identified therein may improperly receive recoveries on a Claim against the incorrect Debtor, and the Claims Register will not reflect the proper amounts for such Claims. Accordingly, I believe it is proper for the Court to enter the Proposed Order modifying the Wrong Debtor and Foreign Currency Claims identified on Schedule 3 as set forth therein and in the Objection. Incorrectly Classified Claim 9. To the best of my knowledge, information, and belief, based on the Debtors’ review of the Claims Register, the Books and Records, and the Incorrectly Classified Claim, the Debtors have determined that the claimant for such Claim is not entitled to the asserted status or other priority identified in the Claim. If the Incorrectly Classified Claim is not properly reclassified, the claimant identified on Schedule 4 may improperly receive recoveries on account of the Claim at the expense of the Debtors and other creditors. Accordingly, I believe it is proper for the Court to enter the Proposed Order reclassifying the Incorrectly Classified Claim as set forth therein and in the Objection. Conclusion 10. 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, modifying and/or reclassifying

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the Wrong Debtor, Incorrectly Classified, and/or Foreign Currency Claims is in the best interest of the Debtors’ estates. 11. 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 al., Case No. 20-11563 (SCC) Debtors.1 (Jointly Administered) 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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