Project Sun Rock · Por Derecho

RPL 3304/2025 · SIGNED 14 SEP 2026 · PRIMARY SOURCE

The Insolvency Administrator’s opposition: full source and forensic/prosecutorial checkpoint

The located copy permits three layers to be tested side by side: what the Insolvency Administrator says; what his own filing incorporates as contemporaneous evidence; and the criminally relevant inferences that still require actor-specific proof of knowledge, duty, act or omission, causation and intent.

New · complete flagship-document pass. The preserved R33 v3 package has now been run through the Context Integrity / Truth Machine as a bounded source-review workflow: 276/276 statement propositions scanned, 482/482 preserved review anchors carried forward, and 179/276 statements identified for one or more context/inference review checks. This is review load, not a lie, credibility or guilt rate. Open the visual audit
Evidence rule. This page does not declare criminal guilt by Francisco de Borja Rodríguez-Batllori Laffitte, Francisco Mario Matos Matas, Antonio or Shaila Cogolludo, José Daniel Acosta Matos, PwC or anyone else. It reconstructs a testable hypothesis. Functional convergence, proximity or continuity do not themselves prove a criminal agreement.

Document

What it is

The Insolvency Administrator’s opposition to Luchy Playa Blanca, S.L.U.’s appeal against the order of 11 November 2025, appeal roll 3304/2025. The copy is electronically signed 14 September 2026 and is 22 pages long.

Copy received from counsel on 21 September 2026. Received original SHA-256: 5e072818…1d711.

Reading rule

A party’s procedural position

The filing proves what the AC argues and which sources he chooses to reproduce. His descriptions of Gil Marer, LPB, Aweswell or Por Derecho are not thereby adjudicated facts; equally, the opposing allegations are not proved merely because they are pleaded.

FORENSIC / PROSECUTORIAL VIEWER · SOURCE LEFT · COMMENTARY RIGHT

Read the filing and evidential commentary at the same time

The scrollable PDF remains the central source. Each side card is linked to a specific page, separates the AC’s words from our commentary, and preserves the contrary explanation or proof still required.

22 pages · RPL 3304/2025 · SHA-256 público df43ba1d…abd14
Binary control. The signed native source received remains separately preserved and unchanged (SHA-256 5e0728185cf9b686abd723497d2a53a2656a5e0de4d323a734ed02880eb1d711). The public viewer preserves all 22 visible pages and removes only interactive signature fields/certificate data containing unnecessary identifiers.

Checkpoint 1

Non-finality acknowledged; adverse first-instance judgment used as a narrative premise

The AC says conclusion of the insolvency depends solely on the appeal against the 28 September 2023 judgment and, in the same sequence, reproduces the €3,032,010.34 award plus interest when explaining the supposed background to the removal application.
Documented fact

The appeal remains pending

The filing itself acknowledges that the 2023 classification judgment is appealed and that closing the insolvency depends on the appeal. The first-instance outcome is therefore not the final procedural result.

Inference to test

Narrative asymmetry

The non-final judgment is nevertheless used as an adverse premise when interpreting motive and credibility. That is not inherently unlawful, but it requires a strict distinction between an existing first-instance judgment and a final outcome.

Checkpoint 2

The 2011 origin may pre-date the AC. The 2016 knowledge does not.

The AC responds to the February and June 2011 Community records by saying he could not have participated in conflicts that pre-dated his June 2012 appointment. That temporal limitation should be preserved. But his filing then reproduces Gil Marer’s 29 April 2016 email to the AC.

According to the text the AC chose to reproduce, the email directly notified him that: LPB disputed the Community debts as unreal; Community accounting documentation was said to be absent; legal and administrator costs were said to be the material costs serviced since 2011; and audited operating-company material was to be reconciled against the disputed quotas/debt.
AC position

The words of thanks

The AC relies on Gil’s thanks for his authorisation/assistance as evidence that he cooperated with the debtor.

Evidence incorporated

The same email fixes substantive notice

Its evidential value does not stop at the thanks. It fixes receipt, by 29 April 2016, of a concrete controversy about debt, arrears, accounting and reconciliation of common expenditure, linked to LPB’s hoped-for composition.

Criminal hypothesis

The question changes after notice

The test becomes: what did the AC verify, request, accept, omit, communicate or authorise after notice, and with what effect?

Open proof

The documentary bridge

Final economic report; material delivered after the Community meeting; PwC↔AC communications; audit/reconciliation response; basis for Community-credit treatment; and later debt/vote/access/security decisions.

FORENSIC / PROSECUTORIAL PASS · SOURCE → PROPOSITION → CONTRARY RECORD → OPEN PROOF

The filing is treated as an evidential statement by the Insolvency Administrator, not as one narrative that must be accepted or rejected wholesale.

Boundary. The private working review decomposed the source into 206 blocks, 276 statement-level propositions and 206 paragraph composites. Those records are review hypotheses, not findings of falsity, intent or criminal responsibility. The public projection retains only points that can be explained through identifiable sources and visible proof boundaries.
MOTIVE / COUNSEL

The proposed common explanation for why different lawyers ceased acting needs lawyer-by-lawyer proof.

The filing moves from one documented 2020 withdrawal to a general explanation for successive professionals using expressly inferential wording. The correct test is individual: date, contemporaneous reason, scope of withdrawal and what each professional actually said could or could not be maintained.

ANNUAL ACCOUNTS

The AC acknowledges the duty and attributes impossibility to missing documentation.

The test does not end with that attribution: what was requested, what was actually received, what remained missing, what further production measures were taken and what accounting, tax and quarterly-report material was later used. A specific missing item is not automatically proof of global non-cooperation.

SWAP / CAIXABANK

His own chronology creates a finite verification exercise.

The originals should fix the meeting/authorisation dates, nature of the action, costs/security conditions, the complete claim supplied and the reason for refusing the apud acta authority. The lawful explanation is preserved too: as legal representative the AC could reasonably require visibility and cost control over litigation pursued in LPB's name.

ARTICLE 1535

Failure of one legal route does not itself reveal the economic assignment price.

The cited order may decide whether the claim was “litigious” and whether the redemption route was available. That is distinct from what the assignee paid, when the AC learned the acquisition price and whether that economics mattered later.

ACTÚA / €400,000

Later judicial approval does not replace transaction-by-transaction reconstruction.

Appraisal, proposal, deed, non-validation, renewed authority, payment, estate accounting, any restitution and final title must remain separate. A later authorised endpoint may be legally important without answering every earlier implementation question.

GRANT THORNTON

The denial in the filing is entity-specific.

It addresses Grant Thornton Advisory, S.L.P.. It should not be transformed either into proof of a relationship with that entity or into a universal denial of every professional relationship across the Grant Thornton/Cuyás/Canary perimeter. Reconciliation requires legal entity, contract, capacity, dates, systems and conflict controls.

ESTATE STATUS

“No assets, actions or cash remain” is frozen as a testable representation.

It can be checked against the asset ledger, bank accounts, pending patrimonial litigation, receivables, final accounts and any unresolved restitution effect. Its forensic value is that it is concrete and falsifiable.

THE FILING'S OWN SCREENSHOTS

The AC evidences notice of both the accusations and their published limitations.

The screenshots he files preserve qualifications such as “not yet proved”, the distinction between accusation and conviction and open questions about coordination, financing and flows. That proves the content of notice; it does not prove the underlying accusation true.

Unitary chain

“Truth inversion” as a testable mechanism

2011Debt, arrears, voting, Pamanil/FMMM, custody and litigation appear together in the first located controversial Community matrix.
2016PwC and others reconstruct costs/debt/vote; FMMM participates; the AC receives direct notice and an expected documentary reconciliation.
2017–2018Antonio Cogolludo is recorded as president; security/access is approved. Documentary authority acquires material consequences.
2018–2022Credit, Community, access/security and the CAM perimeter functionally converge. This does not prove a common plan existed in 2011.
2023An adverse first-instance classification judgment is made within a record where particular arguments/remedies were also limited or rejected.
2026The AC invokes the pending judgment, disclaims the 2011 origin, and reproduces the 2016 email fixing his post-appointment notice.

The working mechanism is: private actors attribute debt → debt affects voting → a reduced voting perimeter validates administrators/accounts/lawyers/security/access → “the Community decided” travels to outside decision-makers → material consequences amplify the apparent authority → later outcomes are invoked as confirmation of the original authority. Criminal liability would require concrete falsity or abuse, knowledge, duty, act/omission, reliance/causation, benefit/harm and the applicable mental element.

PwC · truth-seeking gate

Why the 2016 evidence matters now

PwC’s relevance need not rest on accusing PwC of criminal conduct. Its value is evidential: PwC was inside the reconstruction while the Community, exploitation, private-unit and LPB positions were being separated with contemporary records.

April 2016

Named representation and notice

Three PwC professionals appear in the Community-meeting source as representatives of identified owners, while the team received the debt/books/accounts controversy.

May–June 2016

Accounting and reconciliation

Contemporaneous emails show delivery of calculations, bank material, historic minutes and ledgers. The June meeting record places Carlos Saavedra and Miguel Hernández opposite FMMM and others discussing costs, debt, voting, access and governance.

June–July 2016

Criminal-route instruction

PwC received the client’s written decision to stop further negotiation with the Molina/FMMM perimeter and prioritise a criminal complaint. On 20 July Miguel Hernández replied that PwC had taken note, while explaining the civil challenge deadline.

2021–2026

Institutional escalation

Later correspondence records escalation to PwC UK Risk and Spain General Counsel in 2021, later contacts, and a fresh preservation/whistleblower communication on 18 September 2026.

A finite truth-seeking request

PwC can help confirm or disprove the knowledge bridge by preserving and identifying: the 2016 engagement scope/team; meeting proxies; versions and supports of the Jonathan Simó analysis; meeting notes/audio/transcript; communications or call notes with the AC, FMMM, Prieto and the Community; what was delivered to the AC; and later conflict/KYC/independence records capable of showing whether any later PwC team touched the same asset/perimeter. PwC need not adopt the criminal hypothesis to help resolve it with records.

Right of reply and correction

Source and criticism should remain together.

The Insolvency Administrator, FMMM, Antonio and Shaila Cogolludo, Acosta Matos entities, PwC and any other named person may provide primary evidence correcting this reconstruction. Documented corrections should receive equivalent prominence. Silence is not treated as admission.

R33 ⇄ UNITARY AC CLAIM REGISTER

The 14 September filing is tested against all fourteen claim families, not in isolation.

R33 is primary evidence of the Insolvency Administrator's position. The new PD-AC-CLAIMS-R33-20260922-01 matrix requires its representations to be compared against annual accounts, SWAP, assignment price, ACTÚA/transfer in payment, the 31-property transaction, 2018 access/control, ONA, fees, professional perimeter, personation, counsel continuity, DP 1956 and final-estate reconciliation.

Contradiction rule: no disagreement is published as blanket falsity. Every proposition requires date, capacity, contemporaneous source, material omitted context, adverse evidence, lawful explanation and open proof. Joaquín's withdrawal/apology and adverse rulings remain visible.

Open all 14 families and controls → · Return to AC hub → · AC-CLM-011 · counsel →