Evidentiary Brief

On December 3, 2024, Lisa, S.A. filed its comprehensive evidence submission in the ordinary damages case against Villamorey, S.A. and Juan Luis Bosch Gutiérrez. The filing confirms and expands the documentary evidence already provided with the complaint and adds authenticated judgments, registry certifications, corporate records, correspondence, and prior judicial orders demonstrating Lisa’s continuous status as shareholder and Villamorey’s longstanding refusal to recognize or deliver dividends. Lisa also submitted multiple official letters from various civil courts confirming that no liens or precautionary measures exist against the company, supporting Lisa’s argument of uninterrupted ownership rights.

The submission requests several key forms of evidence: (1) an Exhibitory Proceeding requiring Villamorey’s resident agent (Galindo, Arias & López) to produce accounting books, financial statements, and the share register from 2008–2024; (2) recognition of private documents by Ramiro López Nimatuj and by Diego De la Guardia; (3) multiple official information requests, including to the tax authority (DGI) for declarations made by the resident agent regarding Villamorey’s financial records, and to the Anti-Corruption Prosecutor for authenticated documents linked to Lisa’s related criminal complaint; (4) party declarations from Villamorey’s legal representative and from Bosch; and (5) a full forensic accounting expert examination to quantify dividends owed, interest accrued, and all financial annotations reflecting the withholding of Lisa’s funds. These evidentiary measures are aimed at establishing both the amount retained by Villamorey and Bosch and the full damages suffered by Lisa over more than fifteen years.