Counter evidence Brief

On December 6, 2024, Lisa, S.A. filed its counter-evidence in response to the evidentiary submissions made by Villamorey, S.A. and Juan Luis Bosch Gutiérrez. Lisa challenges defendants’ documentary evidence—particularly materials suggesting wrongdoing in a past request for a letter rogatory and claims attacking Lisa’s standing—by submitting authenticated documents from prior proceedings, failed notification attempts caused by Villamorey, and motions showing that the letter rogatory was ordered by the Eleventh Civil Court, not initiated independently by Lisa. These records aim to show that defendants’ allegations are unfounded and that Lisa acted strictly under court instructions.

Lisa also introduces counter-evidence to rebut defendants’ attempt to undermine its shareholder status. The new submissions include shareholder meeting notices, communications from Villamorey’s president, and requests for certified copies of the shareholder register—all demonstrating that Lisa remains recognized as holder of 33.33% of Villamorey’s shares and continues to be summoned to corporate assemblies. Lisa further asks the court to compel Villamorey and its resident agent, Galindo, Arias & López, to produce authenticated records and to require Ramiro López Nimatuj to acknowledge the authenticity of documents he issued. These measures reinforce Lisa’s claim that Villamorey and Bosch have withheld dividends for years and now seek to obscure Lisa’s rights through baseless procedural objections.