OPEN CALL · WHOLE-CLAIM CONTROL · 9 SEPTEMBER 2026
Project Sun Rock invites Cuatrecasas Legal, S.L.P. to state publicly, clearly and documentably whether it has used, is using, or intends to use the four Matkator promissory notes, Cambiario 1048/2019, ETJ 163/2020, any adjudication, remate cession, assignment or related recovery instrument to obtain or transfer economic value or control over the Aweswell/Sun Rock investment perimeter for the benefit of an adverse party, a connected person or any undisclosed third party.
If accurate, Cuatrecasas can put the following on the record:
“We have not used, and will not use, confidential, privileged, strategic or former-client information obtained through our work for Aweswell/LPB or the Sun Park rescue to advantage an adverse party or an undisclosed connected recipient. We will not instrumentalise the four Matkator pagarés, the Cambiario, the ETJ, any adjudication, remate cession, assignment or residual enforcement position as a concealed route to transfer control or value to an adverse party. We will account once for every invoice, WIP item, pro-forma, pagaré, payment, credit, adjudication value and recovery. Where the law permits disclosure, we will identify or exclude any contemplated third-party recipient and explain the applicable conflict, confidentiality, KYC/AML, approval and information-barrier controls. We will preserve the relevant records and correct any factual error in this public reconstruction.”
They may adopt it, qualify it, reject it, or replace it with their own precise statement. Silence is not treated as guilt.
| # | Question to Cuatrecasas | What would close it |
|---|---|---|
| 1 | Will the firm state that former-client confidential, privileged or strategic information has not been and will not be used to advantage an adverse party or connected recipient? | A clear statement plus a non-privileged description of conflict/information-barrier controls. |
| 2 | What is the legal and accounting bridge from work/invoices principally documented to Aweswell/LPB to four Matkator pagarés and a €182,517.72 Matkator judicial principal? | Original instruments, cause, authority, accommodation/guarantee/assumption evidence and work-allocation ledger. |
| 3 | Was there any side letter, security, accommodation, guarantee, assumption, mandate or other agreement by which Matkator undertook liability for that work? | The instrument and approval chain, or a clear statement that no such separate document exists. |
| 4 | Has any third-party recipient, assignee, adjudicatario or remate transferee been identified, approached, approved, discussed or contemplated? | If none, say so. If one exists, identify what can lawfully be disclosed and the conflict/KYC/beneficial-owner controls applied. |
| 5 | Will every invoice, WIP item, pro-forma, pagaré, interest line, cost award, payment, set-off, adjudication credit and later recovery be cross-credited once and only once? | One single-satisfaction ledger. |
| 6 | What internal review authorised the transition from rescue adviser/former-client counsel to affirmative recovery, adjudication and possible remate cession against Matkator? | Non-privileged decision chronology, matter ownership, conflict/risk review and approval chain. |
| 7 | What did the firm know about the Aweswell/LPB/Matkator entity structure, mixed title, hotel integration and adverse-control dispute when the instruments were accepted and when later enforcement choices were made? | Engagement/matter-opening records, contemporaneous advice and source-qualified chronology. |
| 8 | Does Cuatrecasas deny that its current recovery architecture could be used as a side-door route to confer economic leverage over the former-client investment perimeter? | A reasoned denial or explanation tied to the instruments, debt allocation and beneficiary controls. |
| 9 | Will the firm preserve all relevant matter-opening, DMS, billing, Collections, instrument, conflict, risk, KYC/AML, recovery, ETJ and assignment/cession records? | Confirmation of preservation or an equivalent defensible retention measure, subject to law and privilege. |
| 10 | Which factual proposition on this page does Cuatrecasas say is wrong, incomplete or unfairly framed? | A response with primary records; Project Sun Rock will preserve the original version and publish warranted corrections. |
| Layer | Controlled position | What remains open |
|---|---|---|
| Issued invoices | The located July-2019 schedule contains 22 issued invoices with €327,608.32 invoice-face total: 20 addressed to Aweswell and 2 to LPB; none in that schedule is addressed to Matkator. | Native engagement authority, work-to-entity allocation and complete accounting ledger. |
| Paid / unpaid | 16 invoices reconstruct as settled; six issued invoices total €136,830.72 unpaid. Cuatrecasas also presented the schedule after netting a €1,000 retainer. | Bank-level receipt, VAT and credit-note reconciliation. |
| 2019 WIP / estimate | €152,424.95 was described in the controlled schedule as not issued / WIP-estimate material, not as 22 additional issued invoices. | Time entries, matter IDs, approval, conversion into later invoices/pro-formas/instruments. |
| June 2020 collections | Cuatrecasas Collections separated €136,830.72 of unpaid bills from €161,738.75 of work carried out, both plus VAT, describing roughly €400,000 pending. | Why the 2020 unbilled-work figure differs from the 2019 WIP figure and what was later billed or instrumented. |
| Claim principal 1 | €189,830.72: reconstructed as €136,830.72 unpaid issued invoices + €53,000 in two pro-forma amounts. | Exact proceeding, source invoices/pro-formas, debtor basis, credits and satisfaction ledger. |
| Claim principal 2 | €182,517.72: four Matkator promissory notes; this is the principal underlying Cambiario 1048/2019 / ETJ 163/2020. | Original notes, authority/capacity, causa, exact work allocation and non-overlap with Claim 1/WIP. |
| February 2022 grouped demand | Cuatrecasas stated two ongoing judicial claims together totalled €441,463 including principal, interest and costs and said payment would fully clear the position. | Complete itemised ledger showing every invoice/WIP/pro-forma/pagaré/interest/cost and every credit exactly once. |
Documented former client and principal recipient in the located invoice schedule. Direct collection/settlement dialogue existed: in June 2020 Cuatrecasas circulated a draft for Gil Marer to sign on behalf of Aweswell acknowledging a defined unpaid-invoice amount plus additional work. That draft was a Cuatrecasas proposal, not a signed admission by Aweswell.
Documented subject of substantial insolvency work and recipient of two invoices in the July-2019 schedule. May-2018 emails also show Cuatrecasas chasing identified LPB invoices. Cuatrecasas later withdrew from representing Aweswell in Concurso 36/2012 citing prolonged non-payment.
No issued invoice to Matkator appears in the located July-2019 22-invoice schedule. Matkator later appears as maker/obligor of four pagarés and as defendant/executed party in Cambiario 1048/2019 and ETJ 163/2020. A formal engagement/mandate by Matkator for the relevant underlying work has not yet been located in the controlled sources. This page therefore describes Matkator as a separate company within the investment perimeter and does not assume an unproved parent/subsidiary relationship.
The absence of a located Matkator invoice or engagement does not by itself defeat a pagaré or prove misattribution: an autonomous instrument, guarantee, assumption or other valid accommodation may create liability. The repository therefore asks for the instrument cause, authority and accounting bridge rather than assuming the answer.
The repository should test, not presuppose, the following finite propositions:
| Test | Evidence needed |
|---|---|
| Work and instruction | Engagement letters, matter openings, instructions, time entries, deliverables and responsible professionals. |
| Invoice accuracy | Native invoices, narratives, rates, VAT, timecards, credit notes and payment records. |
| WIP conversion | 2019 WIP → 2020 unbilled work → pro-forma → invoice/pagaré/claim mapping. |
| Debtor attribution | Why Aweswell/LPB work or billing was legally attributed to Matkator, with any assumption/guarantee/accommodation. |
| Instrument cause and authority | Original front/back pagarés, signing capacity, consideration/cause, approvals and contemporaneous communications. |
| Claim overlap | Allocation ledger proving Claim 1, Claim 2 and WIP do not claim the same work/value twice. |
| Court presentation | What was represented or omitted in Cambiario/ETJ and whether any difference was materially capable of affecting a judicial disposition. |
| Single satisfaction | Every payment, credit, set-off, adjudication value, cession consideration and remaining balance. |
Cuatrecasas was plainly present in the LPB insolvency as counsel for the Aweswell/LPB side and filed/handled insolvency work. In May 2020 it withdrew from Aweswell representation because of unpaid fees. The present controlled search has not located proof that Cuatrecasas itself communicated, proved or sought recognition of its own fee credit as a creditor in Concurso 36/2012. The correct repository question is therefore whether such a creditor filing existed and, if so, how it reconciles with the later two-claim/pagaré structure.
Verified: Cuatrecasas's 3 September 2026 ETJ opposition asks for adjudication of finca 8.584 and the faculty to cede the remate to a third party.
Not verified: a completed adjudication, a completed remate cession, transfer of the whole underlying credit, identity of any assignee/recipient, or any Acosta Matos/CAM/HNT beneficiary.
Project hypothesis under test: Gil Marer asks whether the broader claim architecture could create transferable economic leverage over Aweswell through Matkator and whether any eventual recipient/beneficiary connects to the Acosta Matos perimeter. The repository does not adopt the proposition that the beneficiary “can only be” Acosta Matos. It requires instrument-level evidence: assignment/cession documents, consideration, KYC/beneficial-owner data, communications, source of funds, accounting and any link to the hotel perimeter.
| Lane | Purpose | Boundary |
|---|---|---|
| On-record / right of reply | Give Cuatrecasas a prominent, permanent opportunity to deny, correct, explain and supply primary records. | No response is treated as guilt or admission. |
| Public / media scrutiny | Publish the evidence architecture, corrections, counter-evidence and responses in a form journalists and readers can audit. | Public scrutiny is not a substitute for judicial or disciplinary findings and is not conditioned on settlement or payment. |
| Professional / deontological | Continue the existing ICAM/CCACM and territorially competent professional-conduct routes concerning loyalty, conflict, secrecy, diligence, good faith and internal control. | A complaint or appeal is an allegation/procedural act, not proof of misconduct. |
| Civil / professional liability | Test mandate, causation, loss of opportunity, accounting, restitution, set-off, single satisfaction and any professional-liability consequences. | Each cause of action, limitation issue, jurisdiction and loss model requires its own proof. |
| Criminal / investigative | Use DP 748/2026 and any competent route to test exact acts, representations/omissions, knowledge, intent, judicial effect, patrimonial harm and beneficiary where evidence supports it. | No crime is inferred from a fee dispute, pagaré, adverse litigation position or enforcement alone. |
| Cambiario / ETJ procedural control | Test service, title formation, debtor/cause, valuation, adjudication, cession, residual enforcement, registration and possession. | The three proceedings remain separate; cross-links do not create joinder. |
| Preservation / evidence custody | Preserve native instruments, DMS, billing, Collections, decision, conflict, KYC/AML, recovery and assignment records, with hashes/version lineage where lawfully obtained. | Privilege, secrecy, privacy and lawful-access limits remain intact. |
| Accounting / beneficiary tracing | Reconcile every euro once and trace any adjudication, assignment, consideration, source of funds and beneficial owner. | A requested remate cession does not prove a completed transfer or connected beneficiary. |
| Cross-border / investor remedies | Preserve any UK/Spanish or other cross-border former-client, investor or corporate remedies that the evidence and jurisdiction support. | No foreign cause of action is asserted merely because Aweswell is UK-incorporated. |
| Independent expert review | Use accounting, valuation, corporate, forensic-document and professional-practice experts where they can convert disputes into finite evidence questions. | Expert analysis remains distinct from adjudicated fact. |
Absence of a presently located document is never converted into proof that the document or event does not exist. A corrective or exculpatory primary record will be preserved and propagated through the same versioned evidence architecture.