20-11254-jlg Doc 3674 Filed 11/29/21 Entered 11/29/21 18:53:53 Main Document

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UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF NEW YORK
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In re:
: Chapter 11
LATAM AIRLINES GROUP S.A., et al., Case No. 20-11254 (JLG)
(Jointly Administered)
Debtors. :
Related Docket Nos.: 3060, 3457

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SECOND NOTICE OF MEDIATOR

1. By order of the Court entered August 31, 2021 (the “Order”), the undersigned was

appointed mediator (“Mediator”) to conduct a mediation in the above-captioned cases. The

Order contemplated that the mediation would initially concern (a) motions filed by the Official

Committee of Unsecured Creditors (the “Committee”) to obtain standing to bring alleged causes

of action against Delta Air Lines, Inc. (“Delta”) and Qatar Airways Q.C.S.C. (“Qatar) and the

defendants’ responses thereto (the “Standing Motions”); (b) “other shareholder matters that were

raised at the July 30, 2021 hearing, if and when the Designated Parties (defined below) agree that

such issues are ripe for mediation or as directed by the Court”; and (c) “such other matters as the

Designated Parties (defined below) may agree upon or the Court may direct.” (Order, para. 1)

2. The term Designated Parties was defined as (a) the Debtors; (b) the Committee; and

some or all of the following parties as applicable: (c) Delta; (d) Qatar; (e) the Parent Ad Hoc

Claimant Group represented by Kramer Levin Naftalis & Frankel LLP (the “Kramer Levin

Group”); (f) the Ad Hoc Group of LATAM Creditors represented by White & Case LLP (the

“White & Case Group”); and (g) Costa Verde Aeronautica S.A. (“Costa Verde”). (Order, para.

2) It was also provided that Banco del Estado, as trustee for the Chilean Law Bonds Series A-E
20-11254-jlg Doc 3674 Filed 11/29/21 Entered 11/29/21 18:53:53 Main Document
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