{
  "schema": "por-derecho.sun-park-valuation-institutional-admissions-matrix.v1",
  "control_id": "PD-SP-VAL-INST-20260910",
  "control_date": "2026-09-10",
  "status": "PUBLIC_SAFE_INVESTIGATIVE_MATRIX_NOT_FINDING",
  "proceeding": "PD-SP-R-0001 · Concurso 36/2012",
  "boundary": "This is a unitary investigation and recovery matrix. A source-generated admission, institutional act, omission allegation, chronology or later benefit does not prove criminal agreement, intent, corruption, prevaricacion or collective responsibility. Every person is tested by source, knowledge, legal power/duty, act or omission, causal effect and counterfactual.",
  "unitary_question": "Did materially non-representative condition/value information become an institutional premise for a CAM-favouring insolvency route while contrary information, fragmented title and viable operating/finance alternatives were available, and did later acts or omissions allow that premise to migrate through control, competition, title and downstream economic benefit?",
  "institutional_role_model": {
    "insolvency_administrator": {
      "role": "indispensable factual, representation, estate-management, implementation and accounting gatekeeper",
      "test": "information available -> statutory power/duty -> commission or omission -> immediate estate/property consequence -> counterfactual",
      "proof_ceiling": "Documented acts and unresolved omissions justify actor-specific investigation; they do not by themselves establish deliberate disloyal administration, deception, concert or intent."
    },
    "judge": {
      "role": "indispensable judicial approval, supervision, competition, preservation and implementation gate",
      "test": "material actually before court -> judicial power/duty -> order/refusal/omission -> next irreversible step -> counterfactual",
      "proof_ceiling": "Adverse, mistaken or discretionary judicial decisions do not establish criminal wrongdoing. Any criminal theory requires the specific judicial act or legally relevant omission, the applicable objective unlawfulness/arbitrariness threshold, mental element and causation."
    }
  },
  "valuation_reconciliation": {
    "actua_whole_complex_eur": 9776003.13,
    "cam_offer_159_units_eur": 7065384.42,
    "plan_ap_actua_159_units_eur": 6607551.87,
    "same_159_perimeter_difference_eur": 457832.55,
    "actua_31_locals_pools_eur": 489361.96,
    "plan_lpb_real_estate_eur": 7096913.83,
    "gesvalt_rics_2017_eur": 26400000,
    "gesvalt_eco_2018_eur": 25647179.50,
    "rule": "The two 159-unit figures must never be silently merged. The exact filed ACTUA Annex I, schedules, valuation dates and methodology must explain the EUR 457,832.55 difference. Different valuation purposes can legitimately yield different values; numerical divergence alone is not proof of fraud."
  },
  "spatial_hypothesis": {
    "historic_owner_map": "22-Jun-2011: 29/40 apartment references (72.5%) in the 400s and 500s",
    "blocks_4_5_capacity": 44,
    "gesvalt_poor_condition_approx": 44,
    "contemporaneous_party_allegation": "17-Apr-2018 communication alleged two closed blocks / 61 apartments and extrapolation from minority-owner areas",
    "boundary": "The numerical alignment 44 poor-condition units = capacity of Blocks 4+5 is an investigative lead, not proof that the GESVALT 44 were Blocks 4+5, not proof that all owners there were dissidents, and not proof of wrongdoing.",
    "required_test": "ACTUA photo -> exact unit -> finca -> corrected block -> owner/controller at date -> access provider -> operating/maintenance condition -> source supplied to ACTUA"
  },
  "self_created_distress_hypothesis": {
    "classification": "PROJECT_ALLEGATION_AND_FALSIFIABLE_HYPOTHESIS",
    "statement": "Project Sun Rock alleges that closure, withholding, deterioration or interference affecting a limited minority/dissident-linked unit perimeter may have been used or extrapolated as evidence of whole-hotel distress; institutional acceptance and later whole-hotel access/control may then have impaired operation, diligence and finance, potentially creating conditions that retrospectively resembled the original distress narrative.",
    "causal_chain": ["limited-unit closure/condition", "ACTUA sample/input", "whole-hotel depreciation/distress premise", "AC Plan adoption", "judicial transaction architecture", "security/access/control", "operational/diligence impairment", "finance/exit impairment", "later deterioration or weakened bargaining position"],
    "proof_ceiling": "No common plan, malicious purpose or causal feedback loop is established merely by sequence. Prove each arrow and actor independently."
  },
  "events": [
    {"date":"2011-06-22","source_actor":"Owners' Community / historic owner-representation record","source_type":"minutes/owner map","evidence_class":"DOCUMENTED_CONCENTRATION","proposition":"40 apartment references; 29/40 in 400s+500s","administrator_role":"none at this date in the valuation incident","judge_role":"none at this date in the valuation incident","downstream_bridge":"targets owner-by-owner unit history and later condition/sample testing","counterrecord":"concentration is not dissident status or common intent","p0":"owner -> finca -> block -> role -> act crosswalk from contemporaneous lists and Registry"},
    {"date":"2017-06-30","source_actor":"GESVALT","source_type":"RICS valuation","evidence_class":"PROFESSIONAL_VALUATION","proposition":"EUR 26.4m whole-complex market value; nine-block geometry","administrator_role":"later comparison/control evidence","judge_role":"later comparison/control evidence if and when filed/received","downstream_bridge":"baseline before ACTUA","counterrecord":"different purpose/method from later ACTUA/ECO work","p0":"exact circulation to AC/court"},
    {"date":"2017-10-20/2018-02-08","source_actor":"CAM / AC / court","source_type":"assignment and holder-substitution route","evidence_class":"PRIMARY_JUDICIAL_AND_PARTY_RECORD","proposition":"CAM becomes recognised holder of secured claims at preserved definitive-text quantum after favourable AC report","administrator_role":"favourable report and verification premise","judge_role":"holder substitution ordered; court relied on AC verification premise","downstream_bridge":"creditor position preceding CAM offer and Plan","counterrecord":"assignment price/economics and full verification file not produced by the order","p0":"Protocol 2248 schedules, price/payment, AC verification, appeal/finality"},
    {"date":"2018-01-15","source_actor":"Construcciones Acosta Matos, S.A.","source_type":"12-page CAM offer","evidence_class":"PRIMARY_PARTY_DOCUMENT","proposition":"CAM invokes ACTUA EUR 9.776m whole-complex value, EUR 7.065m 159-unit offer value and EUR 12.251m debt premise; future dacion plus EUR 400k branch","administrator_role":"offer addressed directly to AC; subsequent Plan adoption must be traced","judge_role":"later judicial treatment must be traced to the exact filed set","downstream_bridge":"private valuation becomes proposed estate-disposal architecture","counterrecord":"offer creates no present possession/exploitation and no third-party transfer; list duplicates 8579/omits 8519","p0":"ACTUA Annex I, authority/appraisal attachments, exact filed offer and correction trail"},
    {"date":"2018-01-18","source_actor":"Insolvency Administrator","source_type":"Liquidation Plan","evidence_class":"PRIMARY_AC_DOCUMENT","proposition":"AC recommends CAM route; uses ACTUA EUR 6.608m for 159 apartments and EUR 489k for 31-finca branch; distinguishes whole-complex from LPB estate","administrator_role":"commission: authors, selects and recommends the disposal/value architecture","judge_role":"later approval/qualification gate","downstream_bridge":"ACTUA becomes institutional estate premise","counterrecord":"Plan's EUR 6.608m differs from CAM offer EUR 7.065m by EUR 457,832.55; Plan says CAM exploitation only once ownership obtained","p0":"exact ACTUA Annex I; reason for valuation mismatch; AC review of contrary valuations/condition"},
    {"date":"2018-02-27/2018-05-18","source_actor":"AC / Owners' Community","source_type":"email + Community minutes","evidence_class":"DOCUMENTED_AUTHORITY_CHAIN","proposition":"AC requested a Community meeting on LPB's behalf for access-control security; later minutes approve security","administrator_role":"commission: links LPB insolvency administration to the pre-7-June security/access chain","judge_role":"judicial knowledge/response depends on certified docket and later filings","downstream_bridge":"security/access -> material-control investigation","counterrecord":"security/preservation authority is not CAM possession, eviction or whole-hotel title","p0":"native instruction, service, contract, provider, exact spatial/property scope, keys/access logs"},
    {"date":"2018-03-01","source_actor":"GESVALT","source_type":"critical expert report","evidence_class":"PROFESSIONAL_CONTRARY_OPINION","proposition":"criticises ACTUA inputs, uniform 57.14% depreciation and physical-condition treatment; approx. 44 poor-condition units, remainder usable","administrator_role":"omission/commission question: what did AC receive, test, reconcile or reject?","judge_role":"knowledge question: what version was actually before court before 16-Apr?","downstream_bridge":"direct contemporary challenge to ACTUA factual premise","counterrecord":"professional criticism is not itself a finding of fraud","p0":"receipt/circulation metadata; complete reports and annexes"},
    {"date":"2018-04-03","source_actor":"ACTUA","source_type":"counter-report 438_2018","evidence_class":"CONTRARY_PROFESSIONAL_MATERIAL","proposition":"ACTUA responds to GESVALT critique","administrator_role":"receipt/use/reconciliation to prove","judge_role":"pre-16-Apr receipt/use to prove","downstream_bridge":"adversarial valuation record","counterrecord":"17-Apr formal CAM filing is later than Plan order","p0":"complete counter-report and proof of any earlier transmission"},
    {"date":"2018-04-16","source_actor":"Insolvency Court / Judge Alberto Lopez Villarrubia","source_type":"Plan-approval order C36-E008 + separate interest clarification","evidence_class":"PRIMARY_JUDICIAL_ACTS","proposition":"court approves AC Plan subject to qualifications/competition; separate same-date act permits secured interest growth within mortgage maxima","administrator_role":"AC Plan/recommendation and clarification request form inputs","judge_role":"commission: approval and separate debt/interest legal gate","downstream_bridge":"valuation/debt premise gains judicial transaction architecture","counterrecord":"approval is asset-specific; no whole-hotel possession/exploitation order; two same-date acts must not be merged","p0":"bind exact filed Plan/Annex I, all pre-order objections/responses and evidence actually before judge"},
    {"date":"2018-04-17 12:27","source_actor":"CAM","source_type":"LexNET 201810203877878","evidence_class":"PRIMARY_FILING_METADATA","proposition":"formal filing of ACTUA technical responses to GESVALT","administrator_role":"receipt/use after Plan order to trace","judge_role":"cannot have caused the 16-Apr order by chronology","downstream_bridge":"later valuation dispute/court record","counterrecord":"no retroactive causation","p0":"earlier circulation, if any"},
    {"date":"2018-05-23/2018-06-07","source_actor":"GESVALT","source_type":"ECO mortgage valuation","evidence_class":"PROFESSIONAL_VALUATION_AND_PHYSICAL_CONTROL","proposition":"inspection 23-May; EUR 25.647m; Terminado; Con ocupante; 262 fincas treated as one exploitation unit","administrator_role":"comparison against Plan/ACTUA and estate-preservation decisions","judge_role":"knowledge and relevance must be tied to formal filing/receipt","downstream_bridge":"direct pre-control counterfactual for value, condition and finance","counterrecord":"ECO purpose differs from RICS/ACTUA; does not determine legal operator/title","p0":"exact formal circulation and use"},
    {"date":"2018-06-07","source_actor":"Community/private perimeter / witnesses","source_type":"same-day records, later testimony, photographs/videos","evidence_class":"MIXED_PRIMARY_AND_ATTRIBUTED_ALLEGATION","proposition":"material access/control event with alleged lock-breaking, chains, cylinder changes, security and exclusion","administrator_role":"authority/scope/monitoring and response to whole-hotel effects must be tested","judge_role":"no primary judicial possession/eviction/whole-hotel control order identified; later knowledge/protection must be traced","downstream_bridge":"operation/access -> ONA diligence/finance -> value/condition","counterrecord":"2018 criminal proceeding was provisionally dismissed and dismissal affirmed; that outcome must be displayed","p0":"security contract, native instructions, spatial scope, keys, CCTV, witnesses, income/operation impact"},
    {"date":"2018-06-26","source_actor":"Insolvency Court / Judge","source_type":"suspension order","evidence_class":"PRIMARY_JUDICIAL_CONTRARY_EVIDENCE","proposition":"realisation of enumerated mortgaged apartments suspended pending appeal; other liquidation could continue","administrator_role":"implementation under asset-specific limit","judge_role":"commission: genuine protective measure","downstream_bridge":"limits later disposal authority","counterrecord":"stay is not possession/exploitation/security authority","p0":"implementation/service and later asset-by-asset effect"},
    {"date":"2018-11-28/2019-10-24","source_actor":"AC + CAM / Insolvency Court","source_type":"Protocol 2150 + AC report + non-convalidation order","evidence_class":"PRIMARY_NOTARIAL_AC_AND_JUDICIAL_RECORD","proposition":"AC executed EUR 400k 31-finca deed before later LAJ formalisation direction; judge later found transaction occurred without court authorisation and refused convalidation","administrator_role":"commission: executed deed and later sought convalidation; accounting/reversal/cure remains open","judge_role":"commission: refused convalidation and ordered renewed competition; effectiveness of restoration is an omission/supervision question, not an assumed fact","downstream_bridge":"tests whether institutional correction actually restored asset/value/competition","counterrecord":"refusal to convalidate does not itself prove every cash/title consequence automatically reversed","p0":"bank ledger, Registry, reversal/fresh conveyance, post-ruling implementation"},
    {"date":"2020-05-12/2021-02-24","source_actor":"LPB/Aweswell, AC, CAM, Court","source_type":"applications and judicial orders","evidence_class":"PRIMARY_JUDICIAL_RECORD_OF_DISPUTE","proposition":"works/demolition/access and neutral-inspection requests reached court; in Feb 2021 AC said no LPB possession delivered and CAM described mixed title/54 units; substantive measures remained refused","administrator_role":"conservation treated as AC function; response to alleged works/access and mixed title to be tested","judge_role":"commission/omission test: refusal of requested inspection/stop-work relief and what reliable neutral equivalent, if any, replaced it before competition","downstream_bridge":"condition/deliverability/value going into 2021 competition","counterrecord":"refusal is not a factual finding that no damage or interference occurred; court could lawfully find requested procedural vehicle/evidence insufficient","p0":"applications, photos, unit IDs, AC conservation file, any neutral inspection/equivalent"},
    {"date":"2020-06/2020-11","source_actor":"RICPE/CAM project side","source_type":"brochure/webinar","evidence_class":"ACTOR_REPRESENTATION","proposition":"Sun Park presented to investors with whole-project language including title-holding company / acquired / unencumbered / 220 apartments / EUR 12m timetable","administrator_role":"later court/estate relevance depends on when formally notified","judge_role":"later court record shows title/publicity allegations reached court by 2021 and were later treated as irrelevant to finca realisation","downstream_bridge":"reverse comparison: distress acquisition narrative -> investment-ready project narrative before LPB title","counterrecord":"audiences/purposes/dates differ; later title and investment do not prove earlier valuation dishonesty","p0":"scripts, title reports, Board/Control Unit/DD, corrections and recipients"},
    {"date":"2021-01-13 onward","source_actor":"Aweswell/Gil","source_type":"CNMV/AEAT/court/criminal alerts","evidence_class":"NOTICE_RECORD","proposition":"title/investor/property contradiction was formally raised before 2022 deed","administrator_role":"formal receipt/response in insolvency route documented in later filings; exact substantive reconciliation to identify","judge_role":"formal court receipt is documented by 2021 joinder/response chain; later 26-Jan-2022 clarification held publicity material irrelevant to realisation","downstream_bridge":"knowledge before definitive title implementation","counterrecord":"notice proves communication, not truth of allegations","p0":"complete filed exhibits, rulings and any integrated reconciliation"},
    {"date":"2021-05-18","source_actor":"Insolvency Court / Judge","source_type":"Auto 164/2021 C36-E044","evidence_class":"PRIMARY_JUDICIAL_ACT","proposition":"CAM proposal definitively approved after competing Ottawa route did not appear/deposit required bond; order records EUR 14.8m better offer","administrator_role":"supported CAM route / supplied conditions; full comparative analysis and bidder file to reconstruct","judge_role":"commission: definitive approval after court-run competition mechanism","downstream_bridge":"competition -> CAM approval -> later deed","counterrecord":"existence of EUR 14.8m does not prove bidder complied or should have won","p0":"hearing recording/minutes, bidder filing/funds/authority/bond, comparative reasoning, notice/finality"},
    {"date":"2022-02-04","source_actor":"Owners' Community / Acosta Matos representations","source_type":"Community minutes","evidence_class":"PRIMARY_COMMUNITY_RECORD_WITH_OPEN_NOTICE_VOTING","proposition":"20.993% present/represented; project/licence/works/unitary-operation resolutions; CAM described as principal interested owner while LPB retained 72.976% debt/levy allocation in controlled annex reading","administrator_role":"LPB representation/Community-debt/estate-cost interaction must be reconstructed","judge_role":"relationship to imminent deed requires source-specific court knowledge, not inferred","downstream_bridge":"control/project/cost allocation -> title/redevelopment","counterrecord":"a necessary common work can lawfully bind owners; minutes do not by themselves prove invalid notice, fraudulent cost shifting or intent","p0":"call/service/proxies/votes, owner/quota list, technical classification of works, bank/invoices, direct ACTA distribution"},
    {"date":"2022-02-21","source_actor":"AC for LPB + CAM","source_type":"Protocol 457","evidence_class":"PRIMARY_NOTARIAL_ACT","proposition":"159 scheduled mortgaged LPB fincas conveyed by dacion; EUR 13,168,082.02 stated debt consideration; deed places its own traditio on 21-Feb-2022","administrator_role":"commission: executes conveyance and undertakes five-day court report; final accounting/receipt/cancellation remains open","judge_role":"prior approval/confirmation/clarification testimony is implementation predicate; later review/finality record remains incomplete","downstream_bridge":"debt/competition -> title","counterrecord":"deed does not transfer non-LPB title, prove every debt component, or retrospectively authorise 2018 whole-hotel control","p0":"five-day court receipt, debt payoff ledger, cancellations, Registry, EUR 400k branch, surplus/final accounts"},
    {"date":"2022-10 onward","source_actor":"CAM/HNT/RICPE/public-programme/operating perimeter","source_type":"corporate, audited, funding and operating records","evidence_class":"DOWNSTREAM_TRACEABILITY","proposition":"CAM->HNT economic-unit step, RIC-related finance/materialisation, regional incentive and MYND operation create current value/benefit traceability","administrator_role":"final estate accounting and what value/rights left LPB remains open","judge_role":"later benefit does not back-prove historic knowledge or judicial intent","downstream_bridge":"title -> finance -> redevelopment -> current operation/benefit","counterrecord":"finance, grant, RIC and revenue are distinct legal/economic objects and cannot be added as one gain; no automatic successor guilt","p0":"asset/passive schedule, RIC/AEAT and grant files, invoices/jobs/payments, income/EBITDA/refinance/distributions, property-use-consent map"}
  ],
  "anti_fragmentation_rule": "Do not ask only whether the court or Administrator knew one allegation. Reconstruct when enough mutually connected pieces were formally available that continued separate treatment of value, title, access, operation, finance, competition and downstream project representations itself requires a documented explanation. This does not presume that an integrated criminal scheme was known or proved.",
  "private_actor_self_generated_evidence": [
    "CAM's 15-Jan-2018 offer uses whole-hotel exploitation/value language while offering only the stated 159 LPB apartments plus a separate 31-finca branch and grants no present possession/exploitation.",
    "The AC Plan distinguishes whole-complex ACTUA value from LPB estate value and says CAM would exploit the apartments once ownership was obtained.",
    "CAM's 2021 court position described mixed ownership and its own 54-unit position rather than whole-hotel title.",
    "RICPE/CAM-side 2021 material later qualified the earlier investor-facing whole-project picture.",
    "Community minutes themselves record high attendance/representation but very small vote-qualified percentages in key periods because of debt exclusions."
  ],
  "criminal_first_bridge_links": ["B03 PH122->CAM","B04 PP1041/LPB representation","B05 ACTUA->insolvency decision","B06 AC/Community->material control","B07 ONA/finance->exit","B08 2021 competition->adjudication","B09 EUR13.168m->dacion","B10 Protocol457->Registry","B11 CAM->HNT","B12 HNT/MYND->current benefit"],
  "release_rule": "Public derivatives must distinguish DOCUMENTED FACT, PROFESSIONAL OPINION, ACTOR REPRESENTATION, CONTEMPORANEOUS PARTY ALLEGATION, REASONABLE INFERENCE, PROJECT ALLEGATION, CONTRARY EVIDENCE and OPEN PROOF."
}