NewTitle control and criminal-law alarmPwC · CAM/RICPE · Montelanza, S.L.
Four non-estate units: named owners, PwC representations and the missing Registry bridge are now published
The RICPE dossier now contains a high-impact visual stop for four privately owned units identified in the minutes of 26 April 2016. Miguel Hernández Lorenzo, Elena Santos Ramos and Carlos Saavedra Rodríguez de Palacio —all PwC— respectively represented Bungalow 507, Local 1 and the Thompson unit Bungalow 708/property 8,557; LPB’s then representative represented Bungalow 511 and also LPB. The page asks what deed, consent and Registry chain later permitted the use, control or value of those properties to enter the CAM/RICPE picture of a wholly acquired hotel.
Express criminal allegation: Gil Marer publicly characterises the sequence as a patrimonial displacement of criminal-law significance and requests a property-by-property investigation. The analysis identifies concrete legal tests: disposition under non-existent authority, disloyal administration, authenticity of minutes/majorities, and the non-estate boundary of proceeding 36/2012.
Montelanza, S.L.: the 18 November 2016 deed proposed a conditional allocation of 8,499 and 8,500 to the Community and creditors, not a direct sale to CAM. April 2017 Registry records still named Montelanza, S.L.; the April 2018 schedule named CAM. The complete bridge is demanded: satisfaction of both conditions, onward conveyance, authority, price/payment and registration. The formulation is sharpened: CAM later appears with some isolated properties; that does not equal title or control over the whole hotel.
NewSource recordPwC · Community · 11 JUN 2016
176 contextual interventions and the PwC London–Madrid notice trail are now published
The new index identifies all six attendees and publishes, with timestamps, every consolidated substantive/contextual intervention by FMMM (99) and Juan Carlos Prieto (77). It retains the original Spanish, removes later editorial annotations and supports searching by fees, debt, voting, operation or administration.
Knowledge conclusion: Carlos Saavedra and Miguel Hernández attended for PwC Tenerife representing LPB in 2016. Between 1 and 8 March 2021, PwC UK escalated the matter to Risk and PwC Spain received the CNMV/RIC package. The page visualises how JDAM/RIC later became a de facto adverse party and separates proved knowledge, testable inference and what remains unproved.
“Whitewashing”: published as Gil Marer’s attributed conclusion, not a judicial fact. The page identifies the records that can test it: retainers, conflict searches, staffing, escalations, independence, billing and work product.
NewDocumentary reconstructionCommunity · FMMM · 2008–2022
2011 is identified as documentary ground zero; 22 June as the matrix minutes
The dossier now separates the 2008 prehistory from the FMMM era. The 2008 minutes describe a voluntary Exploitation Community distinct from the Owners’ Community, explaining why Gil Marer and Monterecco’s then representative initially regarded ordinary contributions by owners outside hotel operation as normal. The public correction is not “no charge ever”: it requires a valid budget, service, allocation and resolution, without duplication, unsupported backdating or use of debt to remove votes or extend control over third-party units.
The 2 February 2011 minutes are the threshold document: they appoint a president and authorise the hiring of an administrator but do not yet name FMMM. The 22 June minutes are the matrix minutes: FMMM already acts as administrator; LPB appears with approximately 72% but no vote because of attributed debt; debt and litigation are approved, the Exploitation Community maintenance arrangement is terminated and Pamanil is ratified for administration, maintenance, custody and claims. The 2015, 2016, 2018 and 2022 minutes repeat and expand that sequence until it connects with security, access, insolvency administration, CAM, licences and the €4.467 million levy.
Transfer correction: the located records do not establish that Montelanza, S.L. sold directly to Multimatrix. After the June 2008 transfer, LPB appears with 171 apartments and 29 commercial units while Montelanza, S.L. retains 11; a separate contemporary record places Gil’s vehicle’s purchase of LPB’s shares from Multimatrix in December 2011. No later primary Community minutes have been located after 4 February 2022.
NewMaterial correctionPublic Prosecutor · RIC · DP 616/2021 · DP 668/2021
The 2021 referral to the Public Prosecutor is documented
The 10 February LexNET receipt establishes filing of the complaint with the Arrecife duty court. The transmission’s own index identifies, among its annexes, extracts from the website, the webinar and the RIC document. The RIC allegations therefore formed part of the criminal file from entry.
The 12 March order opened DP 616/2021 and directed that the Public Prosecutor be informed and notified. Following allocation, the 22 March order—DP 668/2021, originating from DP 616/2021—directed that the proceedings be sent to the Public Prosecutor before provisional dismissal. Formal institutional communication and referral of a file containing the RIC allegations are therefore established.
Evidential boundary: the documents do not identify the individual prosecutor who examined the material or establish what substantive assessment the prosecution service made. Individual and merits-level traceability remains an open documentary question.
NewKnowledge mapCNMV · AEAT · insolvency · criminal route
The 2021 alert is reconstructed by recipient, substance and proof of receipt
The dossier now contains a plain-language visual panel tracing the connected sequence: the 13 January CNMV complaint and AEAT entry; the 10 February criminal complaint to the duty court; the 11 February insolvency filing; the 28 June update; service on the parties on 8 July; and placement of the file before the judge on 7 September.
The alert was not merely about a title discrepancy. It connected an investor-facing picture of an acquired, unencumbered asset with fragmented title, RIC materialisation, investor risk, estate devaluation, deterrence of bidders and the circular risk of later obtaining an adjudication that retrospectively validated the earlier representation. The map distinguishes established knowledge of the judge, administrator and personated parties from the criminal route: the LexNET receipt proves entry and the 12 and 22 March 2021 orders prove notification and referral to the Public Prosecutor. They do not identify the individual prosecutor or the prosecution service’s substantive assessment.
NewLawWhistleblowers · judicial protection · insolvency
A protected report and a court filing are different; the duty to react remains verifiable
The review separates two legal planes. The 2021 filings entered the insolvency case, met opposition and were later held judicially irrelevant: there was a procedural response, not simple silence. That does not identify a substantive reconciliation of title, third-party units, promotion and estate risk, or locate any Article 40.1 LEC referral to the Public Prosecutor or Article 82 TRLC supervision report.
The current Law 2/2023 regime protects qualifying reports made with reasonable grounds to believe the information true, prohibits obstructing or delaying follow-up and protects public disclosure in defined circumstances, including a low prospect of effective treatment because an authority may be in collusion. Canary Islands Decree 91/2024 permits up to six months only for special complexity and requires immediate referral to the Spanish or European Public Prosecutor where appropriate. Failure to respond within that regime would be a verifiable procedural failure; it would not prove collusion by itself.
NewProcedural chainKnowledge · decision · title
The 2021–2022 sequence precludes treating the administrator and judge as external or uninformed
The record now includes the 7 September 2021 order; the two contradictory orders dated 15 October; clarification applications; the insolvency administrator’s opposition; the 26 January 2022 clarification orders; the request and issue of certified copies with formal effect; the challenges; the 21 February deed; 20 April registration; and the 26 April decrees dismissing the challenges.
Precision correction: CAM did not physically prevent the court from receiving the documents. Its defence asked that the connected chronology not be admitted or treated as one decisional record while offering a narrower proprietary account. Gil Marer personally adopts the conclusion that the acts and omissions of the insolvency administrator and judge show functional alignment with the CAM-favouring outcome and require independent investigation. No clandestine agreement, criminal intent or judicial offence is stated as proved.
The update also explains why publicity serves notice, preservation and accountability without replacing current certifications, targeted notice, interim measures or registry proceedings. The 29 July 2021 legal draft is expressly identified as never filed and is not used as proof of court knowledge.
NewDocumentary chainNotice · title · public exposure
Prior notice, surviving Matkator title and current public exposure
The 13 January 2021 communications to CNMV and AEAT, the 11 February insolvency filing and the 28 February public warning document that objections concerning Sun Park–RICPE title, control and marketing predated adjudication. In 2026 CNMV confirmed supervisory actions and that its material did not contain two contradictory July 2021 records: CAM acknowledged only 54 units and RICPE broke down 262 properties, including 18 third-party properties, with no letter of intent or full due diligence.
Matkator’s 2015/2016 deeds and January 2025 Land Registry notes place full title to properties 8584 and 8588 in Matkator; the 2022 insolvency deed did not transfer them. Hotel operations and the official reference to EU co-financing continue. Without an audited property–use–consent–income map, the proprietary, tax, investor and public-funds exposure is current. Bounded conclusion: the available record requires a “no” answer to whether the integrated 2020 representation gave a complete and truthful title/control account; it does not by itself determine intent or criminal liability.
NewMaterial correctionRIC · finance · aid
Sun Park/MYND Yaiza materialisation and loans are documented
The previous caveat that no allocation or disbursement was shown has been withdrawn. RICPE’s 2023 audited accounts record Series F and G, €6,573,703.10 materialised and lent to Hotel New Trend, and a Canary Government suitability declaration dated 1 December 2022. The September brochure identifies MYND Yaiza as the former Sun Park and confirms two financed components.
Order HFP/521/2023 also awarded €3,440,914.20 against €11,469,714 of investment and 60 jobs. This does not by itself prove falsity, full payment or an offence; it moves the inquiry to the truth and completeness of the title, control, conflict and eligibility record.
NewBilingual correctionReader experience
AC and judge journey made static and directly navigable
The earlier source correction was not sufficiently discoverable. Both languages now contain the institutional block as static HTML immediately after the five private actors, with a visible AC & Judge / AC y Juez navigation tab and a three-step reading route. The cards no longer depend on JavaScript.
Editorial boundary: public or fiduciary office receives no narrative presumption of neutrality; culpability is not presented as an adjudicated fact.
NewCorrectionPrimary evidence
DIP 2/2026 contained a material appeal-status error
The Decree said no appeal was recorded as filed on 2 March and inferred finality through failure to appeal. Official court records dated 28 January and 18 February had already documented the filing, registration and processing of RPL 3319/2025.
The complete registered communication of 11 March is published with a literal comparison and an explanation distinguishing filing, admission and outcome. The contradiction does not by itself prove intent or influence.
NewInstitutionalPrimary documentLaw 2/2023
Formal routing to the Canary Islands Government's internal reporting system
The General Technical Secretariat for Finance and EU Relations stated that the material submitted on 15 July to the Directorate-General for Treasury and Financial Policy—REGAGE26e00065752755—was transferred to the Directorate-General for Modernisation and Service Quality for the purposes of Law 2/2023 and Decree 91/2024. The receipt also identifies internal communication 278202/2026, was signed on 12 August at 09:35:11 and was registered as outgoing record 681432/2026 at 10:19:36.
Scope: this is primary evidence of transfer, signature and outgoing registration. It is not a merits decision, acceptance of the allegations or finding of an infringement.
Privacy: the public copy removes the NIE, postal address, email address, verification code and links, barcode and QR; it retains the operative text, signing authority, date and outgoing record.
NewStructureReader experience
The five private actors now precede the insolvency administrator and judge
The sequence was reorganised so readers encounter the private actions first, followed by the fiduciary and public functions expected to examine, prevent, correct or give reasons for their treatment. Verified portraits were added where a suitable source existed.
Boundary: the order improves causal legibility; it establishes neither liability nor automatic neutrality for any public or private actor.