Bosch's attorney opposed Lisa's request for Villamorey's financial records, admitting that Lisa transferred its shares to BDT Investments, Inc.

Admission of Share Transfer

The defense submitted as evidence Villamorey, S.A. share certificates documenting the chain of title: a first endorsement in ownership to Lisa, S.A. on April 9, 1984, and a second endorsement on April 12, 2022, transferring ownership to BDT Investments, Inc. The brief states:

"Esta documentación acredita, sin duda razonable, que LISA S.A. cedió todos los derechos y la titularidad de las acciones a favor de BDT INVESTMENT INC." (Page 2)

This statement, coming from the defendant's own attorney, constitutes an admission against interest that provides documentary confirmation of the transfer underpinning BDT's standing as a Villamorey shareholder.

Defense Arguments

The brief articulates three lines of opposition. First, that Lisa notified Panamanian courts of its transfer of share rights to BDT, and therefore lacks standing to request confidential shareholder information. Second, that Order 1624-08 issued by the Eleventh Circuit Civil Court of Panama on October 27, 2008, decreed the sequestration of Lisa's shares and dividends, a measure that remains in effect. Third, that Lisa has been using criminal jurisdiction as a pressure mechanism after failing to obtain favorable rulings in civil proceedings over fifteen years.

The defense invokes Article 17 of Panama's Political Constitution to argue that the Public Ministry must protect the confidentiality of Villamorey's shareholder, asset, and financial rights.

Procedural Context

The opposition responds to a request filed by Lcdo. Sidney Sitton, counsel for Lisa, S.A., on January 20, 2025, seeking Villamorey, S.A.'s accounting books and financial statements. This brief was filed three months after Lisa's Evidentiary Brief of October 22, 2024, which detailed Bosch's violations as judicial depositary and requested provisional seizure of the retained funds. Nine days after the present opposition, Lisa filed a Motion requesting that an Interpol location alert be issued against Bosch due to the inability to serve him with notice.

Signatories

• Lcdo. Moisés Joel Bartlett Quiel, Attorney, representative of Juan Luis Bosch Gutierrez