# Criminal-first institutional action protocol — 25 August 2026 **Protocol ID:** `PD-SP-ACTION-2011-CONVERGENCE-001` **Status:** CANONICAL PUBLIC-ACTION CONTROL **Source position:** Declarations 012 and 013; criminal-first unitary control; functional-convergence map v2; matter identity registry v1. **Purpose:** convert the alleged 2011 Community-organ capture, subsequent insolvency enablement and later Acosta Matos/CAM functional convergence into precise preservation, disclosure, explanation, investigation and recovery actions. ## 1. Governing position The Project's strongest presently defensible proposition is not that every named actor has already been proved to belong to one uninterrupted criminal conspiracy. It is that multiple independently documented personal, representational, corporate, title, voting, creditor, security/access, project and operating bridges support a substantial functional-convergence investigation from the 2009–2011 Community/litigation perimeter into the later CAM/Acosta Matos structure. Maximum pressure must therefore be produced by **specificity and traceability**, not by collapsing evidence grades: `actor ID → capacity → act/omission → date → source → notice/knowledge → consequence → benefit → contrary explanation → missing proof → requested action`. Every public or institutional use of this protocol must preserve these boundaries: - allegation is not adjudication; - relationship is not automatic knowledge or intent; - notice is not knowledge of falsity; - benefit is not concert; - later convergence may corroborate adoption, ratification, knowledge and benefit but cannot by itself prove a common plan in 2011; - the Administrador Concursal remains on a separate officeholder enablement/adoption track unless new evidence establishes private-perimeter membership; - adverse and exculpatory evidence must be preserved and published with the allegation it affects. ## 2. Pressure sequence ### PRESERVE Demand immediate preservation of native documents, metadata, communications, devices, accounts, ledgers, minutes, access records, images, recordings, security/locksmith records, court audit trails, title and banking records, professional files, due-diligence reports and board papers. ### DISCLOSE Seek certified or native records with provenance. A summary, reconstructed spreadsheet or recollection is not an adequate substitute where the primary record exists. ### EXPLAIN Require each actor to identify: - legal or contractual authority; - client, principal or beneficiary; - information received; - verification undertaken; - instruction given or relied upon; - decision or omission; - immediate and later consequence; - financial, professional, voting, possession or project benefit; - strongest innocent explanation. ### INVESTIGATE Test offence families and professional duties element by element. Do not use the umbrella phrase `estafa concursal` as a substitute for proving fraud, procedural reliance, insolvency conduct, disloyal administration, documentary falsity/use, coercion, damage or qualifying public-office conduct. ### RECOVER Maintain claimant-specific asset, income, possession, financing, professional-cost and damages schedules for LPB, AWESWELL LIMITED, Matkator, CEXP, the operating business, creditors and individual owners. ## 3. Immediate P0 action families The machine-readable action matrix is canonical: `assets/data/criminal-first-institutional-action-matrix-v1.json` Its P0 families are: 1. certified 2011 Community governance, debt and voting corpus; 2. native professional mandates, powers, conflicts and handovers; 3. AC appointment, independence and conflict file; 4. 2016 notice and verification checkpoint; 5. 2017–2018 security, access, keys and implementation chain; 6. CAM credit, title, voting and payment chain; 7. funded-exit record and estate-value decision trail; 8. locales transaction and use of proceeds; 9. hotel income, operator and asset-control accounting; 10. RICPE/HNT/MYND/ORION/AGM related-party, provenance and diligence files; 11. certified court docket, access logs and judicial-reliance record; 12. coordinated Fiscalía, Policía Nacional and Guardia Civil preservation. ## 4. Public institutional questions ### Comunidad / Pamanil / Pamalexsha / continuing administrators Produce the original authority, debt, vote, accounting, custody, contract, personnel, file, key and bank record. Identify what moved from Pamanil to Pamalexsha, who authorised the transition and which records or functions continued. ### Campanario / Prieto / López Noriega / related professional perimeter Produce retainers, powers, instructions, conflicts, invoices and handovers. Identify the exact client and mandate for each meeting, claim, Community act and later corporate role. A professional relationship is not itself wrongdoing, but the missing file cannot be replaced by inference. ### Administrador Concursal Identify, proposition by proposition, what was received, when it was received, what was independently verified, what authority was used, what was authorised or delegated, what was reported to the court, what was done after notice and why the estate outcome was considered protected. ### CAM / JDAM / LPAM Produce the credit and title chain, beneficial-owner and mandate records, voting qualifications, instructions, access/security communications, purchase payments, project approvals, financing and the basis on which earlier Community and concurso outputs were adopted or relied upon. ### RICPE / HNT / MYND / ORION / AGM Produce title-provenance, related-party, conflict, board, investment-committee, due-diligence, valuation, financing, subsidy/incentive and operating records. Identify how known disputes, possession questions and Community/concurso provenance were treated. ### Court / LAJ / TSJC / CGPJ Preserve and certify the complete docket, index, filing and notification history, access/audit logs, recordings, received documents and the exact material before each decision-maker. Judicial reliance cannot be inferred without the record actually received. ### Fiscalía / Policía Nacional / Guardia Civil Prevent fragmentation. Preserve the private, professional, Community, corporate, banking, court and digital evidence as one connected record while assigning act-specific responsibility. ## 5. Right of correction and response Every named actor, entity and institution should be invited to provide: - corrections of identity, date, capacity or quotation; - primary documents omitted from the Project record; - lawful-authority records; - contrary or exculpatory evidence; - mandate, invoice, power, minute, decision or account evidence; - an explanation suitable for publication alongside the relevant allegation. A correction must update the same immutable actor ID, graph edge and action ID. It must not create an unlinked duplicate narrative. ## 6. Future-thread rule A future thread working on the 2011 hijacking, alleged insolvency fraud, shadow/de facto administration, AC enablement or Acosta Matos convergence must begin by loading: 1. `archive/CRIMINAL_FIRST_UNITARY_REVERSE_ENGINEERING_2011_TO_PRESENT_25AUG2026.md`; 2. Declaration 012; 3. Declaration 013; 4. `assets/data/acosta-matos-functional-convergence-map-v2.json` and its component files; 5. `assets/data/matter-identity-registry-v1.json` and its five parts; 6. `assets/data/criminal-first-institutional-action-matrix-v1.json`; 7. this protocol. It must then re-check `main`, the live public routes and newly received evidence. When a record strengthens, limits or refutes an allegation, update the existing actor ID, edge ID and action ID rather than generating a disconnected theory. ## 7. Public routes - Spanish action hub: `/es/hipotesis-criminal-unitaria-2011-presente/accion-institucional/` - English action hub: `/en/unitary-criminal-hypothesis-2011-present/institutional-action/` - Spanish convergence graph: `/es/hipotesis-criminal-unitaria-2011-presente/convergencia-acosta-matos/` - English convergence graph: `/en/unitary-criminal-hypothesis-2011-present/acosta-matos-convergence/` - Spanish identity registry: `/es/registro-identidad-materia/` - English identity registry: `/en/matter-identity-registry/` **Canonical operational principle:** pressure is maximised when every recipient can see the exact evidence, the exact question, the exact missing record and the exact consequence—while no allegation is inflated beyond its current proof.