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Full title: Declaration of Jane Sullivan on Behalf of Epiq Corporate Restructuring, LLC Regarding Voting and Tabulation of Ballots Cast on the Debtors Joint Plan of Reorganization under Chapter 11 of the Bankruptcy Code (related document(s)[2293]) filed by Timothy E. Graulich on behalf of Grupo Aeromexico, S.A.B. de C.V.. (Graulich, Timothy)

Document posted on Jan 10, 2022 in the bankruptcy, 8 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

In accordance with (i) the Order Authorizing Debtors to Retain and Employ Epiq Corporate Restructuring, LLC as Administrative Agent Nunc Pro Tunc to the Commencement Date, dated November 10, 2020 [ECF No. 626] and (ii) the Order Approving the (I)(the “Disclosure Statement Order”), Epiq was appointed and authorized to assist the Debtors with, inter alia, soliciting, receiving, reviewing, determining the validity of, and tabulating Ballots cast on the Plan by holders of Claims in Voting Classes (as defined below).As specified in the Disclosure Statement Order, November 30, 2021 was established as the record date for determining the holders of Claims in the Voting Classes who would be entitled to vote on the Plan (the “Voting Record Date”).For a Ballot to be counted as valid, the Ballot must have been properly completed in accordance with the procedures set forth in the Disclosure Statement Order and executed by the relevant holder, or such holder’s authorized representative, and must have been received by Epiq no later than 4:00 p.m. (prevailing Eastern Time) on January 7, 2022 (the “Voting Deadline”).All validly executed Ballots cast by holders of Claims in the Voting Classes received by Epiq on or before the Voting Deadline were tabulated as outlined in the Disclosure Statement Order.

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UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK In re: Chapter 11 GRUPO AEROMÉXICO, S.A.B. de C.V., et Case No. 20-11563 (SCC) al., Debtors.1 (Jointly Administered) DECLARATION OF JANE SULLIVAN ON BEHALF OF EPIQ CORPORATE RESTRUCTURING, LLC REGARDING VOTING AND TABULATION OF BALLOTS CAST ON THE DEBTORS’ JOINT PLAN OF REORGANIZATION UNDER CHAPTER 11 OF THE BANKRUPTCY CODE I, Jane Sullivan, declare, under penalty of perjury: 1. I am Executive Vice President of Epiq Corporate Restructuring, LLC (“Epiq”) located at 777 Third Avenue, 12th Floor, New York, New York 10017. I am over the age of 18 years. I do not have a direct interest in these chapter 11 cases and should be considered an impartial party. 2. I submit this Declaration with respect to the Debtors' Joint Plan of Reorganization under Chapter 11 of the Bankruptcy Code, dated December 10, 2021 [ECF No. 2293] (as amended, supplemented, or modified from time to time, the “Plan”).2 Except as otherwise indicated herein, all facts set forth herein are based upon my personal knowledge or my review of relevant documents. I am authorized to submit this Declaration on behalf of Epiq. If I were called upon to testify, I could and would testify competently as to the facts set forth herein. 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.; Aerovías de México, S.A. de C.V. 108984; Aerolitoral, S.A. de C.V. 217315; Aerovías Empresa de Cargo, S.A. de C.V. 437094-1. The Debtors’ corporate headquarters is located at Paseo de la Reforma No. 243, piso 25 Colonia Cuauhtémoc, Mexico City, C.P. 06500. 2 Capitalized terms used but not otherwise defined herein shall have the meanings set forth in the Plan and the Disclosure Statement Order (as defined below).

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3. In accordance with (i) the Order Authorizing Debtors to Retain and Employ Epiq Corporate Restructuring, LLC as Administrative Agent Nunc Pro Tunc to the Commencement Date, dated November 10, 2020 [ECF No. 626] and (ii) the Order Approving the (I) Shortened Notice and Objection Periods for Debtors Disclosure Statement Motion, (II) Adequacy of Information in the Disclosure Statement, (III) Solicitation and Voting Procedures, (IV) Forms of Ballots, Notices and Notice Procedures in Connection Therewith and (V) Certain Dates with Respect Thereto, dated December 10, 2021 [ECF No. 2292] (the “Disclosure Statement Order”), Epiq was appointed and authorized to assist the Debtors with, inter alia, soliciting, receiving, reviewing, determining the validity of, and tabulating Ballots cast on the Plan by holders of Claims in Voting Classes (as defined below). 4. Pursuant to the Plan, the following Classes (collectively, the “Voting Classes”) were entitled to vote to accept or reject the Plan.
Table 1 on page 2. Back to List of Tables
Class Description
Class 3(a) Aerovías and Grupo Aeroméxico Recourse Claims
Class 3(b) General Unsecured Claims against Grupo Aeroméxico
Class 3(c) General Unsecured Claims against Aerovías
Class 3(d) General Unsecured Claims against Aeroméxico Connect
Class 3(e) General Unsecured Claims against Aeroméxico Cargo
Class 4(b) Unsecured Convenience Class Claims against Aerovías
Class 4(c) Unsecured Convenience Class Claims against Aeroméxico Connect
Class 4(d) Unsecured Convenience Class Claims against Aeroméxico Cargo
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5. As specified in the Disclosure Statement Order, November 30, 2021 was established as the record date for determining the holders of Claims in the Voting Classes who would be entitled to vote on the Plan (the “Voting Record Date”). 6. The procedures for the solicitation and tabulation of votes on the Plan are outlined in the Disclosure Statement Order. In accordance with the Disclosure Statement Order, Epiq solicited, reviewed, determined the validity of, and tabulated Ballots submitted by holders of Claims in the Voting Classes as of the Voting Record Date. Epiq’s Affidavit of Service of Solicitation Materials was filed with this Court on January 7, 2022 [ECF No. 2435]. 7. All Ballots received by Epiq were date-stamped upon receipt and were processed in accordance with the procedures set forth in the Disclosure Statement Order. 8. For a Ballot to be counted as valid, the Ballot must have been properly completed in accordance with the procedures set forth in the Disclosure Statement Order and executed by the relevant holder, or such holder’s authorized representative, and must have been received by Epiq no later than 4:00 p.m. (prevailing Eastern Time) on January 7, 2022 (the “Voting Deadline”). 9. All validly executed Ballots cast by holders of Claims in the Voting Classes received by Epiq on or before the Voting Deadline were tabulated as outlined in the Disclosure Statement Order. I declare that the results of the tabulation of votes cast by holders of Claims in the Voting Classes are as set forth in Exhibit A hereto, which is a true and correct copy of the final tabulation of votes cast by timely and properly executed Ballots received by Epiq. 10. A report of all votes received but not included in the tabulation prepared by Epiq, and the reasons for such exclusion, is attached as Exhibit B hereto. [Remainder of page intentionally left blank.] 3

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I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information, and belief. DATED: January 11, 2022 New York, New York /s/ Jane Sullivan Jane Sullivan Executive Vice President Epiq Corporate Restructuring, LLC 4

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EXHIBIT A

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EXHIBIT A Tabulation Summary
Table 1 on page 6. Back to List of Tables
VOTING CLASS ACCEPT None REJECT None Class
Voting
Result
None AMOUNT
(%)
NUMBER
(%)
AMOUNT
(%)
NUMBER
(%)
None
Class 3(a)
AEROVÍAS AND GRUPO
AEROMÉXICO
RECOURSE CLAIMS
$603,814,000.00
(98.86%)
96
(98.97%)
$6,965,000.00
(1.14%)
1
(1.03%)
Accepts
Class 3(b)
GENERAL UNSECURED
CLAIMS AGAINST
GRUPO AEROMÉXICO
$61,605,856.04
(100.00%)
22
(100.00%)
$0.00
(0.00%)
0
(0.00%)
Accepts
Class 3(c)
GENERAL UNSECURED
CLAIMS AGAINST
AEROVÍAS
$1,425,790,789.80
(83.65%)
93
(80.87%)
$278,727,562.66
(16.35%)
22
(19.13%)
Accepts
Class 3(d)
GENERAL UNSECURED
CLAIMS AGAINST
AEROMÉXICO CONNECT
$204,334,789.83
(67.75%)
20
(62.50%)
$97,248,263.67
(32.25%)
12
(37.5%)
Accepts
Class 3(e)
GENERAL UNSECURED
CLAIMS AGAINST
AEROMÉXICO CARGO
$0.00
(0.00%)
0
(0.00%)
$1,110,000.00
(100.00%)
3
(100.00%)
Rejects1
Class 4(b)
UNSECURED CONVEN-
IENCE CLASS CLAIMS
AGAINST AEROVÍAS
$6,445,938.53
(87.18%)
105
(86.07%)
$947,861.84
(12.82%)
17
(13.93%)
Accepts
Class 4(c)
UNSECURED CONVEN-
IENCE CLASS CLAIMS
AGAINST AEROMÉXICO
CONNECT
$933,939.40
(86.22%)
29
(85.29%)
$149,288.40
(13.78%)
5
(14.71%)
Accepts
Class 4(d)
UNSECURED CONVEN-
IENCE CLASS CLAIMS
AGAINST AEROMÉXICO
CARGO
$74,022.93
(80.04%)
5
(83.33%)
$18,457.59
(19.96%)
1
(16.67%)
Accepts
1 Epiq understands that the voting result in Class 3(e) is subject to the Debtors’ Motion to Enforce the Court’s Order Authorizing Entry Into New Agreements Establishing New Labor Conditions with ASPA, ASSA, STIA, and Independencia [ECF No. 2356].

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EXHIBIT B

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EXHIBIT B Votes Not Included in Tabulation
Table 1 on page 8. Back to List of Tables
Plan Class Claim Name Voting Amount Vote Reason for Exclusion
4B B/E AEROSPACE UK LIMITED $196,000.00 ACCEPT CLAIM SUBJECT TO A PENDING DISALLOW
OBJECTION
3D BEAUTECH POWER SYSTEMS LLC $932,364.78 ACCEPT CLAIM WITHDRAWN PER SETTLEMENT
AGREEMENT MOTION
4B CHROMA SYSTEMS SOLUTIONS INC $2,203.72 NO VOTE: BALLOT DID NOT INDICATE A VOTE TO
ACCEPT OR TO REJECT THE PLAN
4D CONTRERAS CARO SILVA IMELDA LUCIANA $2,389.14 ACCEPT BALLOT SUBMITTED BY EMAIL
4B COURTYARD MANAGEMENT CORP, AS MANAGER $3,423.68 NO VOTE: BALLOT DID NOT INDICATE A VOTE TO
ACCEPT OR TO REJECT THE PLAN
3C ENTSERV ENTERPRISE SERV MEXICO SDERLDECV $3,011,628.60 ACCEPT CLAIM SUBJECT TO A PENDING DISALLOW
OBJECTION
4B GUZMAN, LOBSANG MATA $25,560.99 ACCEPT CLAIM SUBJECT TO A PENDING DISALLOW
OBJECTION
4C GUZMAN, LOBSANG MATA $23,096.41 ACCEPT CLAIM SUBJECT TO A PENDING DISALLOW
OBJECTION
4B LUXURY HOTELS INTL OF CANADA ULC $39,482.00 NO VOTE: BALLOT DID NOT INDICATE A VOTE TO
ACCEPT OR TO REJECT THE PLAN
4B MARRIOTT HOTEL SERVICES INC $122,103.59 NO VOTE: BALLOT DID NOT INDICATE A VOTE TO
ACCEPT OR TO REJECT THE PLAN
4B MARRIOTT HOTEL SERVICES INC, AS MANAGER $40,369.06 NO VOTE: BALLOT DID NOT INDICATE A VOTE TO
ACCEPT OR TO REJECT THE PLAN
4B MERINO AEROSPACE FINANCE 36707 LIMITED $52,296.45 ACCEPT CLAIM WITHDRAWN PER SETTLEMENT
AGREEMENT MOTION

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