HTML Document View

Full title: Statement / VERIFIED STATEMENT PURSUANT TO BANKRUPTCY RULE 2019 filed by Steven J. Reisman on behalf of Ad Hoc Group of OpCo Creditors. (Reisman, Steven)

Document posted on Nov 25, 2021 in the bankruptcy, 4 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

Porter Kaye Scholer LLP (“A&P”) hereby make the following verified statement (this “Verified Statement”), pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), in connection with Katten and A&P’s representation in these chapter 11 cases of Invictus Global Management, LLC (“Invictus”), Corvid Peak Capital Management LLC (“Corvid Peak”), Hain Capital Group, 1LLC (“Hain Capital”), and Livello Capital Management LP (“Livello” and, together with Invictus, Corvid Peak, and Hain Capital, the “Ad Hoc Group of OpCo Creditors” or “Ad Hoc Group”): 1. Members of the Ad Hoc Group of OpCo Creditors have indicated to Katten and A&P that they beneficially own disclosable economic interests, or act as investment managers or advisors to funds or accounts that beneficially own disclosable economic interests, in relation to the Debtors. In accordance with Bankruptcy Rule 2019 and based upon information provided to Katten and A&P by each of the members of the Ad Hoc Group, attached hereto as Exhibit A is a list of the names, addresses, nature and amount of all disclosable economic interests of each of the Ad Hoc Group members in relation to the Debtors. Each entity on this Exhibit A is listed either in its principal capacity or in its capacity as agent, investment advisor, or investment manager for certain investment funds or accounts or their respective subsidiaries that hold disclosable economic interests in relation to the Debtors.

List of Tables

Document Contents

Steven J. Reisman, Esq. Jonathan I. Levine, Esq. Cindi M. Giglio, Esq. Maja Zerjal Fink, Esq. David A. Crichlow, Esq. Lucas B. Barrett, Esq. Michael E. Comerford, Esq. KATTEN MUCHIN ROSENMAN LLP ARNOLD & PORTER KAYE SCHOLER LLP 575 Madison Avenue 250 West 55th Street New York, NY 10022 New York, NY 10019 Telephone: (212) 940-8800 Telephone: (212) 836-8000 Facsimile: (212) 940-8776 Facsimile: (212) 836-8689 sreisman@katten.com maja.zerjalfink@arnoldporter.com cgiglio@katten.com jonathan.levine@arnoldporter.com david.crichlow@katten.com lucas.barrett@arnoldporter.com michael.comerford@katten.com Co-Counsel to the Ad Hoc Group of OpCo Creditors UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK ) In re ) Chapter 11 ) GRUPO AEROMÉXICO, S.A.B. de C.V., et al.,1 ) Case No. 20-11563 (SCC) ) Debtors. ) (Jointly Administered) ) VERIFIED STATEMENT PURSUANT TO BANKRUPTCY RULE 2019 Katten Muchin Rosenman LLP (“Katten”) and Arnold & Porter Kaye Scholer LLP (“A&P”) hereby make the following verified statement (this “Verified Statement”), pursuant to Rule 2019 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”), in connection with Katten and A&P’s representation in these chapter 11 cases of Invictus Global Management, LLC (“Invictus”), Corvid Peak Capital Management LLC (“Corvid Peak”), Hain Capital Group, 1 The Debtors in these chapter 11 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

LLC (“Hain Capital”), and Livello Capital Management LP (“Livello” and, together with Invictus, Corvid Peak, and Hain Capital, the “Ad Hoc Group of OpCo Creditors” or “Ad Hoc Group”): 1. The Ad Hoc Group has retained Katten and A&P as co-counsel in connection with the chapter 11 cases of Grupo Aeroméxico, S.A.B. de C.V. and its affiliated debtors and debtors in possession (the “Debtors”). 2. As of the date of this Verified Statement, Katten and A&P represent the Ad Hoc Group and do not represent or purport to represent any entities other than the Ad Hoc Group in connection with the Debtors’ chapter 11 cases. In addition, neither Invictus, Corvid Peak, Hain Capital, nor Livello represent or purport to represent any other entities within the Debtors’ chapter 11 cases. 3. Members of the Ad Hoc Group of OpCo Creditors have indicated to Katten and A&P that they beneficially own disclosable economic interests, or act as investment managers or advisors to funds or accounts that beneficially own disclosable economic interests, in relation to the Debtors. In accordance with Bankruptcy Rule 2019 and based upon information provided to Katten and A&P by each of the members of the Ad Hoc Group, attached hereto as Exhibit A is a list of the names, addresses, nature and amount of all disclosable economic interests of each of the Ad Hoc Group members in relation to the Debtors. 4. Nothing contained in this Verified Statement (or Exhibit A hereto) should be construed as a limitation upon, or waiver of, any rights of Invictus, Corvid Peak, Hain Capital, or Livello to assert, file, and/or amend any claim or proof of claim filed in accordance with applicable law and any orders entered in these cases. 5. The information herein is provided only for the purpose of complying with Bankruptcy Rule 2019 and is not intended for any other use or purpose.

2

6. Katten and A&P reserve the right to amend this Verified Statement as may be necessary in accordance with the requirements set forth in Bankruptcy Rule 2019. 7. The undersigned hereby verifies that this Verified Statement is true and accurate to the best of the undersigned’s knowledge and belief. Dated: November 26, 2021 /s/ Steven J. Reisman New York, NY Steven J. Reisman, Esq. Cindi M. Giglio, Esq. David A. Crichlow, Esq. Michael E. Comerford, Esq. KATTEN MUCHIN ROSENMAN LLP 575 Madison Avenue New York, NY 10022 Telephone: (212) 940-8800 Facsimile: (212) 940-8776 Email: sreisman@katten.com cgiglio@katten.com david.crichlow@katten.com michael.comerford@katten.com - and - Jonathan I. Levine, Esq. Maja Zerjal Fink, Esq. Lucas B. Barrett, Esq. ARNOLD & PORTER KAYE SCHOLER LLP 250 West 55th Street New York, NY 10019 Telephone: (212) 836-8000 Facsimile: (212) 836-8689 Email: maja.zerjalfink@arnoldporter.com jonathan.levine@arnoldporter.com lucas.barrett@arnoldporter.com Co-Counsel to the Ad Hoc Group of OpCo Creditors

3

Exhibit A2
Table 1 on page 4. Back to List of Tables
Name3 Address Aggregate Principal Amounts of Claims None None
None None General
Unsecured
Claims against
Aerovías4
General
Unsecured
Claims against
Aerolitoral5
7.00% Senior
Notes6
Invictus Global
Management, LLC
310 Comal Street
Building A, Suite 229
Austin, TX 78702
$48,537,744.21
Corvid Peak Capital
Management LLC
299 Park Avenue
13th Floor
New York, NY 10171
$46,375,364.42 $6,960,000.00
Hain Capital Group,
LLC
Meadows Office
Complex
301 Route 17, 7th Floor
Rutherford, NJ 07070
$15,737,906.45 $14,219.10
Livello Capital
Management LP
1 World Trade Center
85th Floor
New York, NY 10007
$12,796,333.00 $2,600,000.00
2 To the best of Katten and A&P’s knowledge, the information herein is accurate as of November 24, 2021. The amounts set forth herein include only the outstanding principal amounts of the applicable debt and do not include accrued and unpaid interest, fees, or other amounts that may be owing under the applicable documents. 3 Each entity on this Exhibit A is listed either in its principal capacity or in its capacity as agent, investment advisor, or investment manager for certain investment funds or accounts or their respective subsidiaries that hold disclosable economic interests in relation to the Debtors. 4 Class 3(c) general unsecured claims against Aerovías de México, S.A. de C.V. as defined in the Debtors’ Joint Plan Of Reorganization Under Chapter 11 of the Bankruptcy Code [Docket No. 1898]. 5 Class 3(d) general unsecured claims against Aeroméxico Connect (i.e., Aerolitoral, S.A. de C.V.) as defined in the Debtors’ Joint Plan Of Reorganization Under Chapter 11 of the Bankruptcy Code [Docket No. 1898]. 6 7.000% Senior Notes due in 2025 issued by Aerovías and guaranteed by Grupo Aeroméxico pursuant to the Senior Notes Indenture as defined in the Debtors’ Joint Plan Of Reorganization Under Chapter 11 of the Bankruptcy Code [Docket No. 1898].

4