RPL 3304/2025 · SIGNED 14 SEP 2026 · PRIMARY SOURCE
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.
Document
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
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
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.
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5e0728185cf9b686abd723497d2a53a2656a5e0de4d323a734ed02880eb1d711). The public viewer preserves all 22 visible pages and removes only interactive signature fields/certificate data containing unnecessary identifiers.Checkpoint 1
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.
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.
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 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.
The AC relies on Gil’s thanks for his authorisation/assistance as evidence that he cooperated with the debtor.
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.
The test becomes: what did the AC verify, request, accept, omit, communicate or authorise after notice, and with what effect?
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 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.
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.
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.
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.
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.
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.
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 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
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
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.
Three PwC professionals appear in the Community-meeting source as representatives of identified owners, while the team received the debt/books/accounts controversy.
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.
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.
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.
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
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
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.
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