Lisa files evidence brief with over fifteen exhibits, requests exhibitory proceeding into Villamorey's accounting records and forensic audit to quantify dividends withheld since 2008.

Documentary Evidence

The brief ratifies the documentary evidence submitted with the original complaint in Exp. 8853-24 and introduces over fifteen additional exhibits, building Lisa, S.A.'s evidentiary case to quantify the dividends withheld by Villamorey, S.A. since 2008. Among the most significant are an authenticated copy of Judgement 42-08 of July 11, 2008, issued by the Eleventh Civil Circuit Court, which underlies the sequestration order imposed on Lisa's dividends, and the First Superior Tribunal's Appeal Ruling of August 28, 2012, which modified that judgment on appeal.

To establish Lisa's standing, the filing includes a notarial certification from the Twelfth Notary of the Judicial Circuit of Panama attesting that Lisa remains registered as the holder of Share Certificate No. 1 in Villamorey's Shareholder Register. This document is particularly significant because it demonstrates that, despite the defendants' attempts to challenge Lisa's shareholder status, Villamorey's own corporate records recognize Lisa as such.

Lisa also introduces a letter signed by Juan Luis Bosch Gutierrez addressed to the Eleventh Civil Circuit Judge, in which Bosch offers to place at the court's disposal "the sums of money corresponding to declared dividends to which LISA, S.A. is entitled." This document constitutes a direct acknowledgment of funds owed to Lisa.

Additionally, the brief includes official letters from thirteen civil courts of the First Judicial Circuit of Panama, all confirming that no precautionary measures or attachments exist against Lisa. These certifications were obtained in connection with a criminal complaint filed by Lisa against Bosch for offenses against public administration (Case File No. 202300033850).

Exhibitory Proceeding

Lisa requests an exhibitory proceeding over Villamorey's accounting books, records, financial statements, and shareholder register, grounded in Article 17 of Law 254 of November 11, 2021, on international fiscal transparency. The proceeding is to be conducted at the offices of Villamorey's resident agent, Galindo, Arias & López. Its purpose is to determine the exact amount of dividends withheld from Lisa from 2008 through the date the evidence is gathered.

Document Recognition and Party Declarations

The brief requests the citation of Ramiro López Nimatuj, Villamorey's legal representative, to authenticate his signature and the content of a shareholder assembly invitation addressed to Lisa, as well as the citation of Diego De la Guardia of Galindo, Arias & López to authenticate notes addressed to the Villalobos group's directors. Both citations require letters rogatory, as López Nimatuj is domiciled in Guatemala.

Lisa further requests party declarations from both López Nimatuj and Bosch, pursuant to the procedure established in Article 927 of Panama's Judicial Code.

Evidence Reports and Expert Examination

Three evidence reports are requested: one directed to the General Directorate of Revenue to verify whether Galindo, Arias & López filed a sworn declaration regarding its custody of Villamorey's financial documentation, another to the Anti-Corruption Prosecutor to obtain authenticated copies of judicial letters certifying the absence of attachments against Lisa, and a third directed to Villamorey and its resident agent for certified copies of shareholder assembly minutes from 2018 through 2024.

Finally, Lisa requests a forensic accounting examination of Villamorey's books and financial statements for the period 2008 through 2024, to be conducted on the basis of the exhibitory proceeding's results. The examiners are to determine dividends earned and declared per fiscal year, the proportion corresponding to Lisa's 33.33% shareholding, accumulated interest, and any annotations in the financial statements related to the withheld amounts.

Legal Basis

• Article 17 of Law 254 of November 11, 2021 (international fiscal transparency), grounding the exhibitory proceeding over the resident agent's accounting records
• Article 927 of Panama's Judicial Code, governing the procedure for the requested party declarations

Signatories

• Lcda. María Luisa Villarreal Palacios, judicial representative of Lisa, S.A.