HTML Document View

Full title: Fourth Application for Interim Professional Compensation / Fourth Interim Application of Morrison & Foerster LLP as Special Counsel for the Official Committee of Unsecured Creditors for Compensation and Reimbursement of Expenses Incurred for the Period from May 1, 2021 through September 30, 2021 for Morrison & Foerster LLP, Special Counsel, period: 5/1/2021 to 9/30/2021, fee:$181,993.50, expenses: $267.00. filed by Benjamin Butterfield. (Butterfield, Benjamin)

Document posted on Oct 25, 2021 in the bankruptcy, 86 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Participate on weekly call with Debtors' advisors Delgado, Juan Manuel 2.90 3,335.00 regarding case status (.9); participate on weekly call with Committee advisors regarding same (.7); correspond with internal working group regarding same (.4); participate on weekly update call with Mexican counsel (.5); call with Mexican Committee counsel (.4).Participate on weekly call with Debtors' advisors Delgado, Juan Manuel 2.00 2,300.00 regarding case status (.5); participate on follow-up call with Committee advisors (.6); correspond with internal working group regarding same (.3); participate on weekly update call with Mexican counsel (.6).Delgado, Juan Manuel 3.40 3,910.00 Mexican counsel (.5); participate on weekly call with Debtors' advisors regarding case update (.7); prepare for (.4) and participate on (.6) weekly update call with Committee advisors; correspond with internal working group regarding same (.5); participate on weekly update call with Debtors' Mexican counsel (.7).Participate on weekly call with Committee's Delgado, Juan Manuel 3.70 4,255.00 Mexican advisors regarding case update (.4); participate on weekly call with Debtor's advisors regarding same (.8); prepare for (.3) and participate on (.7) weekly call with Committee advisors regarding same; participate on call with FTI and noteholders (1.0); participate on weekly update call with Debtors' Mexican counsel (.5).Budgeting (Case) 2.70 2,092.50 ase Administration 7-Sep-21 Participate on weekly call with Committee's Delgado, Juan Manuel 3.20 3,680.00 Mexican counsel regarding case status (.4); prepare for (.2) and participate on (.6) weekly call with Debtors' advisors regarding same; prepare for (.3) and participate on (.5) call with Committee advisors regarding same; correspond with internal working group regarding case update (.3); participate on update call with Debtors' Mexican advisors (.7); correspond with internal working group regarding Delta and Mexican shareholder issues (.2).

List of Tables

Document Contents

MORRISON & FOERSTER LLP MORRISON & FOERSTER LLP Juan Manuel Delgado Benjamin W. Butterfield 600 Brickell Avenue Katherine E. Richardson Arnould Suite 1560 250 West 55th Street Miami, Florida 33131 New York, NY 10019 Telephone: (786) 472-6464 Telephone: (212) 468-8000 Facsimile: (786) 228-4869 Facsimile: (212) 468-7900 Email: jdelgado@mofo.com Email: bbutterfield@mofo.com krichardson@mofo.com Special Counsel to the Official Committee of Unsecured Creditors UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ) In re: ) Chapter 11 ) GRUPO AEROMÉXICO, S.A.B. de C.V., et al., ) Case No. 20-11563 (SCC) ) Debtors.1 ) (Jointly Administered) ) COVER SHEET TO THE FOURTH INTERIM APPLICATION OF MORRISON & FOERSTER LLP AS SPECIAL COUNSEL FOR THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES INCURRED FOR THE PERIOD FROM MAY 1, 2021 THROUGH SEPTEMBER 30, 2021 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.

1

Table 1 on page 2. Back to List of Tables
Name of Applicant: Morrison & Foerster LLP
Name of Client: Official Committee of Unsecured Creditors
Petition Date: June 30, 2020
Retention Date: September 25, 2020, nunc pro tunc to July 15, 2020
Date of Order Approving Employment: September 25, 2020 [Docket No. 473]
Time Period Covered by Application (the
“Application Period”):
May 1, 2021 through September 30, 2021
Total Compensation and Expenses
Requested During the Application Period
and Any Amount(s) Previously Requested:
Compensation: $181,993.50

Expenses: $267.00

Previously Requested: Chart on Next Page
Total Compensation and Expenses
Previously Awarded by Court:
Chart on Next Page
Name and Applicable Billing Rate for Each
Person Who Billed Time During the
Application Period, and Date of Bar
Admission for Each Attorney:
Exhibit C to Application
Total Hours Billed and Total Amount of
Billing for Each Person Who Billed Time
During the Application Period:
Exhibit C to Application
Blended Hourly Rate for Persons Who
Billed Time During the Application Period,
Excluding Paralegal or Other
Paraprofessional Time:
$959.16
This is a(n): ___ monthly X interim ___ final application.

2

Summary of Monthly Applications for Application Period:
Table 1 on page 3. Back to List of Tables
Date
Submitted
and ECF
No.
Application
Period
Requested
Fees
Requested
Expenses
Fees
Allowed
Expenses
Allowed
Fee
Holdback
7/23/2021
ECF No.
1467
5/1/2021 –
5/31/2021
$52,581.00 $7.50 $42,064.80 $7.50 $10,516.20
7/23/2021
ECF No.
1469
6/1/2021 –
6/30/2021
$41,500.00 $210.00 $33,200.00 $210.00 $8,300.00
8/10/2021
ECF No.
1539
7/1/2021 –
7/31/2021
$38,805.00 $12.90 $31,044.00 $12.90 $7,761.00
9/28/2021
ECF No.
1785
8/1/2021 –
8/31/2021
$27,397.50 $24.70 $21,918.00 $24.70 $5,479.50
10/11/2021
ECF No.
1872
9/1/2021 –
9/30/2021
$21,710.00 $11.90 $0.00 $0.00 $4,342.002
TOTALS None $181,993.50 $267.00 $128,226.80 $255.10 $36,398.70
2 Subject to no objections being filed in connection with Applicant’s Fourteenth Monthly Fee Application, which objections are due on or before November 15, 2021.

3

Summary of Prior Interim Fee Applications:
Table 1 on page 4. Back to List of Tables
Period
Covered by
Application
Date and
ECF. No.
of Order
on
Application
Interim Fees
Allowed
Interim Fees
Paid
Interim
Expenses
Allowed
Interim
Expenses
Paid
7/15/2020

8/31/2020
11/30/2020
ECF. No.
673
$972,417.753 $882,650.68 $2,221.80 $2,221.80
9/1/2020 -
12/31/2020
3/17/2021
ECF. No.
993
$1,403,089.754 $1,266,795.63 $27,621.95 $27,621.95
1/1/2021 –
4/30/2021
N/A N/A N/A N/A N/A
None None $2,375,507.50 $2,149,446.31 $29,843.75 $29,843.75
  3 In response to informal objections that the U.S. Trustee raised, Morrison & Foerster LLP agreed voluntarily to reduce its fees by $18,686.75. 4 In response to informal objections that the U.S. Trustee raised, Morrison & Foerster LLP agreed voluntarily to reduce its fees by $10,038.25.

4

MORRISON & FOERSTER LLP MORRISON & FOERSTER LLP Juan Delgado Benjamin W. Butterfield 600 Brickell Avenue Katherine E. Richardson Arnould Suite 1560 250 West 55th Street Miami, Florida 33131 New York, NY 10019 Telephone: (786) 472-6464 Telephone: (212) 468-8000 Facsimile: (786) 228-4869 Facsimile: (212) 468-7900 Email: jdelgado@mofo.com Email: bbutterfield@mofo.com krichardson@mofo.com Special Counsel to the Official Committee of Unsecured Creditors UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ) In re: ) Chapter 11 ) GRUPO AEROMÉXICO, S.A.B. de C.V., et al., ) Case No. 20-11563 (SCC) ) ) (Jointly Administered) Debtors.1 ) ) FOURTH INTERIM APPLICATION OF MORRISON & FOERSTER LLP AS SPECIAL COUNSEL FOR THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES INCURRED FOR THE PERIOD FROM MAY 1, 2021 THROUGH SEPTEMBER 30, 2021 Morrison & Foerster LLP (“Morrison & Foerster” or the “Applicant”), special counsel to the Official Committee of Unsecured Creditors (the “Committee”) of Grupo Aeroméxico, S.A.B. de C.V. and its debtor affiliates, as debtors and debtors in possession in the above-captioned chapter 11 cases (collectively, the “Debtors”), hereby submits its fourth interim application for compensation and reimbursement of expenses (the “Application”) for the period 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.

5

from May 1, 2021 through September 30, 2021 (the “Application Period”). In support of the Application, Morrison & Foerster respectfully represents as follows: JURISDICTION, VENUE AND STATUTORY PREDICATES 1. The United States Bankruptcy Court for the Southern District of New York (the “Court”) has jurisdiction over this matter pursuant to 28 U.S.C. §§ 157 and 1334. This matter is a core proceeding within the meaning of 28 U.S.C. § 157(b)(2). Venue before this Court is proper pursuant to 28 U.S.C. §§ 1408 and 1409. 2. The statutory bases for the relief requested herein are sections 330, 331, and 1103 of title 11 of the United States Code (the “Bankruptcy Code”), Rule 2016 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), and Rule 2016-1 of the Local Bankruptcy Rules for the Southern District of New York (the “Local Rules”). This Application has been prepared in accordance with General Order M-447, the Amended Guidelines for Fees and Disbursements for Professionals in Southern District of New York Bankruptcy Cases pursuant to Local Rule 2016-1(a) (as updated June 17, 2013) (the “Local Guidelines”), and the U.S. Trustee Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases, effective November 1, 2013 (the “U.S. Trustee Guidelines” and, together with the Local Guidelines, the “Guidelines”). Attached hereto as Exhibit A is a certification regarding compliance with the Local Guidelines. BACKGROUND A. The Chapter 11 Cases 3. On June 30, 2020 (the “Petition Date”), each of the Debtors filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code in this Court. The Debtors are operating their businesses and managing their properties as debtors-in-possession pursuant to sections 1107(a) and 1108 of the Bankruptcy Code. No trustee or examiner has been appointed

6

in these chapter 11 cases. The Debtors’ chapter 11 cases have been consolidated for procedural purposes only and are being jointly administered. 4. The factual background regarding the Debtors, including their business operations, their capital and debt structure, and the events leading to the filing of the 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 [Docket No. 20]. 5. On July 13, 2020, the Office of the United States Trustee for the Southern District of New York (the “U.S. Trustee”) appointed the Committee pursuant to section 1102 of the Bankruptcy Code [Docket No. 92].2 6. On October 1, 2021, the Debtors filed the Debtor’s Joint Plan of Reorganization under Chapter 11 of the Bankruptcy Code [Docket No. 1806] and the Disclosure Statement for the Joint Chapter 11 of Reorganization of Grupo Aeroméxico, S.A.B. de C.V. and its Affiliated Debtors [Docket No. 1807]. On October 15, the Debtors filed a revised plan of reorganization [Docket No. 1896] (as may be modified or amended, the “Plan”) and a revised disclosure statement [Docket No. 1897] (as may be modified or amended, the “Disclosure Statement”). A hearing on the Disclosure Statement is scheduled for November 10, 2021. 7. The remainder of the information set forth in Local Guidelines § A(2)(ii) and (iv) is not known to and cannot be reasonably ascertained by Applicant. B. The Retention of Morrison & Foerster 8. Immediately following its appointment, the Committee conducted its initial meeting and selected Morrison & Foerster as its counsel. 2 The initial members of the Committee were: (a) Bank of New York Mellon; (b) Asociación Sindical de Pilotos Aviadores; (c) Nordic Aviation Capital; (d) Falko Regional Aircraft Limited; (e) General Electric Company (“GE”); (f) World Fuel Services, Inc. (“World Fuel”) and (g) Sabre GLBL Inc. World Fuel and GE resigned from the Committee, effective February 3, 2021 and May 27, 2021, respectively.

7

9. On August 5, 2020, the Committee filed the Application for Entry of an Order Authorizing the Retention and Employment of Morrison & Foerster LLP as Counsel to the Official Committee of Unsecured Creditors Nunc Pro Tunc to July 15, 2020 [Docket No. 241] (the “Morrison & Foerster Retention Application”). On September 25, 2020, the Court entered the Order Authorizing the Retention and Employment of Morrison & Foerster LLP as Counsel to the Official Committee of Unsecured Creditors Nunc Pro Tunc to July 15, 2020 [Docket No. 473] (the “Retention Order”). 10. The terms and conditions of the Applicant’s retention and compensation are set forth in the Morrison & Foerster Retention Application and the Retention Order. As set forth therein, Applicant is authorized to apply for compensation for professional services rendered on an hourly basis and reimbursement of expenses in connection with these chapter 11 cases, subject to the Court’s approval and in compliance with applicable provisions of the Bankruptcy Code, Bankruptcy Rules, Local Rules, Guidelines, and Interim Compensation Order (as defined herein). The fees and expenses of the Applicant that are authorized to be paid shall be paid by the Debtors’ estates. The Applicant does not hold a retainer. In accordance with the Guidelines, the Applicant works with the Committee to develop a budget and staffing plan for each application period. 11. As of May 1, 2021, Brett H. Miller and Todd M. Goren, the attorneys with primary responsibility for the Committee’s representation in the Debtors’ chapter 11 cases, resigned from their positions at Morrison & Foerster and joined Willkie Farr & Gallagher LLP (“Willkie”). Shortly thereafter, Morrison & Foerster was informed by Willkie that the Committee determined to retain Willkie as its main counsel as of May 1, 2021.

8

12. On June 21, 2021, Applicant filed the Declaration of Juan Manuel Delgado in Support of the Application for Entry of an Order Authorizing the Retention and Employment of Morrison & Foerster LLP as Counsel for the Official Committee of Unsecured Creditors [Docket No. 1331] (the “First Delgado Declaration”). On June 25, 2021, Applicant filed the Supplemental Declaration of Juan Manuel Delgado in Support of the Application for Entry of an Order Authorizing the Retention and Employment of Morrison & Foerster LLP as Counsel for the Official Committee of Unsecured Creditors [Docket No. 1363] (the “Supplemental Delgado Declaration” and, together with the First Delgado Declaration, the “Delgado Declarations”). 13. As set forth in the Delgado Declarations, following its retention of Willkie, the Committee determined to continue to retain Morrison & Foerster to provide the following limited services to the Committee (and only insofar as such services are not duplicative of services otherwise rendered to the Committee by its professionals, including Willkie): (a) Liaising with the Debtors and their professionals (including their Mexican counsel) regarding the U.S. law implications of certain Mexican law issues that may arise in these chapter 11 cases and advising the Committee and its other professionals regarding the same; (b) Analyzing the U.S. law implications of certain Spanish language documents that are relevant to the Committee’s duties in these chapter 11 cases and advising the Committee and its other professionals regarding the same; (c) Attending meetings and teleconferences with the Debtors, the Committee, their respective professionals, and/or other parties-in-interest in connection with the foregoing; and (d) Performing other services that may reasonably be requested by the Committee from time to time, limited to U.S. law implications of Mexican law issues and Spanish language documents. 14. As set forth in the Supplemental Delgado Declaration, Morrison & Foerster may also act as conflicts counsel to the Committee (if necessary) on matters where Willkie is conflicted and Morrison & Foerster is not.

9

C. The Interim Compensation Order 15. On September 8, 2020, the Court entered the Order Pursuant to 11 U.S.C. §§ 105(a) and 331 Establishing Procedures for Monthly and Interim Compensation and Reimbursement of Expenses for Retained Professionals [Docket No. 360] (the “Interim Compensation Order”). Pursuant to the Interim Compensation Order, Applicant is authorized to file and serve its monthly invoices on the Application Recipients (as defined in the Interim Compensation Order). If no objections are raised prior to the expiration of the applicable Objection Deadline, the Debtors are authorized to pay 80% of the fees and 100% of the expenses identified in the monthly fee statement. SUMMARY OF PROFESSIONAL COMPENSATION AND REIMBURSEMENT OF EXPENSES REQUESTED 16. By this Application, Applicant seeks entry of an order (a) approving interim compensation in the amount of $181,993.50 and interim reimbursement of expenses in the amount of $267.00, and (b) granting such other and further relief as may be just and proper. 17. As expressed in the following chart, the amount sought in this Application is the aggregate of the compensation and expenses sought in Applicant’s monthly fee statements for the Application Period (the “Monthly Invoices”):
Table 1 on page 10. Back to List of Tables
Monthly
Application, Date
Filed & Docket
No.
Application
Period
Requested
Fees
Requested
Expenses
Fees Allowed Expenses
Allowed
Fee
Holdback
Tenth Monthly
Filed 7/23/2021
ECF No. 1467
5/1/2021 –
5/31/2021
$52,581.00 $7.50 $42,064.80 $7.50 $10,516.20
Eleventh Monthly
Filed 7/23/2021
ECF No. 1469
6/1/2021 –
6/30/2021
$41,500.00 $210.00 $33,200.00 $210.00 $8,300.00
Twelfth Monthly
Filed 8/10/2021
ECF No. 1539
7/1/2021 –
7/31/2021
$38,805.00 $12.90 $31,044.00 $12.90 $7,761.00

10

Table 1 on page 11. Back to List of Tables
Monthly
Application, Date
Filed & Docket
No.
Application
Period
Requested
Fees
Requested
Expenses
Fees Allowed Expenses
Allowed
Fee
Holdback
Thirteenth
Monthly
Filed 9/21/2021
ECF No. 1785
8/1/2021 –
8/31/2021
$27,397.50 $24.70 $21,918.00 $24.70 $5,479.50
Fourteenth
Monthly
Filed 10/11/2021
ECF No. 1872
9/1/2021 –
9/30/2021
$21,710.00 $11.90 $0.00 $0.00 $4,342.003
TOTALS None $181,993.50 $267.00 $128,226.80 $255.10 $36,398.70
18. The Monthly Invoices submitted by Applicant are subject to a 20% holdback as provided for in the Interim Compensation Order. The aggregate amount of Applicant’s holdback during the Application Period is $36,398.70 (which amount, for the avoidance of doubt, is exclusive of the $825,526.89 holdback for the periods from (a) July 15, 2020 through and including August 31, 2020, (b) September 1, 2020 through and including December 31, 2020, and (c) January 1, 2021 through and including April 30, 2021, hereinafter referred to as the “First Interim Fee Period”, the “Second Interim Fee Period”, and the “Third Interim Fee Period”, respectively). To date, no party has objected to the Monthly Invoices. 19. The Committee’s chairperson has been given the opportunity to review this Application and has approved the requested amounts set forth herein. 20. In the ordinary course of its business, Applicant maintains computerized records of the time spent in connection with providing professional services to the Committee in connection with these chapter 11 cases. Attached hereto as Exhibit B is a schedule of the total 3 Applicant’s request for payment of holdback fees in connection with the Fourteenth Monthly Fee Application is subject to any objection being filed as to those fees on or before November 15, 2021, the deadline by which objections to Morrison & Foerster’s Fourteenth Fee Application are due.

11

amount of fees incurred under each of Applicant’s internal task codes during the Application Period. 21. In addition, attached hereto as Exhibit C is a billing summary for the Application Period, which identifies each attorney and paraprofessional who rendered services during the Application Period, each attorney’s year of bar admission and area of practice, the aggregate time billed by each attorney and paraprofessional during the Application Period, the hourly billing rate for each attorney and paraprofessional, and the aggregate amount of fees generated by each professional and paraprofessional. The compensation requested by Applicant is based on the customary compensation charged by comparably skilled practitioners in cases other than cases under title 11. 22. Applicant also maintains computerized records of all expenses incurred in connection with the performance of professional services. A summary of the amounts and categories of expenses for which reimbursement is sought is attached hereto as Exhibit D. 23. Attached hereto as Exhibit E is a summary and comparison of the aggregate blended hourly rates billed by Morrison & Foerster’s New York and Miami timekeepers to non-bankruptcy matters during the current fiscal year as available and the blended hourly rates billed to the Committee during the Application Period. 24. Attached hereto as Exhibit F is a summary of Morrison & Foerster’s budget for the Application Period. The budget was developed prior to filing this Application and was approved by the Committee’s chairperson. 25. Attached hereto as Exhibit G is a summary of Morrison & Foerster’s staffing plan for the Application Period. The staffing plan was developed prior to filing this Application and was approved by the Committee’s chairperson.

12

26. A copy of Applicant’s computerized records of fees and expenses in the format specified by the Guidelines is attached hereto as Exhibit H. 27. There is no agreement or understanding between Applicant and any other person, other than partners of the firm, for the sharing of compensation to be received for services rendered in these chapter 11 cases. DESCRIPTION OF SERVICES AND EXPENSES AND RELIEF REQUESTED 28. To provide an orderly and meaningful summary of the services rendered by Applicant on behalf of the Committee during the Application Period, Applicant established, in accordance with the Guidelines and its internal billing procedures, separate task codes in connection with the chapter 11 cases. The following is a summary of the most significant professional services rendered by Applicant during the Application Period organized in accordance with Applicant’s internal system of task codes. 29. The summary is divided according to the project billing codes that Applicant created to best reflect the categories of tasks that it was required to perform in connection with these chapter 11 cases. Nevertheless, under the circumstances, and given the interconnectedness of the issues in these chapter 11 cases, certain of these categories may overlap with one another and it is possible that fees attributed to a particular category could have been attributed to other categories. For the avoidance of doubt, however, no work performed by Applicant has been included in more than one task code category. (a) Assumption and Rejection of Leases and Contracts – 003. Fees: $1,600.00 Total Hours: 2.0 30. This category includes time conducting diligence in connection with various matters concerning the assumption or rejection of unexpired leases and contracts.

13

(b) Budgeting (Case) – 005. Fees: $5,407.50 Total Hours: 6.9 31. This category includes time spent preparing prospective budgets and staffing plans, which must be prepared to comply with the U.S. Trustee Guidelines. (c) Business Operations – 006. Fees: $15,087.50 Total Hours: 20.0 32. This category includes time spent on matters relating to the Debtors’ business operations. During the Application Period, Morrison & Foerster spent time: (a) analyzing various documents regarding the Debtors’ capital structure, business operations, and related reporting; (b) reviewing presentations and analyses prepared by the Committee’s financial advisor, FTI Consulting Inc. (“FTI”), concerning the Debtors’ financial performance and business plan; (c) analyzing flight and governmental travel restrictions, and local regulations related thereto; (d) analyzing implications of foreign ownership issues in connection with Debtors’ business plan; and (e) analyzing Mexican law issues and Mexican filings in connection with, among other things, the Mexican Civil Aviation Authority’s progress in obtaining an FAA upgrade. (d) Case Administration – 007. Fees: $81,664.50 Total Hours: 82.3 33. This category includes all matters related to the internal administration of the Committee, including, but not limited to: (a) reviewing and monitoring the case docket, and retrieving and circulating pleadings to professionals; (b) participating on weekly conference calls with the Committee’s professionals and the Debtors’ advisors regarding case status, coordination of schedules, and other administrative matters; and (c) coordinating with Committee professionals regarding case schedules, filings, and deadlines.

14

34. In order to ensure that Morrison & Foerster provided the most efficient and cost-effective services to the Committee, weekly conference calls with the Committee’s professionals and Debtors’ professionals were typically attended by one member of the Morrison & Foerster team working on this representation. The purpose of these calls was to share information about the case in an efficient manner and to prepare for a weekly call with the members of the Committee. Attendance was necessary to keep people up to date on the various development in the chapter 11 cases as a large number of work streams occurred in real time. Given the level of activity in these chapter 11 cases to date, these calls required commensurate preparation. (e) Corporate Governance and Board Matters – 009. Fees: $155.00 Total Hours: 0.2 35. This category includes all time spent on issues relating to the Debtors’ corporate governance matters, including but not limited to analyzing corporate bylaws and other governance documents in connection with open issues concerning the Debtors’ partnership with Delta, including potential foreign ownership restrictions. (f) Employment and Fee Applications – 011. Fees: $29,995.00 Total Hours: 44.6 36. This category includes time spent with respect to the retention and employment of Morrison & Foerster as special counsel to the Committee. Specifically, during the Application Period, Morrison & Foerster spent time on various tasks relating to filings required under the Bankruptcy Code, Bankruptcy Rules, Local Rules, and Guidelines in connection with requests for the payment of fees and expenses. During the Application Period, attorneys and paraprofessionals drafted and filed Morrison & Foerster’s third interim fee application [Docket No. 1420] and fee statements for the months of March through and including August [Docket

15

Nos. 1164, 1303, 1467, 1469, 1539, and 1785]. Morrison & Foerster also prepared and filed the Delgado Declarations. (g) Employment and Fee Application Objections – 012 Fees: $1,632.50 Total Hours: 2.1 37. This category includes time spent with respect to the retention and employment of the Debtors’ professionals and potential objections thereto, including the review and analysis of supplemental declarations, fee statements, fee applications and statements of amounts paid to ordinary course professionals filed by the Debtors’ professionals. (h) Financing and Cash Collateral – 013. Fees: $320.00 Total Hours: 0.4 38. This category includes time spent on tasks relating to the Debtors’ debtor-in-possession financing facility and amendments thereto, and the related DIP motion [Docket No. 271] and order authorizing the Debtors to obtain DIP financing on a final basis [Docket No. 527]. (i) Meetings and Communications with Creditors – 015. Fees: $24,110.00 Total Hours: 21.3 39. This category includes time spent relating to communications with creditors, including preparation for and participation on weekly videoconference calls with the Committee as a whole, as well as calls and correspondence with individual Committee members and with FTI and Santamarina y Steta (the Committee’s “Mexican Counsel”). 40. In order to ensure that Morrison & Foerster provided the most efficient and cost-effective services to the Committee, each weekly Committee call was typically attended by one member of the Morrison & Foerster team working on this representation. Given the level of

16

activity in these chapter 11 cases to date, these Committee calls required commensurate preparation. 41. During Committee calls, Morrison & Foerster addressed key issues with the full Committee and its advisors. Prior to such calls, Morrison & Foerster reviewed pending matters requiring the Committee’s attention, analyzed any underlying documentation in connection therewith, and coordinated with FTI and Mexican Counsel on providing advice to the Committee. Thereafter, Morrison & Foerster discussed pending matters and ongoing work streams with the Committee and assisted the Committee in formulating a position with respect to certain matters and work streams. (j) Plan and Disclosure Statement – 017. Fees: $1,840.00 Total Hours: 1.6 42. This category includes time spent in connection with the analysis of potential plan structures and related exit financing and marketing strategies, and issues related thereto including corresponding with Mexican Counsel regarding related questions of Mexican law. (k) Discovery – 023 Fees: $215.00 Total Hours: 0.2 43. This category includes time spent engaging in aspects of the discovery process during the Application Period. (l) Hearings – 024. Fees: $6,340.00 Total Hours: 7.7 44. This category includes time spent preparing for and attending Court hearings, including a hearing on the retention of Willkie by the Committee. Morrison & Foerster notes that, during the Application Period, the Court anticipated a number of hearings, the majority of which were ultimately either adjourned or deemed unnecessary. Morrison & Foerster

17

nonetheless spent time preparing for and coordinating with the Debtors’ advisors regarding the status of such hearings. (m) Claims Investigation – 026. Fees: $11,322.50 Total Hours: 9.5 45. This category includes time spent in connection with the Committee’s investigation of potential estate claims and causes of action that might serve as a source of recovery for the Debtors’ unsecured creditors. Morrison & Foerster attorneys also participated on conference calls with FTI, the Committee’s Mexican Counsel , the Debtors’ professionals, and the Debtors’ other stakeholders to discuss investigation strategy and coordinate work streams. (n) Lien Investigation – 027. Fees: $780.00 Total Hours: 0.6 46. This category includes time spent finalizing the findings of the lien investigation previously conducted by Morrison & Foerster on behalf of the Committee, concerning certain of the Debtors’ aircraft leases. (o) Other Motions/Applications – 029. Fees: $1,524.00 Total Hours: 2.1 47. This category includes time spent reviewing and analyzing other motions and pleadings that the Debtors have filed, or anticipate needing to file, in these chapter 11 cases, as well as reviewing certain pleadings filed in the currently pending chapter 11 cases of the Debtors’ peer airlines in connection with potential implications in these chapter 11 cases.

18

(p) Time Entry Review – 032. Fees: $23,950.00 Total Hours: 30.0 48. This category includes time spent reviewing and revising attorney and paraprofessional time entries in order to comply with the Guidelines. However, as a concession to the Debtors’ estates and in accordance with the Guidelines, Morrison & Foerster is not seeking compensation for any fees in this category. APPLICANT STATEMENT PURSUANT TO APPENDIX B OF THE U.S. TRUSTEE GUIDELINES 49. The following statement is provided pursuant to ¶ C.5. of the U.S. Trustee Guidelines. (a) Question: Did you agree to any variations from, or alternatives to, your standard or customary billing rates, fees or terms for services pertaining to this engagement that were provided during the application period? If so, please explain. Answer: No. (b) Question: If the fees sought in this fee application as compared to the fees budgeted for the time period covered by this fee application are higher by 10% or more, did you discuss the reasons for the variation with the client? Answer: A chart comparing the amounts billed to each project category to the amount budgeted for each project category is attached hereto as Exhibit F. The fees sought in this Application ($181,993.50) do not exceed the fees budgeted ($445,200.00) for the time period covered by this Application. (c) Question: Have any of the professionals included in this fee application varied their hourly rate based on the geographic location of the bankruptcy case? Answer: No. (d) Question: Does the fee application include time or fees related to reviewing or revising time records or preparing, reviewing, or revising invoices? (This is limited to work involved in preparing and editing billing records that would not be compensable outside of bankruptcy and does not

19

include reasonable fees for preparing a fee application.). If so, please quantify by hours and fees. Answer: The Applicant spent 30 hours totaling $23,950.00 in fees reviewing and revising time records, but is not seeking payment of those fees. (e) Question: Does this fee application include time or fees for reviewing time records to redact any privileged or other confidential information? If so, please quantify by hours and fees. Answer: No. (f) Question: If the fee application includes any rate increases since retention: (i) Did your client review and approve those rate increases in advance? (ii) Did your client agree when retaining the law firm to accept all future rate increases? If not, did you inform your client that they need not agree to modified rates or terms in order to have you continue the representation, consistent with ABA Formal Ethics Opinion 11–458? Answer: The Application included the Applicant’s standard yearly rate increase for 2021. The Applicant’s hourly rates are consistent with the rates charged by other firms rendering comparable services. In accordance with the Morrison & Foerster Retention Order, the Applicant provided ten business days’ notice of the rate changes to the Debtors, the U.S. Trustee, and the Committee and filed such notice with the Court [Docket No. 734]. CONCLUSION 50. Applicant believes that the services rendered during the Application Period on behalf of the Committee were reasonable and necessary within the meaning of section 330 of the Bankruptcy Code. Further, the expenses requested were actual and necessary to the performance of Applicant’s services. 51. Applicant therefore requests entry of an order (a) approving interim compensation in the amount of $181,993.50 and interim reimbursement of expenses in the amount of $267.00, and (b) granting such other and further relief as may be just and proper.

20

Dated: October 26, 2021 MORRISON & FOERSTER LLP New York, New York /s/ Benjamin W. Butterfield Benjamin W. Butterfield Katherine E. Richardson Arnould 250 West 55th Street New York, NY 10019 Telephone: (212) 468-8000 Facsimile: (212) 468-7900 Email: bbutterfield@mofo.com krichardson@mofo.com Juan Manuel Delgado 600 Brickell Avenue Suite 1560 Miami, Florida 33131 Telephone: (786) 472-6464 Facsimile: (786) 228-4869 Email: jdelgado@mofo.com Special Counsel to the Official Committee of Unsecured Creditors

21

EXHIBIT A

22

MORRISON & FOERSTER LLP MORRISON & FOERSTER LLP Juan Manuel Delgado Benjamin W. Butterfield 600 Brickell Avenue Katherine E. Richardson Arnould Suite 1560 250 West 55th Street Miami, Florida 33131 New York, NY 10019 Telephone: (786) 472-6464 Telephone: (212) 468-8000 Facsimile: (786) 228-4869 Facsimile: (212) 468-7900 Email: jdelgado@mofo.com Email: bbutterfield@mofo.com krichardson@mofo.com Special Counsel to the Official Committee of Unsecured Creditors UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ) In re: ) Chapter 11 ) GRUPO AEROMÉXICO, S.A.B. de C.V., et al., ) Case No. 20-11563 (SCC) ) ) (Jointly Administered) Debtors.1 ) ) CERTIFICATION UNDER GUIDELINES FOR FEES AND DISBURSEMENTS FOR PROFESSIONALS IN RESPECT OF THE FOURTH INTERIM APPLICATION OF MORRISON & FOERSTER LLP AS SPECIAL COUNSEL FOR THE OFFICIAL COMMITTEE OF UNSECURED CREDITORS FOR COMPENSATION AND REIMBURSEMENT OF EXPENSES INCURRED FOR THE PERIOD FROM MAY 1, 2021 THROUGH SEPTEMBER 30, 2021 I, Juan Manuel Delgado, hereby certify that: 1. I am a partner with Morrison & Foerster LLP (the “Firm”), which serves as special counsel to the Official Committee of Unsecured Creditors of Grupo Aeroméxico, S.A.B. de C.V., et al. and its affiliates that are debtors and debtors in possession in the above-captioned chapter 11 cases (collectively, the “Debtors”). 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.

23

2. This certification is made in respect of the Firm’s compliance with General Order M-447, Amended Guidelines for Fees and Disbursements for Professionals in Southern District of New York Bankruptcy Cases pursuant to Local Rule 2016-1(a) (as updated June 17, 2013) (the “Local Guidelines”), and the U.S. Trustee Guidelines for Reviewing Applications for Compensation and Reimbursement of Expenses Filed under 11 U.S.C. § 330 by Attorneys in Larger Chapter 11 Cases, effective November 1, 2013 (the “US Trustee Guidelines” and, together with the Local Guidelines, the “Guidelines”), and the Order Pursuant to 11 U.S.C. §§ 105(a) an 331 Establishing Procedures for Monthly and Interim Compensation and Reimbursement of Expenses for Retained Professionals [Docket No. 360] (the “Interim Compensation Order”), in connection with the Firm’s application filed contemporaneously herewith (the “Application”), for interim compensation and reimbursement of expenses for the period commencing May 1, 2021 through and including September 30, 2021, in accordance with the Guidelines. 3. In respect of Section B.1 of the Local Guidelines, I certify that: (a) I have read the Application; (b) to the best of my knowledge, information, and belief formed after reasonable inquiry, the fees and expenses sought fall within the Guidelines; (c) the fees and disbursements sought are billed at rates and in accordance with practices customarily employed by the Firm and generally accepted by the Firm’s clients; and (d) in providing any reimbursable services reflected in the Application, the Firm did not make a profit on those services, whether performed by the Firm in-house or through a third party.

24

4. I further certify that the Firm has complied with the notice provisions of the Interim Compensation Order with respect to notice of its monthly statements of fees and disbursements and this Application. Dated: October 26, 2021 /s/ Juan Manuel Delgado Miami, Florida Juan Manuel Delgado

25

EXHIBIT B SUMMARY OF PROFESSIONAL SERVICES RENDERED BY PROJECT CATEGORY ON BEHALF OF THE COMMITTEE DURING THE APPLICATION PERIOD
Table 1 on page 26. Back to List of Tables
Project
Category
Number
Matter Description Total
Hours
Billed
Total Fees Requested
003 Assumption and Rejection of Leases and Contracts 2.00 $1,600.00
005 Budgeting (Case) 6.90 $5,407.50
006 Business Operations 20.00 $15,087.50
007 Case Administration 82.30 $81,664.50
009 Corporate Governance and Board Matters 0.20 $155.00
011 Employment and Fee Applications 44.60 $29,995.00
012 Employment and Fee Application Objections 2.10 $1,632.50
013 Financing and Cash Collateral 0.40 $320.00
015 Meetings and Communications with Creditors 21.30 $24,110.00
017 Plan and Disclosure Statement 1.60 $1,840.00
023 Discovery 0.20 $215.00
024 Hearings 7.70 $6,340.00
026 Claims Investigation 9.50 $11,322.50
027 Lien Investigation 0.60 $780.00
029 Other Motions/Applications 2.10 $1,524.00
032 Time Entry Review 30.00 $23,950.00
Total Incurred: None 231.5 $205,943.50
Less Client Accommodation for Time Entry Review
(100% of Fees Incurred):
None None $(23,950.00)
Total Requested: 231.5 None None $181,993.50

26

EXHIBIT C SUMMARY OF PROFESSIONAL SERVICES RENDERED BY PROFESSIONAL ON BEHALF OF THE COMMITTEE DURING THE APPLICATION PERIOD
Table 1 on page 27. Back to List of Tables
Name Position
with the
Applicant
Year
Admitted
or No. of
Years
with
Firm
Department Hourly
Billing
Rate
Total
Hours
Billed
Total
Compensation
Partners and Of Counsel None None None None None None
Bullard, Randy Partner 1993 Corporate $1,400.00 0.30 $420.00
Delgado, Juan
Manuel
Partner 2006 Corporate $1,150.00 82.50 $94,875.00
Foudy, Theresa
A.
Partner 1994 Business
Restructuring
& Insolvency
Group1
$1,325.00 7.50 $9,937.50
Marines, Jennifer
L.
Partner 2005 BRIG $1,350.00 1.00 $1,350.00
Smithline, Ruti Partner 2002 Litigation $1,300.00 0.20 $260.00
Dopsch, Peter C. Senior Of
Counsel
1987 Finance &
Projects
$1,300.00 0.60 $780.00
Butterfield,
Benjamin
Of
Counsel
2014 BRIG $975.00 16.30 $15,892.50
Associates and Attorneys None None None None None None
B.P. do Lago,
Luiz Fernando
Visiting
Int’l
Attorney
Brazil
(2012)
New York
(Pending)
Corporate $425.00 8.50 $3,612.50
Damast, Craig A. Attorney 1992 BRIG $1,070.00 0.20 $214.00
Kim, Hanna Associate 2020 Finance &
Projects
$695.00 1.60 $1,112.00
Richardson,
Katherine
Associate 2019 BRIG $775.00 71.80 $55,645.00
Rodriguez,
Roberto
Associate 2014 Corporate $925.00 7.50 $6,937.50
1 Hereinafter referred to as “BRIG”.

27

Table 1 on page 28. Back to List of Tables
Name Position
with the
Applicant
Year
Admitted
or No. of
Years
with
Firm
Department Hourly
Billing
Rate
Total
Hours
Billed
Total
Compensation
Russell, Miranda
Kelsey
Associate Pending BRIG $650.00 2.80 $1,820.00
Selick, Allison Associate 2018 BRIG $825.00 1.90 $1,567.50
Paraprofessionals None None None None None None
Senior 13 ½
Guido, Laura BRIG $400.00
Paralegal years
None None None None 28.80 $11,520.00
Total Incurred: None None None None 231.5 $205,943.50
Less Client Accommodation for Time Entry Review
(100% of Fees Incurred):
None None None None None $(23,950.00)
Total Requested: 231.5 None None None None None $181,993.50

28

Blended Rates
Table 1 on page 29. Back to List of Tables
PROFESSIONALS BLENDED
RATES
TOTAL
HOURS
BILLED
Partners and Counsel $1,139.43 108.4
Associates and Attorneys $751.94 94.3
Total Incurred by All Attorneys: $959.16 202.7
Paraprofessionals and Non-Legal Staff $400.00 28.8
Subtotal: $889.60 231.5
Less Client Accommodations for Time Entry Review
(100% of Fees Incurred):
None None
Total: $786.14 231.5 None None

29

EXHIBIT D SUMMARY OF EXPENSES INCURRED ON BEHALF OF THE COMMITTEE DURING THE APPLICATION PERIOD
Table 1 on page 30. Back to List of Tables
Service Description Amount
On-line Research - OTHER DATABASE - PACER $46.00
Miscellaneous Disbursement - COURTSOLUTIONS LLC/INTERNET $221.00
Total Requested: $267.00

30

EXHIBIT E CUSTOMARY AND COMPARABLE COMPENSATION DISCLOSURES FOR THE APPLICATION PERIOD1
Table 1 on page 31. Back to List of Tables
None Blended Hourly Rates None
Category of Timekeeper Billed by the New York and
Miami Offices (Excluding
BRIG) for the Trailing 12-
Month Period Ending on
September 30, 20212
Billed to Committee
May 1, 2021 to
September 30, 2021
Senior/ Equity Partner/
Shareholder
$1,153.76 $1,167.67
Senior Of Counsel $1,074.04 $1,300.00
Of Counsel $848.36 $975.00
Attorneys and Senior Associate
(7 or more years since first
admission)3
$807.30 $925.00
Associate
(4-6 years since first admission)
$681.06 $825.00
Junior Associate (1-3 years since
first admission)
$521.97 $768.72
1 The non-bankruptcy rates set forth in this Exhibit E to the Application reflect average rates charged by attorneys and paraprofessionals in the New York and Miami offices during the Application Period. The vast majority of the fees billed by the Applicant to this representation are attributable to limited number of professionals who were selected due to their significant experience in airline restructurings or with Mexican law and their ability to manage this complex representation effectively and efficiently. Because these professionals billed the majority of time in this representation, the average billing rates for the corresponding category of professional is necessarily skewed since it primarily reflects those individuals’ billing rates rather than a true average. 2 In accordance with the U.S. Trustee Guidelines, the non-bankruptcy blended rate was calculated using data for timekeepers in each of the Applicant’s domestic offices in which timekeepers collectively billed at least 10% of the hours to the Debtors’ chapter 11 cases during the Application Period and excludes all bankruptcy timekeepers. 3 There are no “Attorney” level non-bankruptcy attorneys in the New York and Miami offices, so the non-bankruptcy blended rate reflects the nationwide billing rate for attorneys at the “Attorney and Senior Associate” level of seniority.

31

Table 1 on page 32. Back to List of Tables
None Blended Hourly Rates None
Category of Timekeeper Billed by the New York and
Miami Offices (Excluding
BRIG) for the Trailing 12-
Month Period Ending on
September 30, 20212
Billed to Committee
May 1, 2021 to
September 30, 2021
Visiting International Attorney $440.13 $425.00
Senior Paralegal $398.22 $400.00
Total Attorney Rate $871.01 $959.16
Total Blended Rate (Attorneys,
Paraprofessionals)
$837.29 $889.60

32

EXHIBIT F BUDGET FOR THE APPLICATION PERIOD (ESTIMATED VS. ACTUAL)
Table 1 on page 33. Back to List of Tables
Task
Code
Project Category Estimated
Hours
Estimated
Fees
Actual
Hours
Actual
Fees
3 Assumption and Rejection of
Leases and Contracts
5 $4,500 2.00 $1,600.00
5 Budgeting (Case) 15 $13,500 6.90 $5,407.50
6 Business Operations 57 $51,500 20.00 $15,087.50
7 Case Administration 115 $106,000 82.30 $81,664.50
9 Corporate Governance and
Board Matters
8 $7,200 0.20 $155.00
11 Employment and Fee
Applications
50 $45,000 44.60 $29,995.00
12 Employment and Fee
Application Objections
8 $7,200 2.10 $1,632.50
13 Financing and Cash Collateral 5 $4,500 0.40 $320.00
15 Meetings and Communications
with Creditors
63 $58,000 21.30 $24,110.00
17 Plan and Disclosure Statement 60 $66,000 1.60 $1,840.00
23 Discovery 8 $7,200 0.20 $215.00
24 Hearings 38 $35,000 7.70 $6,340.00
26 Claims Investigation 20 $18,000 9.50 $11,322.50
27 Lien Investigation 4 $3,600 0.60 $780.00
29 Other Motions/Applications 20 $18,000 2.10 $1,524.00
32 Time Entry Review 70 $0.00 30.00 $23,950.00
None Totals: 546 $445,200.00 231.5 $205,943.50
None Less Client Accommodations for Time Entry Review
(100% of Fees Incurred):
None None None $(23,950.00)
None Total Requested: None None None $181,993.50

33

EXHIBIT G STAFFING PLAN FOR THE APPLICATION PERIOD
Table 1 on page 34. Back to List of Tables
Category of
Timekeeper
Number of
Timekeepers
Expected to Work on
the Matter during the
Application Period
Actual Number of
Timekeepers that
Worked on the
Matter during the
Application Period
Hourly Rates
Partner 5 5 $1,150 per hour to
$1,400 per hour
Of Counsel 2 2 $975 per hour to
$1,300 per hour
Associate 8 5 $650 per hour to $925
per hour
Paralegal 2 1 $400 per hour

34

EXHIBIT H

35

36

atter Number: 021093-0000001 Invoice Number: 6027175 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 Time Detail ate Services Timekeeper Hours Value ssumption and Rejection of Leases and Contracts 5-May-21 Review orders authorizing Debtors to enter into Richardson Arnould, 1.00 775.00 new aircraft lease agreements (.4) and redaction of Ka Boeing agreements (.2); review amended stipulation and order regarding equipment agreements (.4). 5-May-21 Review orders authorizing Debtors to enter into Selick, Allison 0.90 742.50 new aircraft lease agreements (.6); review LATAM as-entered orders authorizing JSA (.1) and Orix (.1) lease amendments, and side letter agreements (.1) for implications in Aeroméxico restructuring. 6-May-21 Review as-entered order authorizing Debtors to Selick, Allison 0.10 82.50 enter into amendments with Mayan Aircraft Holdings. otal: 003 Assumption and Rejection of Leases and Contracts 2.00 1,600.00 udgeting (Case) 1-May-21 Call with Mexican counsel regarding case budgets. Richardson Arnould, 0.40 310.00 Ka 2-May-21 Correspond with Mexican counsel and Willkie Richardson Arnould, 0.40 310.00 regarding case budgets. Ka otal: 005 Budgeting (Case) 0.80 620.00 usiness Operations 2-May-21 Correspond with internal working group regarding Delgado, Juan Manuel 0.20 230.00 Aeroméxico annual report. 3-May-21 Review weekly critical vendor report. Richardson Arnould, 0.30 232.50 Ka 4-May-21 Review and revise flight restrictions chart. B. P. do Lago, Luiz Fe 1.20 510.00 4-May-21 Review updated flight restrictions chart. Bullard, Randy 0.30 420.00 4-May-21 Review updated flight restrictions chart. Richardson Arnould, 0.20 155.00 Ka 4-May-21 Review and revise flight restrictions charts (.3); Rodriguez, Roberto 0.50 462.50 analyze COVID restrictions updates in Canada and Panama (.2). 4-May-21 Correspond with R. Rodriguez regarding flight Selick, Allison 0.10 82.50 restrictions. 5-May-21 Review notice of May ASA fuel payment. Richardson Arnould, 0.10 77.50 Ka

37

atter Number: 021093-0000001 Invoice Number: 6027175 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 ate Services Timekeeper Hours Value 0-May-21 Review stipulations and updates to fleet bible (1.5); Rodriguez, Roberto 2.00 1,850.00 call with M. Dunn (Willkie) regarding fleet tracker (.1); revise same (.4). 1-May-21 Review and revise flight restrictions chart. B. P. do Lago, Luiz Fe 1.60 680.00 2-May-21 Review updates to flight restrictions chart (.3) and Rodriguez, Roberto 0.60 555.00 local law changes in Peru and UK in connection therewith (.3). 7-May-21 Correspond with M. Dunn (Willkie) regarding fleet Rodriguez, Roberto 0.10 92.50 bible. 8-May-21 Review and revise flight restrictions chart. B. P. do Lago, Luiz Fe 0.80 340.00 8-May-21 Review updates to flight restrictions chart (.1); Rodriguez, Roberto 0.30 277.50 discuss new orders with respect to Mexico and South American countries (.2). 0-May-21 Call with Willkie regarding fleet trackers. Rodriguez, Roberto 0.50 462.50 5-May-21 Review and revise flight restrictions chart. B. P. do Lago, Luiz Fe 1.10 467.50 6-May-21 Review flight restrictions chart (.3) and updates to Rodriguez, Roberto 0.40 370.00 regulations in Argentina, Colombia, Uruguay, Canada and Germany (.1). otal: 006 Business Operations 10.30 7,265.00 ase Administration 3-May-21 Revise memorandum regarding current research Butterfield, Benjamin 1.50 1,462.50 workstreams. 3-May-21 Circulate notice of ECF filings and distribute Guido, Laura 0.20 80.00 recently filed pleadings to internal working group. 4-May-21 Call with D. Sinclair (Willkie) regarding current Butterfield, Benjamin 3.00 2,925.00 research workstreams (.5); prepare for (.5) and participate on (.9) call with Willkie regarding current workstreams; prepare for (.1) and participate on (.8) weekly professionals' call regarding case status; call with T. Foudy regarding materials to review with professionals on weekly call (.2). 4-May-21 Participate on weekly update call with Mexican Delgado, Juan Manuel 2.80 3,220.00 counsel (.5); prepare for (.2) and participate on (.9) call with Willkie regarding current workstreams; prepare for (.1) and participate on (.8) weekly professionals' call regarding case status; follow-up call with internal working group regarding same (.3).

38

atter Number: 021093-0000001 Invoice Number: 6027175 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 ate Services Timekeeper Hours Value 4-May-21 Participate on weekly professionals' call regarding Foudy, Theresa A. 1.70 2,252.50 case status (.8); call with B. Butterfield regarding materials to review with professionals on weekly call (.2); review same (.2); review docket update (.1); review calendar update (.1); correspond with J. Delgado and B. Butterfield regarding workstreams (.3). 4-May-21 Circulate notice of ECF filings and distribute Guido, Laura 0.40 160.00 recently filed pleadings to internal working group (.2); update case calendar (.2). 4-May-21 Participate on call with Willkie regarding current Kim, Hanna 0.90 625.50 workstreams. 4-May-21 Participate on call with Willkie regarding current Richardson Arnould, 2.60 2,015.00 workstreams (.9); prepare for (.3) and participate on Ka (.8) weekly professionals' call regarding case status; analyze recent filings in connection with same (.4); correspond with B. Butterfield regarding same (.1); correspond with J. Kirchgraber (FTI) regarding materials for professionals' call (.1). 4-May-21 Participate on call with Willkie regarding current Rodriguez, Roberto 1.70 1,572.50 workstreams (.9); prepare for (.3) and participate on (.5) weekly update call with Mexican counsel. 4-May-21 Participate on call with Willkie regarding current Russell, Miranda 0.80 520.00 workstreams (partial). Kelse 4-May-21 Call with internal working group regarding case Selick, Allison 0.40 330.00 status (.3); correspond with B. Butterfield regarding same (.1). 5-May-21 Review recent filings. Foudy, Theresa A. 0.10 132.50 5-May-21 Circulate notice of ECF filings and distribute Guido, Laura 0.30 120.00 recently filed pleadings to internal working group (.2); correspond with A. Ambeault (Willkie) regarding service distributions (.1). 5-May-21 Correspond with P. Dopsch regarding current Kim, Hanna 0.70 486.50 workstreams (.3); correspond with Willkie regarding same (.4). 6-May-21 Review recent filings. Foudy, Theresa A. 0.20 265.00 6-May-21 Circulate notice of ECF filings and distribute Guido, Laura 0.50 200.00 recently filed pleadings to internal working group (.3); update case calendar (.2). 7-May-21 Call with D. Sinclair (Willkie) regarding current Butterfield, Benjamin 0.20 195.00 workstreams. 7-May-21 Analyze current workstreams and related Foudy, Theresa A. 0.80 1,060.00 correspondence to Willkie.

39

atter Number: 021093-0000001 Invoice Number: 6027175 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 ate Services Timekeeper Hours Value 0-May-21 Circulate notice of ECF filings and distribute Guido, Laura 0.50 200.00 recently filed pleadings to internal working group (.2); prepare notice of appearance for J. Delgado (.3). 0-May-21 Correspond with internal working group and Richardson Arnould, 2.00 1,550.00 Willkie regarding current workstreams (1.4); Ka correspond with Willkie regarding weekly professionals' and Committee calls (.1); revise notice of appearance for J. Delgado (.3); correspond with same regarding same (.2). 1-May-21 Participate on weekly call with Mexican counsel Delgado, Juan Manuel 2.90 3,335.00 regarding case status (.2); participate on weekly professionals' call regarding same (.8); follow-up call with FTI regarding same (.9); correspond with internal working group regarding case update (.2); prepare for (.2) and participate on (.6) weekly update call with Sainz. 1-May-21 Review recent filings. Foudy, Theresa A. 0.10 132.50 1-May-21 Circulate notice of ECF filings and distribute Guido, Laura 0.60 240.00 recently filed pleadings to internal working group (.2); update case calendar (.2); file and coordinate service of notice of appearance of J. Delgado (.2). 1-May-21 Correspond with J. Delgado regarding notice of Richardson Arnould, 0.30 232.50 appearance (.1); finalize and coordinate filing of Ka same (.2). 2-May-21 Update distribution list for court filing notifications. Guido, Laura 0.10 40.00 3-May-21 Correspond with Willkie regarding weekly Richardson Arnould, 0.10 77.50 professionals' calls. Ka 7-May-21 Circulate notice of ECF filings to internal working Guido, Laura 0.30 120.00 group (.1); update case calendar (.2). 4-May-21 Circulate notice of ECF filings to internal working Guido, Laura 0.50 200.00 group (.1); update case calendar (.4). 5-May-21 Participate on weekly professionals' call (.7); Delgado, Juan Manuel 2.40 2,760.00 follow-up call with FTI regarding same (.7); correspond with internal working group regarding case update (.6); participate on weekly update call with Mexican counsel (.4). otal: 007 Case Administration 28.60 26,509.50 orporate Governance and Board Matters 4-May-21 Correspond with D. Sinclair (Willkie) regarding Richardson Arnould, 0.20 155.00 Committee bylaws. Ka otal: 009 Corporate Governance and Board Matters 0.20 155.00 mployment and Fee Applications

40

atter Number: 021093-0000001 Invoice Number: 6027175 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 ate Services Timekeeper Hours Value 0-May-21 Prepare MoFo's March fee statement (1.3); finalize, Guido, Laura 1.70 680.00 file and coordinate service of same (.4). 0-May-21 Revise March fee statement (.4); correspond with Richardson Arnould, 0.70 542.50 B. Butterfield regarding same (.2); coordinate filing Ka of same (.1). otal: 011 Employment and Fee Applications 2.40 1,222.50 mployment and Fee Application Objections 3-May-21 Review as-entered order for Mexican counsel Selick, Allison 0.10 82.50 compensation. 0-May-21 Correspond with Willkie and Mexican counsel Richardson Arnould, 0.70 542.50 regarding interim fee application for Mexican Ka counsel. 3-May-21 Review and revise FTI March fee statement (.4); Richardson Arnould, 0.60 465.00 correspond with M. Healy (FTI) regarding revisions Ka to same and related objection deadline (.2). 4-May-21 Correspond with M. Healy (FTI) regarding FTI Richardson Arnould, 0.10 77.50 March fee statement. Ka 5-May-21 Correspond with Willkie regarding interim fee Richardson Arnould, 0.40 310.00 applications for Mexican counsel. Ka otal: 012 Employment and Fee Application Objections 1.90 1,477.50 inancing and Cash Collateral 4-May-21 Review order to redact letters of intent (.1); review Richardson Arnould, 0.20 155.00 order to enter into amended PDPs (.1). Ka 4-May-21 Review orders authorizing PDP financing Selick, Allison 0.20 165.00 arrangements (.1) and redaction of letter of intent (.1). otal: 013 Financing and Cash Collateral 0.40 320.00 eetings and Communications with Creditors 5-May-21 Prepare for (.2) and participate on (.7) weekly Butterfield, Benjamin 0.90 877.50 Committee call regarding case status. 5-May-21 Prepare for (.1) and participate on (.7) weekly Delgado, Juan Manuel 0.80 920.00 Committee call regarding case status. 5-May-21 Correspond with B. Butterfield regarding summary Foudy, Theresa A. 0.20 265.00 of weekly Committee call. 5-May-21 Participate on weekly Committee call regarding Richardson Arnould, 0.70 542.50 case status. Ka 6-May-21 Participate on weekly Committee call regarding Delgado, Juan Manuel 0.70 805.00 case status. otal: 015 Meetings and Communications with Creditors 3.30 3,410.00 lan and Disclosure Statement

41

atter Number: 021093-0000001 Invoice Number: 6027175 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 ate Services Timekeeper Hours Value 3-May-21 Review (.7) and revise (.4) memorandum regarding Delgado, Juan Manuel 1.10 1,265.00 COFECE filings and precedents in Mexico for strategic investors. otal: 017 Plan and Disclosure Statement 1.10 1,265.00 iscovery 4-May-21 Correspond with Willkie regarding draft discovery Foudy, Theresa A. 0.10 132.50 requests in connection with PLM motion. 4-May-21 Correspond with T. Foudy regarding PLM Selick, Allison 0.10 82.50 discovery. otal: 023 Discovery 0.20 215.00 laims Investigation 3-May-21 Review newly filed annual report for information Foudy, Theresa A. 3.80 5,035.00 highlighted by Mexican counsel and information relevant to PLM investigation (1.2); draft presentation summarizing PLM investigation (2.6). 7-May-21 Correspond with T. Foudy regarding PLM Butterfield, Benjamin 0.20 195.00 investigation and related workstreams. 0-May-21 Correspond with B. Butterfield regarding PLM Foudy, Theresa A. 0.50 662.50 investigation workstreams (.2); draft instructions regarding PLM materials to gather and transmit (.3). 0-May-21 Correspond with internal working group regarding Russell, Miranda 0.70 455.00 PLM claims investigation research (.3); analyze Kelse same (.4). 0-May-21 Correspond with Willkie regarding status of and Smithline, Ruti 0.20 260.00 current workstreams in connection with claims investigation. otal: 026 Claims Investigation 5.40 6,607.50 ien Investigation 5-May-21 Review summary of status of lien review. Dopsch, Peter C. 0.30 390.00 otal: 027 Lien Investigation 0.30 390.00 ther Motions/Applications 3-May-21 Review weekly LATAM update for implications in Damast, Craig A. 0.20 214.00 Aeroméxico restructuring (.1); correspond with M. Russell regarding same (.1). 3-May-21 Analyze recent pleadings in LATAM cases for Richardson Arnould, 0.60 465.00 implications in Aeroméxico restructuring (.3); Ka revise memorandum summarizing same (.1); call with M. Russell regarding same (.2).

42

atter Number: 021093-0000001 Invoice Number: 6027175 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 ate Services Timekeeper Hours Value 3-May-21 Analyze recent pleadings in LATAM cases for Russell, Miranda 1.30 845.00 implications in Aeroméxico restructuring (.6); draft Kelse memorandum regarding summary of same (.4); call with K. Richardson regarding same (.2); revise same (.1). otal: 029 Other Motions/Applications 2.10 1,524.00 ime Entry Review 3-May-21 Revise March invoice for compliance with U.S. Richardson Arnould, 5.90 4,572.50 Trustee's guidelines (5.8); correspond with R. Ka Rodriguez regarding same (.1). 4-May-21 Revise March invoice for compliance with U.S. Richardson Arnould, 1.20 930.00 Trustee's guidelines (1.1); correspond with B. Ka Butterfield regarding same (.1). 6-May-21 Revise March invoice for compliance with U.S. Butterfield, Benjamin 2.10 2,047.50 Trustee's guidelines (1.9); call with K. Richardson regarding same (.2). 6-May-21 Call with B. Butterfield regarding revisions to Richardson Arnould, 1.20 930.00 March invoice (.2); revise same accordingly (.5); Ka correspond with R. Rodriguez regarding same (.2); correspond with B. Butterfield and J. Delgado regarding revised March invoice (.3). 8-May-21 Analyze April invoice for compliance with U.S. Richardson Arnould, 3.30 2,557.50 Trustee's guidelines. Ka otal: 032 Time Entry Review 13.70 11,037.50 Current Fees 52,581.00

43

atter Number: 021093-0000001 Invoice Number: 6027175 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 Timekeeper Summary No. Timekeeper Rate Hours Value 23904 Bullard, Randy 1,400.00 0.30 420.00 23905 Delgado, Juan Manuel 1,150.00 10.90 12,535.00 24614 Foudy, Theresa A. 1,325.00 7.50 9,937.50 11311 Smithline, Ruti 1,300.00 0.20 260.00 22662 Kim, Hanna 695.00 1.60 1,112.00 21823 Richardson Arnould, Ka 775.00 23.20 17,980.00 23952 Rodriguez, Roberto 925.00 6.10 5,642.50 23754 Russell, Miranda Kelse 650.00 2.80 1,820.00 24181 Selick, Allison 825.00 1.90 1,567.50 08676 Dopsch, Peter C. 1,300.00 0.30 390.00 20018 Butterfield, Benjamin 975.00 7.90 7,702.50 17323 Damast, Craig A. 1,070.00 0.20 214.00 13849 Guido, Laura 400.00 5.10 2,040.00 24626 B. P. do Lago, Luiz Fe 425.00 4.70 1,997.50 Client Accommodation - Time (11,037.50) Entry Review TOTAL 72.70 52,581.00

44

atter Number: 021093-0000001 Invoice Number: 6027175 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 Task Code Summary ask Code Description Hours Value 03 Assumption and Rejection of Leases and Contracts 2.00 1,600.00 05 Budgeting (Case) 0.80 620.00 06 Business Operations 10.30 7,265.00 07 Case Administration 28.60 26,509.50 09 Corporate Governance and Board Matters 0.20 155.00 11 Employment and Fee Applications 2.40 1,222.50 12 Employment and Fee Application Objections 1.90 1,477.50 13 Financing and Cash Collateral 0.40 320.00 15 Meetings and Communications with Creditors 3.30 3,410.00 17 Plan and Disclosure Statement 1.10 1,265.00 23 Discovery 0.20 215.00 26 Claims Investigation 5.40 6,607.50 27 Lien Investigation 0.30 390.00 29 Other Motions/Applications 2.10 1,524.00 32 Time Entry Review 13.70 11,037.50 Client Accommodation - Time Entry Review (11,037.50) TOTAL 72.70 52,581.00

45

atter Number: 021093-0000001 Invoice Number: 6027175 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 Disbursement Detail ate Description Value 1-May-21 On-line Research - OTHER DATABASE 7.50 Current Disbursements 7.50

46

atter Number: 021093-0000001 Invoice Number: 6027175 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 Invoice Summary U.S.Dollar otal Fees 52,581.00 otal Disbursements 7.50 otal Amount Due 52,588.50

47

atter Number: 021093-0000001 Invoice Number: 6027175 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 or your convenience, we have listed below previous invoices on this matter which our records show as outstanding and the total alance due on this account. If you have already submitted payment, we appreciate your promptness. If your records are not in greement, or if we can provide additional assistance, please call our Billing Department at (415) 268-6446 or (866) 314-5320 Date Invoice Number Currency Original Invoice Amount Payments Applied Amount Outstandin30-Sep-20 5949491 USD 993,326.30 884,872.48 108,453.82 29-Oct-20 5956137 USD 422,657.70 381,371.12 41,286.58 30-Nov-20 5964422 USD 259,825.20 232,649.02 27,176.18 23-Dec-20 5972347 USD 389,963.80 350,087.82 39,875.98 25-Jan-21 5978782 USD 368,303.25 330,309.62 37,993.63 26-Feb-21 5987007 USD 470,871.00 376,765.60 94,105.40 02-Apr-21 5995304 USD 793,735.66 635,882.00 157,853.66 07-May-21 6003763 USD 777,468.23 622,059.00 155,409.23 08-Jun-21 6013021 USD 825,128.40 0.00 825,128.40

48

49

atter Number: 021093-0000001 Invoice Number: 6027177 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 Time Detail ate Services Timekeeper Hours Value usiness Operations 1-Jun-21 Review and update flight restrictions chart. B. P. do Lago, Luiz Fe 1.70 722.50 2-Jun-21 Review and revise flight restrictions chart. Rodriguez, Roberto 0.30 277.50 8-Jun-21 Review and update flight restrictions chart. B. P. do Lago, Luiz Fe 0.90 382.50 8-Jun-21 Review revised flight restrictions chart and updated Rodriguez, Roberto 0.50 462.50 regulations in Mexico, Germany, Spain and United Kingdom regarding flight restrictions. 5-Jun-21 Review and update flight restrictions chart. B. P. do Lago, Luiz Fe 1.20 510.00 5-Jun-21 Analyze flight restrictions chart (.2); review local Rodriguez, Roberto 0.60 555.00 law regulations regarding travel restrictions to Argentina, Honduras, United States and Spain (.4). otal: 006 Business Operations 5.20 2,910.00 ase Administration 1-Jun-21 Participate on weekly call with Debtors' advisors Delgado, Juan Manuel 1.80 2,070.00 (.5); follow-up call with FTI (.5); correspond with internal working group regarding weekly update calls (.4); participate on weekly update call with Mexican counsel (.4). 1-Jun-21 Circulate notice of ECF filings to internal working Guido, Laura 0.30 120.00 group (.1); update case calendar (.2). 7-Jun-21 Circulate notice of ECF filings to internal working Guido, Laura 0.50 200.00 group (.1); update case calendar (.4). 8-Jun-21 Participate on weekly call with Debtors' advisors Delgado, Juan Manuel 3.90 4,485.00 (.9); participate on follow-up call with FTI (1.0); participate on weekly update call with Committee advisors (1.0); correspond with internal working group regarding same (.5); participate on weekly update call with Mexican counsel (.5). 4-Jun-21 Circulate notice of ECF filings to attorneys (.1); Guido, Laura 0.50 200.00 update case calendar and provide updates to attorneys (.4). 2-Jun-21 Participate on weekly call with Debtors' advisors Delgado, Juan Manuel 2.90 3,335.00 regarding case status (.9); participate on weekly call with Committee advisors regarding same (.7); correspond with internal working group regarding same (.4); participate on weekly update call with Mexican counsel (.5); call with Mexican Committee counsel (.4). 3-Jun-21 Call with Mexican counsel regarding case status. Delgado, Juan Manuel 0.70 805.00

50

atter Number: 021093-0000001 Invoice Number: 6027177 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 ate Services Timekeeper Hours Value 5-Jun-21 Circulate notice of ECF filings to internal working Guido, Laura 0.70 280.00 group (.1); update case calendar (.6). 9-Jun-21 Participate on weekly call with Committee advisors Delgado, Juan Manuel 1.70 1,955.00 regarding case status (.7); participate on follow-up call with FTI regarding same (.7); correspond with internal working group regarding same (.3). otal: 007 Case Administration 13.00 13,450.00 mployment and Fee Applications 2-Jun-21 Correspond with E. Jerrard (Davis Polk) regarding Richardson Arnould, 0.20 155.00 MoFo interim fee applications (.1); correspond with Ka B. Butterfield regarding same (.1). 3-Jun-21 Correspond with E. Jerrard (Davis Polk) regarding Richardson Arnould, 0.10 77.50 MoFo interim fee applications and related hearing. Ka 8-Jun-21 Prepare MoFo April fee statement. Guido, Laura 0.60 240.00 0-Jun-21 Prepare MoFo April fee statement. Guido, Laura 1.30 520.00 0-Jun-21 Correspond with internal working group regarding Richardson Arnould, 0.20 155.00 MoFo April fee statement. Ka 1-Jun-21 Correspond with K. Richardson regarding MoFo Guido, Laura 1.00 400.00 April fee statement (.2); review related ECF filing procedures (.2); revise, file and coordinate service of MoFo April fee statement (.5); coordinate preparations for third interim fee application (.1). 1-Jun-21 Revise MoFo April fee statement (.5); correspond Richardson Arnould, 1.10 852.50 with internal working group regarding same (.3); Ka coordinate filing of same (.1); correspond with internal working group regarding MoFo third interim fee application (.2). 4-Jun-21 Correspond with internal working group regarding Richardson Arnould, 0.30 232.50 declaration in support of MoFo retention and Ka upcoming hearing on Willkie retention. 5-Jun-21 Call with K. Richardson regarding declaration in Guido, Laura 2.50 1,000.00 support of MoFo retention (.1); prepare MoFo third interim fee application (2.4). 5-Jun-21 Draft declaration in support of MoFo retention Richardson Arnould, 2.40 1,860.00 (1.6); call with L. Guido regarding same (.1); Ka review Willkie retention application in connection with same (.4); correspond with B. Butterfield regarding same (.3). 6-Jun-21 Prepare MoFo third interim fee application. Guido, Laura 2.50 1,000.00 7-Jun-21 Revise supplemental Delgado declaration. Butterfield, Benjamin 0.70 682.50 7-Jun-21 Review MoFo third interim fee application. Guido, Laura 0.50 200.00

51

atter Number: 021093-0000001 Invoice Number: 6027177 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 ate Services Timekeeper Hours Value 7-Jun-21 Correspond with L. Guido regarding MoFo third Richardson Arnould, 0.70 542.50 interim fee application (.1); correspond with Ka internal working group regarding draft declaration in support of MoFo retention (.2); correspond with B. Butterfield and L. Guido regarding status of same (.4). 8-Jun-21 Correspond with internal working group and Richardson Arnould, 0.20 155.00 Willkie regarding declaration in support of Ka retention. 1-Jun-21 Finalize, file and coordinate service of declaration Guido, Laura 0.30 120.00 in support of MoFo retention. 1-Jun-21 Review and revise MoFo third interim fee Richardson Arnould, 2.60 2,015.00 application (2.2); finalize and coordinate filing of Ka declaration in connection with MoFo retention (.2); correspond with internal working group and Willkie regarding same (.2). 3-Jun-21 Draft supplemental declaration in support of MoFo Richardson Arnould, 1.40 1,085.00 retention (.8); correspond with B. Butterfield and J. Ka Delgado regarding same (.2); review correspondence from Willkie regarding U.S. Trustee comments in connection with same (.1); revise supplemental declaration (.2); correspond with Willkie regarding same (.1). 5-Jun-21 Revise supplemental declaration in support of Butterfield, Benjamin 0.20 195.00 MoFo retention. 5-Jun-21 Finalize, file and coordinate service of Guido, Laura 0.30 120.00 supplemental declaration in support of MoFo retention. 5-Jun-21 Revise supplemental declaration in support of Richardson Arnould, 0.50 387.50 MoFo retention (.1); correspond with internal Ka working group regarding same (.2); finalize supplemental declaration and coordinate filing of same (.2). otal: 011 Employment and Fee Applications 19.60 11,995.00 mployment and Fee Application Objections 4-Jun-21 Correspond with M. Healy (FTI) regarding fee Richardson Arnould, 0.20 155.00 statements. Ka otal: 012 Employment and Fee Application Objections 0.20 155.00 eetings and Communications with Creditors 9-Jun-21 Participate on weekly Committee call regarding Delgado, Juan Manuel 0.80 920.00 case update. 6-Jun-21 Prepare for (.2) and participate on (.7) weekly Delgado, Juan Manuel 0.90 1,035.00 Committee call regarding case status.

52

atter Number: 021093-0000001 Invoice Number: 6027177 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 ate Services Timekeeper Hours Value 3-Jun-21 Prepare for (.2) and participate on (.7) weekly Delgado, Juan Manuel 0.90 1,035.00 Committee call regarding case status. 0-Jun-21 Participate on weekly Committee call regarding Delgado, Juan Manuel 0.70 805.00 case status. otal: 015 Meetings and Communications with Creditors 3.30 3,795.00 earings 4-Jun-21 Correspond with B. Butterfield and L. Guido Richardson Arnould, 0.30 232.50 regarding upcoming hearing on Willkie retention Ka application. 7-Jun-21 Prepare June 22 telephonic hearing materials and Guido, Laura 0.30 120.00 coordinate telephonic appearance for same. 7-Jun-21 Correspond with B. Butterfield regarding June 22 Richardson Arnould, 0.60 465.00 hearing in connection with Willkie retention (.4); Ka review pleadings relating to same (.2). 4-Jun-21 Correspond with E. Jerrard (Davis Polk) regarding Richardson Arnould, 0.20 155.00 hearing on interim fee applications (.1); correspond Ka with internal working group regarding same (.1). 6-Jun-21 Coordinate June 22 telephonic hearing appearances. Guido, Laura 0.20 80.00 6-Jun-21 Correspond with J. Delgado regarding June 22 Richardson Arnould, 0.20 155.00 hearing on Willkie retention. Ka 1-Jun-21 Coordinate June 22 telephonic hearing appearance. Guido, Laura 0.10 40.00 1-Jun-21 Review notice of hearing agenda (.1); correspond Richardson Arnould, 0.30 232.50 with J. Delgado and B. Butterfield regarding Ka hearing on Willkie retention and related materials (.2). 2-Jun-21 Prepare for (.2) and attend (.7) hearing regarding Butterfield, Benjamin 1.30 1,267.50 Willkie retention; call with J. Delgado regarding same (.4). 2-Jun-21 Attend hearing regarding Willkie retention (.7); call Delgado, Juan Manuel 1.10 1,265.00 with B. Butterfield regarding same (.4). 2-Jun-21 Attend hearing regarding Willkie retention (partial). Richardson Arnould, 0.10 77.50 Ka otal: 024 Hearings 4.70 4,090.00 laims Investigation 1-Jun-21 Correspond with Mexican counsel regarding Delgado, Juan Manuel 1.10 1,265.00 shareholders support agreement. 2-Jun-21 Review shareholder support agreement (.8); Delgado, Juan Manuel 1.20 1,380.00 correspond with internal working group regarding same (.4). 5-Jun-21 Prepare for (.4) and participate on (1.4) call Delgado, Juan Manuel 1.80 2,070.00 regarding shareholder support agreement. otal: 026 Claims Investigation 4.10 4,715.00

53

atter Number: 021093-0000001 Invoice Number: 6027177 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 ate Services Timekeeper Hours Value ien Investigation 6-Jun-21 Correspond with B. Butterfield regarding true sale Dopsch, Peter C. 0.30 390.00 analysis. otal: 027 Lien Investigation 0.30 390.00 ime Entry Review 1-Jun-21 Revise MoFo April invoice for compliance with Richardson Arnould, 3.20 2,480.00 U.S. Trustee's guideline (3.0); correspond with R. Ka Rodriguez regarding same (.2). 2-Jun-21 Revise MoFo April invoice for compliance with Richardson Arnould, 3.00 2,325.00 U.S. Trustee's guideline (2.8); correspond with Ka internal working group regarding same (.2). 3-Jun-21 Revise MoFo April invoice for compliance with Richardson Arnould, 0.40 310.00 U.S. Trustee's guideline (.3); correspond with B. Ka Butterfield regarding same (.1). 7-Jun-21 Revise MoFo April invoice for compliance with Butterfield, Benjamin 1.40 1,365.00 U.S. Trustee's guidelines. 7-Jun-21 Review comments to MoFo April invoice from B. Richardson Arnould, 1.10 852.50 Butterfield (.4); revise same accordingly (.5); Ka correspond with internal working group regarding same (.2). 8-Jun-21 Finalize MoFo April invoice (.4); correspond with Richardson Arnould, 0.90 697.50 internal working group regarding same (.5). Ka 9-Jun-21 Correspond with J. Delgado regarding MoFo April Richardson Arnould, 0.10 77.50 invoice. Ka otal: 032 Time Entry Review 10.10 8,107.50 Current Fees 41,500.00

54

atter Number: 021093-0000001 Invoice Number: 6027177 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 Timekeeper Summary No. Timekeeper Rate Hours Value 23905 Delgado, Juan Manuel 1,150.00 19.50 22,425.00 21823 Richardson Arnould, Ka 775.00 20.30 15,732.50 23952 Rodriguez, Roberto 925.00 1.40 1,295.00 08676 Dopsch, Peter C. 1,300.00 0.30 390.00 20018 Butterfield, Benjamin 975.00 3.60 3,510.00 13849 Guido, Laura 400.00 11.60 4,640.00 24626 B. P. do Lago, Luiz Fe 425.00 3.80 1,615.00 Client Accommodation - Time (8,107.50) Entry Review TOTAL 60.50 41,500.00

55

atter Number: 021093-0000001 Invoice Number: 6027177 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 Task Code Summary ask Code Description Hours Value 06 Business Operations 5.20 2,910.00 07 Case Administration 13.00 13,450.00 11 Employment and Fee Applications 19.60 11,995.00 12 Employment and Fee Application Objections 0.20 155.00 15 Meetings and Communications with Creditors 3.30 3,795.00 24 Hearings 4.70 4,090.00 26 Claims Investigation 4.10 4,715.00 27 Lien Investigation 0.30 390.00 32 Time Entry Review 10.10 8,107.50 Client Accommodation - Time Entry Review (8,107.50) TOTAL 60.50 41,500.00

56

atter Number: 021093-0000001 Invoice Number: 6027177 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 Disbursement Detail ate Description Value 2-Jun-21 Miscellaneous Disbursement COURTSOLUTIONS LLC, 6/22/2021 telephonic hearing 70.00 appearance 2-Jun-21 Miscellaneous Disbursement COURTSOLUTIONS LLC, 6/22/2021 telephonic hearing 70.00 appearance 2-Jun-21 Miscellaneous Disbursement COURTSOLUTIONS LLC, 6/22/2021 telephonic hearing 70.00 appearance Current Disbursements 210.00

57

atter Number: 021093-0000001 Invoice Number: 6027177 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 Invoice Summary U.S.Dollar otal Fees 41,500.00 otal Disbursements 210.00 otal Amount Due 41,710.00

58

atter Number: 021093-0000001 Invoice Number: 6027177 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: July 23, 2021 or your convenience, we have listed below previous invoices on this matter which our records show as outstanding and the total alance due on this account. If you have already submitted payment, we appreciate your promptness. If your records are not in greement, or if we can provide additional assistance, please call our Billing Department at (415) 268-6446 or (866) 314-5320 Date Invoice Number Currency Original Invoice Amount Payments Applied Amount Outstandin30-Sep-20 5949491 USD 993,326.30 884,872.48 108,453.82 29-Oct-20 5956137 USD 422,657.70 381,371.12 41,286.58 30-Nov-20 5964422 USD 259,825.20 232,649.02 27,176.18 23-Dec-20 5972347 USD 389,963.80 350,087.82 39,875.98 25-Jan-21 5978782 USD 368,303.25 330,309.62 37,993.63 26-Feb-21 5987007 USD 470,871.00 376,765.60 94,105.40 02-Apr-21 5995304 USD 793,735.66 635,882.00 157,853.66 07-May-21 6003763 USD 777,468.23 622,059.00 155,409.23 08-Jun-21 6013021 USD 825,128.40 0.00 825,128.40 23-Jul-21 6027175 USD 52,588.50 0.00 52,588.50

59

60

atter Number: 021093-0000001 Invoice Number: 6030926 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: August 10, 2021 Time Detail ate Services Timekeeper Hours Value usiness Operations 1-Jul-21 Correspond with J. Delgado regarding guarantee Butterfield, Benjamin 0.20 195.00 issue. 1-Jul-21 Correspond with B. Butterfield and FTI regarding Delgado, Juan Manuel 0.80 920.00 local law guarantees. 3-Jul-21 Call with J. Delgado regarding status of Mexican Butterfield, Benjamin 0.30 292.50 filings. 3-Jul-21 Call with B. Butterfield regarding status of Delgado, Juan Manuel 0.30 345.00 Mexican filings. 2-Jul-21 Analyze impact of Mexican Civil Aviation Delgado, Juan Manuel 1.50 1,725.00 Authority's progress in obtaining FAA upgrade (1.3); correspond with Willkie regarding same (.2). 7-Jul-21 Correspond with Debtors regarding Mexican Delgado, Juan Manuel 0.40 460.00 corporate governance issues. otal: 006 Business Operations 3.50 3,937.50 ase Administration 1-Jul-21 Circulate notice of ECF filings to internal working Guido, Laura 0.30 120.00 group (.1); update case calendar (.2). 7-Jul-21 Circulate notice of ECF filings to internal working Guido, Laura 0.20 80.00 group (.1); update case calendar (.1). 3-Jul-21 Participate on weekly call with Debtors' advisors Delgado, Juan Manuel 2.30 2,645.00 regarding case status (.5); participate on call with Committee advisors regarding same (.7); correspond with internal working group regarding same (.6); participate on weekly update call with Mexican counsel (.5). 5-Jul-21 Circulate notice of ECF filings to internal working Guido, Laura 0.50 200.00 group (.1); update case calendar (.4). 0-Jul-21 Participate on weekly call with Debtors' advisors Delgado, Juan Manuel 2.00 2,300.00 regarding case status (.5); participate on follow-up call with Committee advisors (.6); correspond with internal working group regarding same (.3); participate on weekly update call with Mexican counsel (.6). 6-Jul-21 Circulate notice of ECF filings to internal working Guido, Laura 0.80 320.00 group (.1); update case calendar (.7).

61

atter Number: 021093-0000001 Invoice Number: 6030926 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: August 10, 2021 ate Services Timekeeper Hours Value 7-Jul-21 Participate on weekly update call with Committee's Delgado, Juan Manuel 3.40 3,910.00 Mexican counsel (.5); participate on weekly call with Debtors' advisors regarding case update (.7); prepare for (.4) and participate on (.6) weekly update call with Committee advisors; correspond with internal working group regarding same (.5); participate on weekly update call with Debtors' Mexican counsel (.7). otal: 007 Case Administration 9.50 9,575.00 mployment and Fee Applications 8-Jul-21 Correspond with B. Butterfield and J. Delgado Richardson Arnould, 1.10 852.50 regarding potential conflict counsel tasks (.4); Ka analyze same (.7). 9-Jul-21 Revise MoFo third interim fee application. Richardson Arnould, 2.20 1,705.00 Ka 2-Jul-21 Revise MoFo third interim fee application (6.2); Richardson Arnould, 6.30 4,882.50 correspond with B. Butterfield regarding same (.1). Ka 3-Jul-21 Revise MoFo third interim fee application. Butterfield, Benjamin 1.80 1,755.00 4-Jul-21 Review MoFo third interim fee application. Marines, Jennifer L. 1.00 1,350.00 4-Jul-21 Correspond with B. Butterfield regarding MoFo Richardson Arnould, 0.60 465.00 third interim fee application (.2); correspond with Ka Willkie and Committee chairperson regarding same (.4). 5-Jul-21 Revise MoFo interim fee application. Butterfield, Benjamin 1.20 1,170.00 5-Jul-21 Finalize exhibits for MoFo third interim fee Guido, Laura 0.70 280.00 application for filing (.2); file and coordinate service of same (.4); provide Chambers with courtesy copies of same (.1). 5-Jul-21 Finalize MoFo third interim fee application for Richardson Arnould, 1.40 1,085.00 filing (1.1); correspond with internal working group Ka regarding same (.2); coordinate filing of same (.1). 3-Jul-21 Prepare MoFo's May (.9) and June (.9) monthly fee Guido, Laura 2.20 880.00 statements; finalize, file and coordinate service of same (.4). 3-Jul-21 Review and revise MoFo's May (.6) and June (.4) Richardson Arnould, 1.30 1,007.50 fee statements; correspond with internal working Ka group regarding revisions to same (.2) and coordinate filing and service (.1). 6-Jul-21 Correspond with internal working group regarding Richardson Arnould, 0.10 77.50 MoFo monthly fee statements. Ka otal: 011 Employment and Fee Applications 19.90 15,510.00 eetings and Communications with Creditors

62

atter Number: 021093-0000001 Invoice Number: 6030926 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: August 10, 2021 ate Services Timekeeper Hours Value 7-Jul-21 Prepare for (1.4) and participate on (.9) weekly Delgado, Juan Manuel 2.30 2,645.00 Committee call regarding case status. 4-Jul-21 Prepare for (.9) and participate on (1.0) weekly Delgado, Juan Manuel 1.90 2,185.00 Committee call regarding case status. 1-Jul-21 Prepare for (1.0) and participate on (.8) weekly Delgado, Juan Manuel 1.80 2,070.00 Committee call regarding case status. 8-Jul-21 Prepare for (1.0) and participate on (.9) weekly Delgado, Juan Manuel 1.90 2,185.00 Committee call regarding case status. otal: 015 Meetings and Communications with Creditors 7.90 9,085.00 earings 7-Jul-21 Correspond with J. Delgado regarding July 8 Richardson Arnould, 0.20 155.00 hearing (.1); review notice of agenda in connection Ka with same (.1). 6-Jul-21 Correspond with internal working group regarding Richardson Arnould, 0.70 542.50 timing of hearing on interim fee application, related Ka notice and relevant interim compensation order provisions (.4); correspond with E. Jerrard (Davis Polk) regarding same (.3). otal: 024 Hearings 0.90 697.50 ime Entry Review 3-Jul-21 Review and revise April (.6) and May (.6) invoices Richardson Arnould, 1.20 930.00 for compliance with U.S. Trustee's guidelines. Ka 0-Jul-21 Correspond with B. Butterfield regarding MoFo Richardson Arnould, 0.60 465.00 May and June invoices (.2); revise same (.3); Ka correspond with J. Delgado regarding revised invoices (.1). 2-Jul-21 Correspond with J. Delgado regarding May and Richardson Arnould, 0.10 77.50 June MoFo invoices. Ka 3-Jul-21 Correspond with internal working group regarding Richardson Arnould, 0.20 155.00 MoFo's May and June invoices. Ka otal: 032 Time Entry Review 2.10 1,627.50 Current Fees 38,805.00

63

atter Number: 021093-0000001 Invoice Number: 6030926 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: August 10, 2021 Timekeeper Summary No. Timekeeper Rate Hours Value 23905 Delgado, Juan Manuel 1,150.00 18.60 21,390.00 17456 Marines, Jennifer L. 1,350.00 1.00 1,350.00 21823 Richardson Arnould, Ka 775.00 16.00 12,400.00 20018 Butterfield, Benjamin 975.00 3.50 3,412.50 13849 Guido, Laura 400.00 4.70 1,880.00 Client Accommodation - Time (1,627.50) Entry Review TOTAL 43.80 38,805.00

64

atter Number: 021093-0000001 Invoice Number: 6030926 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: August 10, 2021 Task Code Summary ask Code Description Hours Value 06 Business Operations 3.50 3,937.50 07 Case Administration 9.50 9,575.00 11 Employment and Fee Applications 19.90 15,510.00 15 Meetings and Communications with Creditors 7.90 9,085.00 24 Hearings 0.90 697.50 32 Time Entry Review 2.10 1,627.50 Client Accommodation - Time Entry Review (1,627.50) TOTAL 43.80 38,805.00

65

atter Number: 021093-0000001 Invoice Number: 6030926 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: August 10, 2021 Disbursement Detail ate Description Value 1-Jul-21 On-line Research - OTHER DATABASE 12.90 Current Disbursements 12.90

66

atter Number: 021093-0000001 Invoice Number: 6030926 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: August 10, 2021 Invoice Summary U.S.Dollar otal Fees 38,805.00 otal Disbursements 12.90 otal Amount Due 38,817.90

67

atter Number: 021093-0000001 Invoice Number: 6030926 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: August 10, 2021 or your convenience, we have listed below previous invoices on this matter which our records show as outstanding and the total alance due on this account. If you have already submitted payment, we appreciate your promptness. If your records are not in greement, or if we can provide additional assistance, please call our Billing Department at (415) 268-6446 or (866) 314-5320 Date Invoice Number Currency Original Invoice Amount Payments Applied Amount Outstandin30-Sep-20 5949491 USD 993,326.30 884,872.48 108,453.82 29-Oct-20 5956137 USD 422,657.70 381,371.12 41,286.58 30-Nov-20 5964422 USD 259,825.20 232,649.02 27,176.18 23-Dec-20 5972347 USD 389,963.80 350,087.82 39,875.98 25-Jan-21 5978782 USD 368,303.25 330,309.62 37,993.63 26-Feb-21 5987007 USD 470,871.00 376,765.60 94,105.40 02-Apr-21 5995304 USD 793,735.66 635,882.00 157,853.66 07-May-21 6003763 USD 777,468.23 622,059.00 155,409.23 08-Jun-21 6013021 USD 825,128.40 661,755.20 163,373.20 23-Jul-21 6027175 USD 52,588.50 0.00 52,588.50 23-Jul-21 6027177 USD 41,710.00 0.00 41,710.00

68

69

atter Number: 021093-0000001 Invoice Number: 6045236 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: September 27, 2021 Time Detail ate Services Timekeeper Hours Value udgeting (Case) 9-Aug-21 Revise case budget for interim period. Butterfield, Benjamin 0.30 292.50 9-Aug-21 Prepare budget (1.2); correspond with B. Richardson Arnould, 1.30 1,007.50 Butterfield regarding same (.1). Ka 0-Aug-21 Correspond with B. Butterfield regarding budget Richardson Arnould, 0.50 387.50 (.1); correspond with J. Delgado regarding same Ka (.2); draft transmittal to Committee chairperson regarding same (.2). 2-Aug-21 Correspond with J. Delgado regarding budget (.1); Richardson Arnould, 0.30 232.50 correspond with Willkie regarding same (.2). Ka 6-Aug-21 Correspond with Willkie team regarding MoFo Richardson Arnould, 0.30 232.50 budget (.1); correspond with Committee Ka chairperson regarding same (.2). 5-Aug-21 Prepare prospective budget for fifth interim fee Richardson Arnould, 0.70 542.50 period. Ka otal: 005 Budgeting (Case) 3.40 2,695.00 usiness Operations 4-Aug-21 Correspond with T. Goren (Willkie) regarding Butterfield, Benjamin 1.00 975.00 communications with Debtors in connection with marketing process (.2); analyze files regarding same (.8). otal: 006 Business Operations 1.00 975.00 ase Administration 4-Aug-21 Circulate notice of ECF filings to internal working Guido, Laura 0.30 120.00 group (.1); update case calendar (.2). 0-Aug-21 Participate on weekly call with Debtors' advisors Delgado, Juan Manuel 2.50 2,875.00 regarding case status (.7); participate on call with Committee advisors regarding same (.6); correspond with internal working group regarding same (.5); participate on call with Debtors' Mexican counsel regarding case status (.7). 0-Aug-21 Circulate notice of ECF filings to internal working Guido, Laura 0.50 200.00 group (.1); update case calendar (.4). 7-Aug-21 Participate on weekly call with Committee's Delgado, Juan Manuel 2.80 3,220.00 Mexican counsel regarding case update (.6); participate on weekly call with Debtors' advisors regarding same (.9); prepare for (.4) and participate on (.6) weekly update call with Committee advisors; attend mediation session (.3).

70

atter Number: 021093-0000001 Invoice Number: 6045236 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: September 27, 2021 ate Services Timekeeper Hours Value 7-Aug-21 Circulate notice of ECF filings to internal working Guido, Laura 0.50 200.00 group (.1); update case calendar (.4). 3-Aug-21 Prepare for (.6) and participate on (1.2) call with Delgado, Juan Manuel 2.50 2,875.00 Debtors' Mexican counsel regarding case status; participate on call with Committee's Mexican counsel regarding same (.7). 3-Aug-21 Circulate notice of ECF filings to internal working Guido, Laura 1.00 400.00 group (.1); update case calendar (.9). 4-Aug-21 Participate on weekly call with Committee's Delgado, Juan Manuel 3.70 4,255.00 Mexican counsel regarding case update (.6); prepare for (.3) and participate on (.9) weekly call with Debtors' advisors regarding same; participate on weekly update call with Committee's advisors (.8); correspond with internal working group regarding same (.6); participate on weekly update call with Debtors' Mexican counsel (.5). 8-Aug-21 Participate on call with noteholders and FTI Delgado, Juan Manuel 0.50 575.00 regarding case update. 0-Aug-21 Circulate notice of ECF filings to internal working Guido, Laura 0.50 200.00 group (.1); update case calendar (.4). 1-Aug-21 Participate on weekly call with Committee's Delgado, Juan Manuel 3.70 4,255.00 Mexican advisors regarding case update (.4); participate on weekly call with Debtor's advisors regarding same (.8); prepare for (.3) and participate on (.7) weekly call with Committee advisors regarding same; participate on call with FTI and noteholders (1.0); participate on weekly update call with Debtors' Mexican counsel (.5). otal: 007 Case Administration 18.50 19,175.00 mployment and Fee Applications 0-Aug-21 Prepare MoFo's July 2021 fee statement (.8); Guido, Laura 1.10 440.00 finalize, file and coordinate service of same (.3). 0-Aug-21 Correspond with M. Healy (FTI) regarding Richardson Arnould, 0.40 310.00 objection deadlines to May and June fee statements Ka (.2); correspond with internal working group regarding MoFo July fee statement (.2). otal: 011 Employment and Fee Applications 1.50 750.00 eetings and Communications with Creditors 4-Aug-21 Participate on weekly Committee call regarding Delgado, Juan Manuel 0.70 805.00 case status. 1-Aug-21 Prepare for (.2) and participate on (.6) weekly Delgado, Juan Manuel 0.80 920.00 Committee call regarding case status. 8-Aug-21 Participate on weekly Committee call regarding Delgado, Juan Manuel 0.70 805.00 case status.

71

atter Number: 021093-0000001 Invoice Number: 6045236 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: September 27, 2021 ate Services Timekeeper Hours Value otal: 015 Meetings and Communications with Creditors 2.20 2,530.00 lan and Disclosure Statement 0-Aug-21 Participate on call regarding plan exclusivity. Delgado, Juan Manuel 0.50 575.00 otal: 017 Plan and Disclosure Statement 0.50 575.00 earings 2-Aug-21 Correspond with E. Jerrard (Davis Polk) regarding Richardson Arnould, 0.10 77.50 upcoming hearings. Ka 5-Aug-21 Review notice of September 20 hearing. Richardson Arnould, 0.10 77.50 Ka 6-Aug-21 Correspond with E. Jerrard (Davis Polk) regarding Richardson Arnould, 0.30 232.50 hearing on interim fee applications (.1); review Ka notice in connection with same (.1); correspond with internal working group regarding same (.1). 8-Aug-21 Correspond with J. Delgado and B. Butterfield Richardson Arnould, 0.30 232.50 regarding August 18 hearing (.2); review agenda in Ka connection with same (.1). 4-Aug-21 Correspond with B. Butterfield regarding upcoming Richardson Arnould, 0.10 77.50 hearing in connection with final approval of DAE Ka motion. otal: 024 Hearings 0.90 697.50 ime Entry Review 6-Aug-21 Review and revise MoFo July invoice for Richardson Arnould, 0.50 387.50 compliance with U.S. Trustee's guidelines (.4); Ka correspond with internal working group regarding same (.1). 9-Aug-21 Review revised MoFo July invoice (.3); correspond Richardson Arnould, 0.80 620.00 with B. Butterfield regarding same (.3); correspond Ka with J. Delgado regarding same (.2). 0-Aug-21 Correspond with J. Delgado and B. Butterfield Richardson Arnould, 0.40 310.00 regarding revisions to MoFo July invoice (.3); Ka revise same (.1). otal: 032 Time Entry Review 1.70 1,317.50 Current Fees 27,397.50

72

atter Number: 021093-0000001 Invoice Number: 6045236 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: September 27, 2021 Timekeeper Summary No. Timekeeper Rate Hours Value 23905 Delgado, Juan Manuel 1,150.00 18.40 21,160.00 21823 Richardson Arnould, Ka 775.00 6.10 4,727.50 20018 Butterfield, Benjamin 975.00 1.30 1,267.50 13849 Guido, Laura 400.00 3.90 1,560.00 Client Accommodation - Time (1,317.50) Entry Review TOTAL 29.70 27,397.50

73

atter Number: 021093-0000001 Invoice Number: 6045236 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: September 27, 2021 Task Code Summary ask Code Description Hours Value 05 Budgeting (Case) 3.40 2,695.00 06 Business Operations 1.00 975.00 07 Case Administration 18.50 19,175.00 11 Employment and Fee Applications 1.50 750.00 15 Meetings and Communications with Creditors 2.20 2,530.00 17 Plan and Disclosure Statement 0.50 575.00 24 Hearings 0.90 697.50 32 Time Entry Review 1.70 1,317.50 Client Accommodation - Time Entry Review (1,317.50) TOTAL 29.70 27,397.50

74

atter Number: 021093-0000001 Invoice Number: 6045236 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: September 27, 2021 Disbursement Detail ate Description Value 1-Aug-21 On-line Research - OTHER DATABASE 13.70 3-Aug-21 Miscellaneous, B. Butterfield, Internet service on plane 11.00 Current Disbursements 24.70

75

atter Number: 021093-0000001 Invoice Number: 6045236 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: September 27, 2021 Invoice Summary U.S.Dollar otal Fees 27,397.50 otal Disbursements 24.70 otal Amount Due 27,422.20

76

atter Number: 021093-0000001 Invoice Number: 6045236 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: September 27, 2021 or your convenience, we have listed below previous invoices on this matter that remain outstanding at this time according to our ecords. If you have already submitted payment, we appreciate your promptness. Should you note any discrepancies or if we can rovide additional assistance, please call our Client Accounting team at (415) 268-6446 or (866) 314-5320. Date Invoice Number Currency Original Invoice Amount Payments Applied Amount Outstandin30-Sep-20 5949491 USD 993,326.30 884,872.48 108,453.82 29-Oct-20 5956137 USD 422,657.70 381,371.12 41,286.58 30-Nov-20 5964422 USD 259,825.20 232,649.02 27,176.18 23-Dec-20 5972347 USD 389,963.80 350,087.82 39,875.98 25-Jan-21 5978782 USD 368,303.25 330,309.62 37,993.63 26-Feb-21 5987007 USD 470,871.00 376,765.60 94,105.40 02-Apr-21 5995304 USD 793,735.66 635,882.00 157,853.66 07-May-21 6003763 USD 777,468.23 622,059.00 155,409.23 08-Jun-21 6013021 USD 825,128.40 661,755.20 163,373.20 23-Jul-21 6027175 USD 52,588.50 42,072.00 10,516.50 23-Jul-21 6027177 USD 41,710.00 33,410.00 8,300.00 10-Aug-21 6030926 USD 38,817.90 0.00 38,817.90

77

78

atter Number: 021093-0000001 Invoice Number: 6048985 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: October 11, 2021 Time Detail ate Services Timekeeper Hours Value udgeting (Case) 9-Sep-21 Revise budget for fifth interim fee period (.4); Richardson Arnould, 0.60 465.00 correspond with B. Butterfield regarding further Ka revisions to same (.2). 3-Sep-21 Further revise budget (.2); correspond with B. Richardson Arnould, 0.30 232.50 Butterfield regarding same (.1). Ka 4-Sep-21 Further revise budget (.4); correspond with B. Richardson Arnould, 0.60 465.00 Butterfield regarding same (.2). Ka 0-Sep-21 Finalize budget (.6); correspond with J. Delgado Richardson Arnould, 0.70 542.50 regarding same (.1). Ka 7-Sep-21 Correspond with J. Delgado (.1) and Willkie (.1) Richardson Arnould, 0.20 155.00 regarding budget for fifth interim fee period. Ka 8-Sep-21 Correspond with internal working group (.1) and Richardson Arnould, 0.30 232.50 Committee chairperson (.2) regarding budget for Ka fifth interim fee period. otal: 005 Budgeting (Case) 2.70 2,092.50 ase Administration 7-Sep-21 Participate on weekly call with Committee's Delgado, Juan Manuel 3.20 3,680.00 Mexican counsel regarding case status (.4); prepare for (.2) and participate on (.6) weekly call with Debtors' advisors regarding same; prepare for (.3) and participate on (.5) call with Committee advisors regarding same; correspond with internal working group regarding case update (.3); participate on update call with Debtors' Mexican advisors (.7); correspond with internal working group regarding Delta and Mexican shareholder issues (.2). 7-Sep-21 Circulate notice of ECF filings to internal working Guido, Laura 0.60 240.00 group (.1); update case calendar (.5). 3-Sep-21 Circulate notice of ECF filings to internal working Guido, Laura 0.40 160.00 group (.1); update case calendar (.3). 4-Sep-21 Participate on weekly call with Committee's Delgado, Juan Manuel 2.40 2,760.00 Mexican counsel regarding case status (.4); prepare for (.2) and participate on (.4) weekly call with Debtors' advisors regarding same; prepare for (.3) and participate on (.3) weekly call with Committee advisors regarding same; correspond with internal working group regarding case update (.4); participate on weekly update call with Debtors' Mexican counsel (.4).

79

atter Number: 021093-0000001 Invoice Number: 6048985 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: October 11, 2021 ate Services Timekeeper Hours Value 0-Sep-21 Circulate notice of ECF filings to internal working Guido, Laura 0.60 240.00 group (.1); update case calendar (.5). 1-Sep-21 Participate on weekly call with Committee's Delgado, Juan Manuel 2.70 3,105.00 Mexican counsel regarding case status (.3); prepare for (.2) and participate on (.6) weekly call with Debtors' advisors regarding same; prepare for (.4) and participate on (.6) weekly call with Committee's advisors regarding same; correspond with internal working group regarding same (.3); participate on weekly update call with Mexican counsel (.3). 8-Sep-21 Participate on weekly call with Committee's Delgado, Juan Manuel 2.20 2,530.00 Mexican counsel regarding case status (.5); prepare for (.4) and participate on (.5) weekly call with Debtors' advisors regarding same; participate on weekly call with Committee's advisors regarding same (.5); correspond with internal working group regarding same (.3). 0-Sep-21 Circulate notice of ECF filings to internal working Guido, Laura 0.60 240.00 group (.1); update case calendar (.5). otal: 007 Case Administration 12.70 12,955.00 mployment and Fee Applications 7-Sep-21 Prepare MoFo's August fee statement. Guido, Laura 0.80 320.00 7-Sep-21 Correspond with M. Healy (FTI) regarding July fee Richardson Arnould, 0.10 77.50 statement. Ka 8-Sep-21 Finalize, file and coordinate service of MoFo's Guido, Laura 0.30 120.00 August fee statement. otal: 011 Employment and Fee Applications 1.20 517.50 eetings and Communications with Creditors 1-Sep-21 Prepare for (.3) and participate on (.6) weekly Delgado, Juan Manuel 0.90 1,035.00 Committee call regarding case update. 5-Sep-21 Prepare for (.8) and participate on (1.2) weekly Delgado, Juan Manuel 2.00 2,300.00 Committee call regarding case status. 2-Sep-21 Prepare for (.3) and participate on (.5) weekly Delgado, Juan Manuel 0.80 920.00 Committee call regarding case update. 9-Sep-21 Prepare for (.3) and participate on (.6) weekly Delgado, Juan Manuel 0.90 1,035.00 Committee call regarding case update. otal: 015 Meetings and Communications with Creditors 4.60 5,290.00 earings

80

atter Number: 021093-0000001 Invoice Number: 6048985 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: October 11, 2021 ate Services Timekeeper Hours Value 5-Sep-21 Correspond with J. Delgado and B. Butterfield Richardson Arnould, 0.30 232.50 regarding proposed adjournment of hearing on Ka interim fee applications (.2); correspond with E. Jerrard (Davis Polk) regarding same (.1). 7-Sep-21 Coordinate October 1 telephonic hearing Guido, Laura 0.20 80.00 appearances (.1); compile materials for same (.1). 7-Sep-21 Correspond with internal working group regarding Richardson Arnould, 0.30 232.50 upcoming interim fee hearing. Ka 0-Sep-21 Review notices of cancellation of hearing and new Richardson Arnould, 0.40 310.00 omnibus hearing date (.1); correspond with E. Ka Jerrard (Davis Polk) regarding same and anticipated timing of hearings concerning interim fee applications (.2); correspond with internal working group regarding cancellation of hearing and next steps (.1). otal: 024 Hearings 1.20 855.00 ime Entry Review 3-Sep-21 Correspond with internal working group regarding Richardson Arnould, 0.20 155.00 August time detail. Ka 3-Sep-21 Correspond with internal working group regarding Richardson Arnould, 0.10 77.50 August invoice. Ka 4-Sep-21 Analyze August time entries for compliance with Richardson Arnould, 0.80 620.00 U.S. Trustee's guidelines (.6); correspond with Ka internal working group regarding same (.2). 5-Sep-21 Review August time entries for compliance with Richardson Arnould, 0.90 697.50 U.S. Trustee's guidelines (.6); correspond with B. Ka Butterfield regarding same (.3). 0-Sep-21 Review revised August invoice (.1); correspond Richardson Arnould, 0.20 155.00 with J. Delgado regarding same (.1). Ka 7-Sep-21 Correspond with J. Delgado and internal working Richardson Arnould, 0.20 155.00 group regarding August invoice. Ka otal: 032 Time Entry Review 2.40 1,860.00 Current Fees 21,710.00

81

atter Number: 021093-0000001 Invoice Number: 6048985 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: October 11, 2021 Timekeeper Summary No. Timekeeper Rate Hours Value 23905 Delgado, Juan Manuel 1,150.00 15.10 17,365.00 21823 Richardson Arnould, Ka 775.00 6.20 4,805.00 13849 Guido, Laura 400.00 3.50 1,400.00 Client Accommodation - Time (1,860.00) Entry Review TOTAL 24.80 21,710.00

82

atter Number: 021093-0000001 Invoice Number: 6048985 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: October 11, 2021 Task Code Summary ask Code Description Hours Value 05 Budgeting (Case) 2.70 2,092.50 07 Case Administration 12.70 12,955.00 11 Employment and Fee Applications 1.20 517.50 15 Meetings and Communications with Creditors 4.60 5,290.00 24 Hearings 1.20 855.00 32 Time Entry Review 2.40 1,860.00 Client Accommodation - Time Entry Review (1,860.00) TOTAL 24.80 21,710.00

83

atter Number: 021093-0000001 Invoice Number: 6048985 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: October 11, 2021 Disbursement Detail ate Description Value 0-Sep-21 On-line Research - OTHER DATABASE 11.90 Current Disbursements 11.90

84

atter Number: 021093-0000001 Invoice Number: 6048985 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: October 11, 2021 Invoice Summary U.S.Dollar otal Fees 21,710.00 otal Disbursements 11.90 otal Amount Due 21,721.90

85

atter Number: 021093-0000001 Invoice Number: 6048985 atter Name: BANKRUPTCY OF GRUPO AEROMEXICO Invoice Date: October 11, 2021 or your convenience, we have listed below previous invoices on this matter that remain outstanding at this time according to our ecords. If you have already submitted payment, we appreciate your promptness. Should you note any discrepancies or if we can rovide additional assistance, please call our Client Accounting team at (415) 268-6446 or (866) 314-5320. Date Invoice Number Currency Original Invoice Amount Payments Applied Amount Outstandin30-Sep-20 5949491 USD 993,326.30 884,872.48 108,453.82 29-Oct-20 5956137 USD 422,657.70 381,371.12 41,286.58 30-Nov-20 5964422 USD 259,825.20 232,649.02 27,176.18 23-Dec-20 5972347 USD 389,963.80 350,087.82 39,875.98 25-Jan-21 5978782 USD 368,303.25 330,309.62 37,993.63 26-Feb-21 5987007 USD 470,871.00 376,765.60 94,105.40 02-Apr-21 5995304 USD 793,735.66 635,882.00 157,853.66 07-May-21 6003763 USD 777,468.23 622,059.00 155,409.23 08-Jun-21 6013021 USD 825,128.40 661,755.20 163,373.20 23-Jul-21 6027175 USD 52,588.50 42,072.00 10,516.50 23-Jul-21 6027177 USD 41,710.00 33,410.00 8,300.00 10-Aug-21 6030926 USD 38,817.90 31,057.00 7,760.90 27-Sep-21 6045236 USD 27,422.20 0.00 27,422.20

86