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LEE, BROCK, CAMARGO ADVOGADOS

Rua Dr. Renato Paes de Barros, 618, 1/3/5 floors

04530-000 - São Paulo, SP, Brazil,

E-mail: [email protected]

Solano de Camargo

Local Brazilian Litigation Counsel to the Debtors

UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF NEW YORK

Chapter 11 In re:

Case No.: 20-11254 (JLG)

LATAM Airlines Group S.A., et al.,

Jointly Administered

Debtors.

1 SUPPLEMENTAL DECLARATION OF SOLANO DE CAMARGO PURSUANT TO

(I) ORDER APPROVING AND AUTHORIZING RETENTION OF

LEE, BROCK, CAMARGO ADVOGADOS AND (II) BANKRUPTCY RULE 2014

I, Solano de Camargo, pursuant to 28 U.S.C. § 1746, hereby declare

that the following is true to the best of my knowledge, information, and belief:

1. I am a founding partner of the firm Lee, Brock, Camargo

Advogados (“LBCA” or the “Firm”), which maintains offices at Rua Dr. Renato Paes de

Barros, 618, Sao Paulo, SP, Brazil, 04530-000 (previously at Rua Tenente Negrã, 166, Sao

1 _{The Debtors in these Chapter 11 Cases, along with each Debtor’s U.S. or local tax identification}

number (as applicable), are: LATAM Airlines Group S.A. (59-2605885); Lan Cargo S.A. (98-0058786);

Transporte Aéreo S.A. (96-9512807); Inversiones Lan S.A. (96-5758100); Technical Training LATAM

S.A. (96-847880K); LATAM Travel Chile II S.A. (76-2628945); Lan Pax Group S.A. (96-9696800); Fast

Air Almacenes de Carga S.A. (96- 6315202); Línea Aérea Carguera de Colombia S.A. (26-4065780);

Aerovías de Integración Regional S.A. (98- 0640393); LATAM Finance Ltd. (N/A); LATAM Airlines

Ecuador S.A. (98-383677); Professional Airline Cargo Services, LLC (35-2639894); Cargo Handling

Airport Services, LLC (30-1133972); Maintenance Service Experts, LLC (30-1130248); Lan Cargo

Repair Station LLC (83-0460010); Prime Airport Services Inc. (59-1934486); Professional Airline

Maintenance Services LLC (37-1910216); Connecta Corporation (20-5157324); Peuco Finance Ltd.

(N/A); Latam Airlines Perú S.A. (52-2195500); Inversiones Aéreas S.A. (N/A); Holdco Colombia II

SpA (76- 9310053); Holdco Colombia I SpA (76-9336885); Holdco Ecuador S.A. (76-3884082); Lan

Cargo Inversiones S.A. (96-9696908); Lan Cargo Overseas Ltd. 7752959); Mas Investment Ltd.

(85-7753009); Professional Airlines Services Inc. (65-0623014); Piquero Leasing Limited (N/A); TAM S.A.

(N/A); TAM Linhas Aéreas S.A. (65- 0773334); Aerolinhas Brasileiras S.A. (98-0177579); Prismah

Fidelidade Ltda. (N/A); Fidelidade Viagens e Turismo S.A. (27-2563952); TP Franchising Ltda.

(N/A); Holdco I S.A. (76-1530348) and Multiplus Corredora de Seguros Ltda. (N/A). For the purpose

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2 Paulo, SP, Brazil, 04530-030 until December 31, 2020). I am admitted in, practicing in,

and a member in good standing of the Brazilian Bar Association. I submit this

declaration (this “Supplemental Declaration”) regarding LBCA ’s hourly rate

adjustments for certain engagements effective as of the applicable date set forth in

Exhibit A hereto (the “2021 Rate Schedule”), and in compliance with the requirements

set forth in the: Order Authorizing Employment and Retention of Lee, Brock, Camargo

Advogados as Local Brazilian Litigation Counsel for the Debtors and Debtors-in-Possession

Nunc Pro Tunc to the Subsequent Petition Date entered on October 1, 2020 [Docket No.

1141], (the “Retention Order”). The Application was supported by the declaration of

Solano de Camargo, a founding partner of LCBA (the “Camargo Declaration”) and the

declaration of Juan Carlos Menció, Legal Vice President of LATAM Airlines Group S.A.

(the “Menció Declaration”). Except as otherwise indicated, I have personal knowledge

of the matters set forth herein and, if called as a witness would testify competently

thereto.

2. In accordance with the Retention Order which provides that the

LBCA Firm shall, prior to any increases in its rates, file a supplemental declaration with

the Court and provide ten days’ notice to the United States Trustee and other parties in

interest, which supplemental declaration shall explain the basis for the requested rate

increases in accordance with section 330(a)(3)(F) of the Bankruptcy Code. [Docket No.

1141] ¶ 7.

LBCA’S HOURLY RATES

3. As set forth in the Solano Declaration, the Firm employs a variety

of fee structures depending on the needs of the specific engagement, including charging

on an hourly basis, a flat predetermined basis, a fixed limited basis, or on a contingency

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basis. For certain services, the Firm’s fees are determined by General Index of Market

Price, as provided for under Brazilian law. The General Index of Market Price reflects

the inflation in the previous 12-month period (not necessarily the calendar year because

the index is released by Brazilian authorities for each month and the accumulated

percentage for the previous 12-month period). This practice is adopted by all parties in

Brazil in long-term agreements (i.e., agreements with terms of 12 months or more), as

provided for under Brazilian law.

4. LBCA and the Debtors have agreed, with respect to certain service

agreements, to apply monetary adjustments on related fees according to the General

Index of Market Price, as provided for under Brazilian law. The service agreements

between the Firm and the Debtors and related fees are set forth in the 2021 Rate

Schedule attached hereto as Exhibit A.

5. LBCA submits that its rate adjustments are reasonable pursuant to

section 330(a)(3)(F) of the Bankruptcy Code as such adjustments are applied firm-wide,

and the new rates are comparable to those in similar circumstances by similarly skilled

professionals. To the extent practicable, the Firm is providing not less than ten days’

notice of the applicable rate adjustment date to the parties provided for in the Retention

Order. With respect to the adjusted rates effective as of January 1, 2021, LBCA is

providing as much notice as possible under the circumstances.

7. The Debtors have been provided with the LCBA Firm’s adjustment

rates set forth in Exhibit A and the Debtors have no objection thereto.

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8. Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that

the foregoing is true and correct.

Dated: January 22, 2021

São Paulo, Brazil

/s/Solano de Camargo

Solano de Camargo

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Ref AREA SCOPE FEE STRUCTURE INVOICING HIRING DATE DATE OF ADJUSTMENT IN ₂₀₂₁ % of ADJUSTMENT RATE _{(FORECAST) (*)}

Commercial Litigation

1 – Relevant Cases Fixed Fees · Monthly payments of $ 41.76 for each case

2 · Monthly payments of $106.34 for each case; plus

3 Commercial Litigation Fixed Fees and Success

Fee · 10% success fee – Sale Agents

4 · Monthly payments of $ 41.76 for each case; plus

5 Commercial Litigation Fixed Fees and Contingent

Fee 10% contingent fee

Litigation – Travel Agency Claims

· Payment of

6 $140.92 upon filing of case plus

7 $140.92 upon conclusion of case for cases up to

8 $19.99; or May 1, 2017 N/A

9 · Monthly payments of $42.85 for cases between October 1, 2014 October 1, 2021 11.22

10

Regulatory Litigation – PROCON1 Court Cases (discussion of penalties imposed by PROCON)

$19.99 and

11 $199.95; or

12 · Monthly payments of $107.13 for cases above $199.95

13 Regulatory Litigation –

PROCON · $44.36 upon registration of new case, plus

14

Administrative Cases (discussion of penalties

imposed by PROCON)

· $44,36 upon conclusion of case

Fixed Fees

15 · $59.32 upon registration of new case, plus

16 Regulatory Litigation – _DECEA2 · $59.32 upon conclusion of case Administrative Cases Fixed Fees

18 Regulatory Litigation – _{ANAC3 Court Cases} · $322.58 upon conclusion of case Fixed Fees

20 Regulatory Litigation – ANAC

Administrative Cases · $127.60 upon conclusion of case Fixed Fees

22 · $15.49 upon conclusion of case, plus

23 · $150.06 per in loco diligence (if necessary)

25 · $59.98 upon conclusion of case

26 · $11.38 upon registration of new PROCON case _{without hearing, plus}

27 · $11.38 upon conclusion of PROCON case without _{hearing; or}

28 · $25.63 upon registration of new PROCON case _{with hearing, plus}

29 · $25.63 upon conclusion of PROCON case with _{hearing; plus} 30 · Consumer Litigation Overall Success Fee

31 Consumer Litigation – Court

Cases

Fixed Fees and Consumer Litigation Overall Success

Fee

· $108.82 upon registration of new court case, plus

32 · $108.82 upon conclusion of court case; plus

33 · Consumer Litigation Overall Success Fee

34 · $33.65 upon registration of new Small Claims Court _{case, plus}

35 · $33.65 upon conclusion of Small Claims Court case; _plus 36 · Consumer Litigation Overall

37 Success Fee

38 · _{on average economic savings based on performance}Success Fee of either 15%, 20%, 25% or 30% based

indicators agreed by parties

39 · $148.59 upon registration of new PROCON case _{with hearing, plus}

EFFECTIVE DATE INVOICING FEE STRUCTURE SCOPE AREA Regulatory Credit Recovery Consumer Litigation

Consumer Litigation – PROCON

Fee Fixed Fees

Regulatory Litigation - Other5 Regulatory Litigation –

ANAC STELLA4 Fixed Fees

Consumer Litigation – Overall Success Fee Consumer Litigation – Small

Claims Court

Fee

Fixed Fees and Contingent Fee Credit Recovery Litigation

Success Fee DATE OF ADJUSTMENT IN 2021 N/A N/A September 1, 2014 September 30, 2014 January 1, 2020 January 1, 2020 January 1, 2020 November 1, 2014 Fixed Fees September 1, 2021 September 1, 2014 July 1, 2014 N/A July 1, 2021 % of ADJUSTMENT RATE (FORECAST) (*) September 30, 2021 January 1, 2021 January 1, 2021 November 1, 2021 September 1, 2021 N/A May 1, 2017 July 1, 2014 May 1, 2017 September 6, 2017 January 1, 2020 January 1, 2021 October 1, 2021 October 1, 2014 15.49 15.49 15.49 20.35 September 1, 2014 July 1, 2014 July 1, 2021 20.35 September 1, 2014 September 1, 2021 September 1, 2021 15.49 15.49 July 1, 2021 23.54 23.54 23.54 jan/dec20=23,139% jan21=0,3975% jul/dec20 = 17,96% jan/jun21 = 2,385% sep/dec20 = 12,31% jan/aug21 = 3,18% jan/dec20=23,139% jan21=0,3975% jan/dec20=23,139% jan21=0,3975% 11.22 8.25 nov/dec20 = 4,27 jan/oct21=3,975% 20.35 Indexation Period sep/dec20 = 12,31% jan/aug21 = 3,18% sep/dec20 = 12,31% jan/aug21 = 3,18% sep/dec20 = 12,31% jan/aug21 = 3,18% sep/dec20 = 12,31% jan/aug21 = 3,18% jul/dec20 = 17,96% jan/jun21 = 2,385% jul/dec20 = 17,96% jan/jun21 = 2,385% oct/dec20=7,64% oct/dec20=7,64% jan/sep21 = 3,577%

LEE, BROCK, CAMARGO ADVOGADOS

DECLARATION OF SOLANO IN SUPPORT OF APPLICATION AUTHORIZING PRICE ADJUSTMENT AS PER THE ENGAGEMENT LETTERS W/ LATAM GROUP

EXHIBIT A

January 22, 2021

Indexation Period

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42

43 Project Peri - Mediation Success Fee · $99.97 for each settlement February 1, 2016 N/A

44 General Advice on Corporate _Law · LBCA Hourly Rates (See Exhibit A)

45 · Currently – monthly payment for eleven seconded professionals

46 Permanent Call Center · Monthly payments of $1,043.89 - Airport Legal Assistance

47 In Loco Diligence Fixed Fees · $147.77 per diligence

48 Consumer Litigation

Prevention - Settlement · $30.80 per settlement of Claims at Airport

49 General Services – · $147.77 per service Consumer Litigation

Prevention

50 LATAM Stores – Compliance _Assistance Fixed Fees · $158.33 per store verification

51 PROCON Rio de Fixed Fees (potential · $73.07 per diligence

Janeiro – Claim Book

Assistance6 combination with fees for other scopes)

52 Diligences – Criminal Courts Fixed Fees · $97,49 per diligence

53 · $20.88 per reply ref. passenger list

54 Replies to Criminal Court

Requests/Notices · $41.76 per reply ref. other issues

55 Replies to Labor Court _{Requests/Notices} · $9.89 per reply June 1, 2017 N/A

56 · $21.11 per reply ref. passenger list

57 Replies to Civil Court

Requests/Notices Fixed Fees · $42.22 per reply ref. other issues

58 Replies to ANAC · $19.77 per reply May 1, 2017 N/A

Requests/Notices

59 _{representatives – Labor}Appointment of

Court Hearings

60 PROCON –

Attendance to Institutional Meetings

61 General Diligences · $73.88 per diligence July 1, 2021

(not covered by other scopes)

62 Mediation – Pre Litigation · $44.12 per settlement reached through mediation

63 · Monthly payments of $0.62 for each active case _{on Legalbox} January 1, 2020 N/A

Use of Legalbox – Consumer Cases

64 Use of Legalbox –Tax Cases _{(not handled by} · Monthly payments of $1.198 July 10, 2014 July 10, 2021

LBCA)

65 Use of Legalbox – Other cases _{(including Tax Cases)} · Monthly payments of $0.44 for each July 1, 2014 July 1, 2021

active case on Legalbox Registration – Consumer Civil

and

66 Small Claims Court Cases

67 Registration – PROCON

Administrative Cases Fixed Fees

68 Registration – Labor Cases _{assigned to other} · $7.31 per registration July 1, 2014 July 1, 2021

firms Fixed Fees

69 Registration – Tax Cases (not _{handled by} · $8.99 per registration September 10, 2019

LBCA) Fixed Fees

70 Contract Management Fixed Fees · Monthly payments of $1,988.91 February 3, 2020

71 Training – Sao Paulo Hourly · $79.97 per hour June 1, 2017

72 Training – Other Locations · $474.57 for 6 hours June 1, 2017

73

Commercial (Relevant and Sale Agents), Regulatory, Consumer, Credit Recovery and Travel Agency Litigation

· Monthly payment of 844.99 for processing of up to 500 payments. Exceeding

payments paid proportionally

AREA SCOPE FEE STRUCTURE EFFECTIVE DATE

93 Consumer Litigation – PROCON

Fee

· $11.38 upon registration of new PROCON case without hearing, plus

94 Administrative Cases · $11.38 upon conclusion of PROCON case without _{hearing; or}

95 · $25.91 upon registration of new PROCON case _{with hearing, plus} Corporate Seconded Professionals Airport Assistance Other Services Legalbox – Use of LBCA Technology Handling of Court- related Payments (LATAM Fixed Fund)7 Fixed Fees EFFECTIVE DATE EFFECTIVE DATE INVOICING

· $2.77 per registration January 1, 2020

Labor Litigation Legalbox – Other AREA AREA Seconded Professionals SCOPE Fixed Fees Fixed Fees Fixed Fees Fixed Fees Fixed Fees Fixed Fees Fixed Fees Fixed Fees Fixed Fees Success Fee March 1, 2021 N/A August 1, 2021

General Labor Litigation Fixed Fees · Monthly payments of $16.61 per case June 1, 2017

Hourly Rates August 1, 2016

Fixed Fees Success Fee

SCOPE FEE STRUCTURE INVOICING

DATE OF ADJUSTMENT IN 2021

· $2.18 per registration January 1, 2020

N/A DATE OF ADJUSTMENT IN 2021 INVOICING FEE STRUCTURE DATE OF ADJUSTMENT IN 2021

· $29.99 per appointment April 1, 2015

Fixed Fees Fixed Fees for each Seconded Professional % of ADJUSTMENT RATE (FORECAST) (*) 23.39 % of ADJUSTMENT RATE (FORECAST) (*) 20.35 20.35 20.35 20.35 22.29 11.22 July 1, 2021 20.35 April 1, 2021 July 1, 2021 20.35 % of ADJUSTMENT RATE (FORECAST) (*) · $159.33 per attendance July 1, 2014 July 1, 2014 July 1, 2014 July 1, 2021 20.35 18.17 aug/dec20=15,39% _{jan/jul21=2,7825%} oct/dec20=7,64% jan/sep21 = 3,577% Indexation Period jul/dec20 = 17,96% jan/jun21 = 2,385% mar/dec20=22,59% jan/feb21=0,795% jul/dec20 = 17,96% jan/jun21 = 2,385% jul/dec20 = 17,96% jan/jun21 = 2,385% jul/dec20 = 17,96% jan/jun21 = 2,385% jul/dec20 = 17,96% jan/jun21 = 2,385% apr/dec20=21,10% jan/mar21=1,1925% jul/dec20 = 17,96% jan/jun21 = 2,385% jul/dec20 = 17,96% jan/jun21 = 2,385% October 1, 2021 October 1, 2014 Indexation Period March 1, 2014 N/A Indexation Period

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96 · $25.91 upon conclusion of PROCON case with

hearing

97 98

99 Consumer Litigation – Court

Cases

Fee

· $97.10 upon registration of new court case, plus

100 · $97.10 upon conclusion of court case

101 Consumer Litigation – Small _{Claims Court}

Fee

· $30.03 upon registration of new Small Claims Court case, plus

102 · $30.03 upon conclusion of Small Claims Court case

103

· Success Fee of either 15%, 20%, 25% or 30% based on average economic savings based on performance

indicators agreed by parties

**(*) Rationale for the Forecast**

(i) all engagement letters are subject to monetary adjustment according to the variation of IGPM (General Index of Market Prices) yearly

(ii) for each anniversary, the variation of the correspondent month in 2020 up to Dec 2020 is fully condered in LBCA calculation;

(iii) the remaining months completing the 12 month period within 2021 shows a variation of IGPM based on a forecast for 2021 (4,77%)

Example:

Engagement Letter to be adjusted on March 1, 2021

(b) % IGPM variation in the period January 1, 2021 up to February 28, 2021 = 2,795% (4,77%/12 months x 2 months)

Forecast of the Inflation rate ==>> (a) + (b) = 23,39%

Consumer Litigation March 1, 2021 March 1, 2021 23.39 23.39 mar/dec20=22,59% jan/feb21=0,795% mar/dec20=22,59% jan/feb21=0,795%

(a) % IGPM variation in the period March 1, 2020 up to December 2020 = 22,59%

mar/dec20=22,59% jan/feb21=0,795%

March 1, 2014

Success Fee Consumer Litigation – Overall

Success Fee

March 1, 2014 March 1, 2021

March 1, 2014 N/A

23.39