# AC claims and R33 unitary canon

**Control ID:** PD-AC-CLAIMS-R33-20260922-01  
**Actor:** Francisco de Borja Rodríguez-Batllori Laffitte, court-appointed Insolvency Administrator in Concurso 36/2012  
**Status:** attributed claim-family register and evidential crosswalk; not an adjudicated finding of wrongdoing.

## Purpose

This control prevents the claims concerning the Insolvency Administrator from fragmenting across removal, remuneration, criminal, 2018 control/access, ONA/Clubotel, counsel-continuity and later appellate materials. It also prevents the 14 September 2026 R33 opposition in RPL 3304/2025 from being analysed as an isolated pleading.

Every claim family is actor-specific and must preserve: source lane, exact alleged act/omission, contrary/lawful explanation, causation/intent status, open proof and R33 treatment where relevant. Shared evidence does not merge separate proceedings.

## R33 control

R33 is the AC's 22-page opposition to LPB's appeal in RPL 3304/2025, electronically signed 14 September 2026 and received from counsel on 21 September 2026. It proves the position taken and material incorporated by the AC. It does not independently prove every factual characterization. Nor does disagreement, hostile tone or an omitted context establish falsity or bad faith.

The correct method is proposition-by-proposition comparison: **R33 proposition → contemporaneous source → date/capacity → material omitted context → contrary/adverse source → lawful alternative → remaining proof**.

## Fourteen controlled claim families

1. `AC-CLM-001` — annual accounts / information gap.
2. `AC-CLM-002` — financial-risk contract / SWAP.
3. `AC-CLM-003` — assignment price / Article 1535 information.
4. `AC-CLM-004` — dación / ACTÚA / debt-value premises.
5. `AC-CLM-005` — operating unity / 31-property €400,000 transaction / non-convalidation and later reconciliation.
6. `AC-CLM-006` — 2018 security/access/material-control authority and corrective action.
7. `AC-CLM-007` — ONA/Clubotel funded exit, information, cooperation and personation.
8. `AC-CLM-008` — remuneration, estate money and professional-payment reconciliation.
9. `AC-CLM-009` — opacity/conflict and Cuyás / Grant Thornton professional perimeter.
10. `AC-CLM-010` — standing/personation/procedural-access opposition.
11. `AC-CLM-011` — professional interference, isolation and attrition.
12. `AC-CLM-012` — actor-specific criminal complaint / DP 1956; separate from DP 1901.
13. `AC-CLM-013` — final estate/assets/actions/cash reconciliation.
14. `AC-CLM-014` — R33 contested characterizations / narrative-inversion hypothesis, tested without blanket falsity.

The exact allegation, R33 test, counterevidence and open proof live in `assets/data/ac-claims-r33-crosswalk-v1.json`.

## Mandatory non-transfer rules

- The AC is not a sixth private actor and is not the judge.
- A judicial authorization/approval is relevant contrary evidence; it is not automatic proof that every antecedent premise or implementation act was correct.
- A later adverse outcome does not prove that an earlier alternative was fictitious or that an adviser acted improperly.
- Payment does not prove bribery; contact does not prove influence; opposition to standing/personation does not by itself prove obstruction.
- A later structural finding may corroborate objective effect without proving earlier knowledge or intent.
- DP 1956, DP 1901, removal, remuneration and private-actor proceedings remain procedurally distinct.
- R33 must preserve genuine adverse evidence, including Joaquín Ruiz de Infante's withdrawal/apology and other adverse rulings.

## Truth Machine integration

Whenever an AC-related lawyer/professional interaction is analysed, use both:

- `PD-LAW-TRUTH-20260922-01` — professional × client × matter × period envelope; and
- the relevant `AC-CLM-*` family — actor-specific AC claim envelope.

A new lawyer interaction does not create a new AC theory by default. A new AC act/omission must be placed in an existing claim family or assigned a new stable claim ID with explicit reason.

## Public surfaces

- Spanish AC hub: `es/concurso-36-2012-administrador-concursal/`
- English AC hub: `en/insolvency-36-2012-insolvency-administrator/`
- Spanish R33 reader: `es/concurso-36-2012-oposicion-ac-apelacion-lpb-septiembre-2026/`
- English R33 reader: `en/insolvency-36-2012-ac-opposition-lpb-appeal-september-2026/`
- Removal/fees digest, DP 1956, counsel-continuity pages and ONA/Clubotel routes remain linked evidence lanes.

Native private Gmail/Drive locators and privileged communications remain outside public Git.