16 April 2018: two separate Autos
The primary register controls two distinct orders issued on the same date. They must not be conflated because they share a judge and notification date.
JUD-2018-001 · JUD-2018-002
PUBLIC AUTHORITIES · PROSECUTORS · COURTS · REGULATORS · AUDITORS · EXPERTS
Reconstruct the complete chain without adopting any party's theory.
This interface organises common facts spread across ownership, Community governance, Insolvency 36/2012, material control, finance, tourism, administrative acts and later transfers. Its purpose is not to ask an authority to accept a global accusation. It is to let the authority identify its own part, inspect the sources, verify it independently and understand which other decisions depend on the same fact.
You do not need to solve the whole case. Determine the propositions within your lawful competence. The system then shows which other institutions share the same factual dependency and where evidence remains incomplete.
THE CASE ON ONE SCREEN
One physical/economic base; several legal and institutional lives.
1 · UnitProperty / title
Who owned it and from when.
2 · VoteMajority / representation
Which title generated each vote.
3 · AuthorityMinute / office
Who could speak and certify.
4 · Right/debtCreation and calculation
What was asserted against LPB or others.
5 · InstitutionReceipt / verification
What each body received and checked.
6 · ConsequenceControl / money / title
What changed afterwards.
Every arrow is an evidential question. Sequence does not prove causation. An authority repeating a proposition does not prove that it independently verified the proposition.
Five points to understand first
4 June 2018: complete canonical copy
The canonical authentic electronic copy has three pages and includes the operative part and signatures. An earlier two-page derivative was incomplete and is retained only as source history.
JUD-2018-003
15 June: LAJ act
The Diligencia de Ordenación is an act of Águeda Reyes Almeida, LAJ. It is not attributed to the Judge merely because it implements judicial Autos.
JUD-2018-004
26 June: realisation suspended
A complete two-page Auto suspends realisation of specified properties pending appeal, within the exact terms of that order.
JUD-2018-005
2011 remains a root to prove
The alleged Community-authority rupture is not presented here as a criminal fact or an adjudicated invalidity. It requires the complete minute, title, attendance/proxies, debt, vote and majority reconstruction.
AUTH-2011-001
2022 is a later threshold
Later formal title/transfer acts must be analysed by their date and perimeter; they cannot automatically be projected backwards to validate or invalidate acts in 2011–2021.
TXN-2022-001
SIX KEYSTONE NODES · READ BACKWARDS AND FORWARDS
Six conversions that can change several branches at once.
Ownership → debt → voting → authority
Reconstruct title, participation, notice, proxies, coefficients, debt, voting restriction, offices, custody and litigation from the native package.
Professional knowledge and private units
The controlled PwC source family records detailed knowledge of private units, Community/exploitation, accounts, debt/voting, access and insolvency. Later mandate/use/conflict questions remain open.
Authority → security/access → material control
Material access/control is source-supported subject to exact perimeter; AP 804/2018 supplies adverse lawful/civil context. Instructions, excess and actor-specific intent remain to prove.
Project representations
Compare each investor-facing title/acquisition/encumbrance statement with contemporaneous title, control and qualification evidence.
Internal position → judicial use
RICPE documents 54 CAM / 190 LPB / 18 third-party properties, conditional acquisition, unsigned LOI and incomplete DD; CAM files the certification the next day. Purpose, authorisation and reliance remain finite questions.
Re-entry → title → Series F/G → public support → MYND
Identify the re-entry record, title perimeter, use of Series F/G, Regional Incentives and ERDF by asset, invoice, payment and job. Series F/G control →
Criminal/investigative rule: no node becomes an offence because it is irregular, adverse or later beneficial. The question is whether a specific actor knowingly made, used or omitted a materially relevant proposition; who relied; what result followed; and what lawful alternative explains the same event.
UNITARY CONVERSION MATRIX
Do not convert the narrative into a criminal conclusion. Prove or reject each conversion.
| Conversion | Actor / function | Primary evidence / present status | Knowledge / notice | Recipient / reliance | Benefit / harm | Strongest lawful alternative | Dependency |
|---|---|---|---|---|---|---|---|
| Ownership → vote | Owners / Community organs | Title, attendance, proxies, coefficients and debt/voting package incomplete | Who knew the true title and voting base? | Later minutes / certificates / litigation | Governance and voting effect | Valid title and lawful restriction | BROKEN / OPEN |
| Debt → authority/document | Administrator / officers / certifiers | 2011 architecture source-supported; calculation/custody package incomplete | Who created or approved the debt and certificate? | Owners, IA, courts and later actors | Voting, claims and documentary authority | Accurate debt and valid office | DEPENDENT |
| Authority → access/control | Community / IA / security / private actors | 2018 material-control transition supported; exact finca reach open | Who knew limits of LPB/common-element authority? | Security, owners, operators, later project | Access, exclusion and practical availability | Lawful preservation/maintenance | DEPENDENT / CONTESTED |
| Control → project availability | CAM / project sponsors / advisers | Pre-title project chronology documented; exact rights and independent verification vary by date | What title/access limits were known? | RICPE, investors, advisers | Project progression and valuation | Preliminary project subject to conditions | DEPENDENT |
| Internal RICPE position → re-entry | RICPE governance/control functions | 20-Jul-2021 restrictive position verified; re-entry bridge still to produce | Who received and approved the change? | Committee/Board/investors | Funding eligibility and project continuation | New independently verified facts / valid waiver | BROKEN |
| Re-entry/title → finance/public support → MYND | RICPE/HNT and competent public bodies | Later title, F/G, award and ERDF identification verified at different levels | What asset/cost/job basis did each decision-maker know? | Investors, AEAT, Regional Incentives, ERDF controls | Finance, support, operation, income and value | Distinct costs, lawful cumulation and valid title | RECONCILIATION OPEN |
2016 knowledge bridge: PwC/Carlos is presently a knowledge, former-client, conflict and records inquiry. The later bridge requires an actual mandate, file access, conflict/KYC result, information barrier, work product, use, reliance and causation before any participation theory is upgraded.
YOUR INSTITUTION
One factual base; different questions according to competence.
These routes do not assume that an institution should accept Por Derecho's overall theory. Each begins with a limited question the body can test against its own files.
Applicant, capacity, title and file
- Who applied and in what capacity?
- What title/authority was supplied?
- Which properties/project did it cover?
- What did the municipality independently verify?
Establishment, operation and perimeter
- Which operator/establishment was presented?
- What title was evidenced?
- How was the totality of units treated?
- What was received in the 2020–2022 files?
RICPE: knowledge and communication
- What did decision-makers know about title/control?
- What did investor materials state?
- What changed before later representations?
- What independent verification is recorded?
Asset, costs, employment and cumulation
- Which costs/assets were eligible?
- What other finance was disclosed?
- How were jobs defined?
- Is there a reconciliation without double counting?
Facts before offence labels
- What did each actor do?
- What did the actor know at that date?
- What document/representation was used?
- Was there reliance, benefit/harm and causation?
Estate, authority, value and realisation
- Which /por-derecho-setup-or-gitlab-setup/assets/rights belonged to LPB?
- What was extraconcursal?
- Which debts/authority propositions were verified?
- How were fruits, value and alternatives preserved?
SHARED FACT
A question does not cease to matter to your institution because another authority also needs the answer.
Example: title on a material date. It may independently matter to the insolvency, a municipal file, tourism, RICPE/CNMV, public funding and—if a materially inaccurate representation was knowingly used—to a criminal investigation. The legal consequence is not the same in every lane; the underlying fact may be shared.
The system is intended to let each institution mark its own part as verified, not verified, contradicted or outside competence, rather than rebuilding the same fact from scratch—or assuming it was resolved—in every file.
CLEAN-ROOM REVIEW
For a new judge, prosecutor, auditor, regulator or expert.
Rule: this view does not require acceptance of Por Derecho's narrative or any prior actor's narrative. Start with verifiable objects.
Asset
Sun Park / MYND Yaiza: an economically unitary hotel operation over a property perimeter that must remain legally disaggregated by unit.
Ownership
Reconstruct by date and property. Do not substitute possession, operation, brand or a later transfer for title.
Authority
Reconstruct minute → voters → units → title → majority → appointment.
AUTH-2011-001 remains an open working hypothesis.Insolvency
Separate the LPB estate from Matkator/third parties and distinguish acts of the Judge, LAJ, Insolvency Administrator and parties.
2018
The primary register now distinguishes two 16-Apr Autos, an incomplete 4-Jun copy, the 15-Jun LAJ Diligencia and the 26-Jun suspension Auto.
2021–2022
Separate ownership representations/conditional title, adjudication and later transfers. Do not use later status as automatic proof of earlier status.
Funding
Reconcile each instrument by assets, costs, jobs, dates, conditions and other finance. Coexistence does not equal fraud.
Criminal
Analyse act, knowledge, representation, use, reliance, benefit/harm, causation and exculpatory evidence actor by actor.
DUAL COMMAND
A civil irregularity does not automatically become a crime; formal validity does not automatically close a separate criminal question.
Civil / commercial / insolvency / administrative track
Validity, competence, title, authority, credit, procedure, effectiveness, appeal and remedy.
Criminal / investigative / forensic track
Objective act, actor, contemporaneous knowledge, representation or omission, document used, recipient, reliance, benefit, harm, pattern, proven coordination and alternative explanation.
Actor-specific discipline. A company, family, law firm or institution does not share knowledge or intent merely because its members are connected. Coordination needs its own evidence. An adverse or disputed decision by an official or judge is not by itself criminal evidence.
READY FOR INDEPENDENT REVIEW
Neutral mandate for any future forensic audit or expert review.
Proposed mandate: “Independently reconcile ownership, authority, debts, assets, money flows, valuations, funding and institutional representations across the relevant periods and identify any unexplained inconsistency, without assuming that Por Derecho's allegations are correct.”
Initial work
- 2008 property/title/completion map.
- Recalculate votes and authority at material dates.
- Trace every material Community debt.
- Reconcile estate, value, fruits and transfers.
- Reconcile funding, costs, employment and works.
Required outputs
- Reproducible facts.
- Contradictions and alternative explanations.
- Institutional dependencies.
- Benefit/loss without double counting.
- Questions that remain open.
This proposed mandate does not imply that a court-appointed expert currently exists or that any particular procedural measure is presently available. Availability and form depend on the competent body and proceeding.
SOURCE OF TRUTH
Proposition → evidence → dependency → revisable conclusion.
Canonical IDs
UNIT, OWN, VOTE, ACTA, AUTH, DEBT, AC, JUD, PUB, TXN, FUND and EVID prevent each thread from creating its own version of the facts.
Mandatory contradiction search
Every adverse proposition must actively search for evidence that weakens or exculpates. What survives that review is more useful than a one-sided accumulation of material.
Visible corrections
Statuses change when better evidence appears. Corrections should preserve the earlier statement, the source that caused the change and downstream pages requiring revision.
AI boundary: AI-assisted tools may help locate, classify and cross-reference material. AI inference is not primary evidence. Every material conclusion must be reproducible from a source a human can inspect.
CORRECTION / RIGHT OF REPLY
The fastest way to weaken a conclusion is to provide a better source.
People, professionals and institutions mentioned in the record may provide documents, context or corrections. A material documentary response should itself be treated as evidence: it may confirm, limit, contradict or supersede an existing proposition. The methodological objective is a system capable of changing its mind when the evidence changes.
Permanent question: what proxy, deed, recalculation, due-diligence record, waiver, ruling or contemporaneous communication would require us to modify this conclusion? If it exists, it should be sought and displayed.