# JV 1260/2011 → Rollo 793/2012 → AP Las Palmas Sentencia 89/2014
## Unitary reverse-engineering, claimant/counsel accountability and 2018 CAM convergence

**Date:** 17 August 2026  
**Status:** CANONICAL FORENSIC / INVESTIGATIVE CONTROL — SOURCE-LED, NOT A CRIMINAL FINDING  
**Scope:** 2008 CEXP formation → 2011 Community governance/debt/vote architecture → 23-Dec-2011 JV 1260/2011 claim → 23-Feb-2012 claimant-driven extension against Monterecco Sun Park, S.L. → qualified CEXP allanamiento → Sentencia 122/2012 → post-judgment 28-May-2012 key-delivery evidence → appeal 793/2012 → AP Sentencia 89/2014 → 18-May/23-May/31-May/7-Jun-2018 Community/CAM convergence.

## 1. Executive finding

This reverse-engineering materially strengthens the Project's case, but not by proving that the 2011 plaintiffs or their lawyer committed a crime.

The strongest source-supported proposition is more precise:

> A substantially continuous claimant/lawyer perimeter operated simultaneously inside Sun Park Community governance and outside it through litigation; by 22-Jun-2011 the same minority-owner perimeter appears in the ACTA as the effective voting-right perimeter while LPB's much larger represented coefficient is excluded; the same lawyer who represented most of that owner group acted as Secretary in the 2-Feb-2011 Community meeting, proposed procedural strategy there, and then signed the 23-Dec-2011 eviction claim and continued on appeal. The plaintiffs themselves later introduced Monterecco into the existing proceeding because of an alleged change in exploitation. First instance found no proof that Monterecco possessed or exploited the 18 units. The appeal reversed that result after admitting a post-judgment 28-May-2012 key-delivery event. Contemporaneous material describes those keys as CEXP maintenance copies being returned pursuant to CEXP's qualified allanamiento. The complete notarial act and the plaintiffs' actual appellate evidential filing remain keystone evidence before the Project can responsibly classify that transition as maquinación fraudulenta or estafa procesal.

The later CAM connection is now direct and documentary, but it must not be projected backwards as proof that CAM caused the 2011 litigation:

> On 18-May-2018 Laura Acosta Matos represented CAM and Borja Rodríguez-Batllori represented LPB at the Sun Park Community meeting. The ACTA's separate voting-right list contains only the AMENEM/Shaila Cogolludo 0.385% line. The meeting then approved the Community security/access-control mechanism unanimously by those entitled to vote. AMENEM was one of the original JV1260 corporate plaintiffs. A separate registry chain shows Finca 8718 — a different Sun Park unit formerly held by TENGOLF/AMENEM — transferred to CAM by deeds of 23-May and 31-May-2018. Seven days later came the documented 7-Jun-2018 material-control event.

Accordingly, the current classification is:

- **ordinary underlying owner grievance:** materially supported;
- **integrated Community-governance / litigation architecture:** VERIFIED;
- **debt → voting exclusion → minority decision mechanism:** VERIFIED as an ACTA-recorded mechanism; legal validity remains a separate question;
- **claimant-originated procedural equation CEXP → Monterecco:** VERIFIED;
- **first-instance absence of proof against Monterecco:** VERIFIED;
- **post-judgment key event used as appellate possession evidence:** VERIFIED;
- **maintenance-key context materially relevant to that appellate inference:** STRONGLY SUPPORTED by contemporaneous records, but complete notarial act remains open;
- **later CAM convergence through the same owner/Community perimeter:** VERIFIED / STRONGLY SUPPORTED;
- **CAM participation in, direction of or agreement concerning the 2011 litigation:** NOT ESTABLISHED;
- **maquinación fraudulenta / estafa procesal by claimants or counsel:** OPEN INVESTIGATIVE HYPOTHESIS — elements not yet closed.

## 2. The 18-unit claim: claimant-by-claimant map

The 23-Dec-2011 pleading identifies seven plaintiffs and 18 units:

| Claimant | Pleaded unit/apartment labels | Count |
|---|---:|---:|
| Acciones Canarias, S.L. | 907, 553 | 2 |
| Muruga, S.L. | 504 | 1 |
| Roque Prieto, S.L. | 509 | 1 |
| Amenem, S.L. | 404, 405, 406, 407, 408, 454, 455, 456, 457, 458 | 10 |
| Amenem, S.L. + Tengolf, S.L. | 453 | 1 |
| Miguel Molina Betancor | 911 | 1 |
| Francisco Luis Molina Molina | 503, 908 | 2 |
| **Total** |  | **18** |

The claim says that from July 2008 CEXP took the keys `manu militari`, possessed and tourist-exploited the units without title or payment, and that the owners had expressly rejected repeated invitations to join CEXP.

The pleading relies principally on:

1. Community-administrator certificate mapping physical/unit/registry numbering;
2. registry notes for the 18 units;
3–4. Cabildo tourism communications about unitary tourist exploitation;
5. 25-Mar-2010 tourism inspection complaint;
6–9. sanction-file 92/11 materials;
10. 3-Jan-2011 private detective report;
11. Community certificate alleging CEXP non-payment of Community charges relating to the claimant units;
12–15. February/March 2010 notarial key-delivery/access demands and responses;
16. IBI/value material.

### Evidential consequence

The original claim was facially a possession action, not an action adjudicating the validity of the 2011 Community government, debts or voting exclusions. But its factual and documentary foundations were intertwined with the same Community/CEXP architecture. Later readers must not treat the resulting judgment as if it separately adjudicated every upstream governance proposition.

## 3. 29-Apr and 26-May-2008: the origin story cannot be reduced to an unexplained July 'manu militari' event

The primary 29-Apr-2008 ACTA records 84.988% present/represented and the collective creation of CEXP. The five corporate plaintiffs later appearing in JV1260 were present or represented:

- Tengolf;
- Acciones Canarias;
- Muruga;
- Amenem;
- Roque Prieto.

Representatives of Muruga, Amenem and Roque Prieto expressly raised reservations. The final recorded vote was 74.90% in favour and 10.01% against/reserving and therefore not participating. The ACTA presently recovered does not identify the 10.01% unit by unit. It expressly frames participation as open/voluntary.

The 26-May-2008 Montelanza–CEXP instrument then records a formal cession of exploitation of the Sun Park hotel complex to CEXP, while its detailed operation continues to refer to apartments/locals integrated or ceded into exploitation.

### Current conclusion

These 2008 sources **do not yet prove** that CEXP had title to exploit every one of the later plaintiffs' 18 units. They do, however, materially qualify any later description of the origin as though CEXP simply appeared and seized keys in a factual vacuum. The five corporate plaintiffs were already participants or represented participants in the formal governance meeting that created the exploitation vehicle and at least three openly articulated reservations.

The decisive missing evidence is the unit-level accession/non-accession schedule and exact identity of the 10.01% that did not participate.

## 4. 2-Feb-2011: Álvaro Campanario was a governance actor as well as later litigation counsel

The 2-Feb-2011 Community ACTA significantly changes the actor map.

The ACTA records Álvaro Campanario Hernández as representing virtually the future JV1260 claimant perimeter, including units of Acciones Canarias, Amenem/Tengolf, Francisco Molina, Miguel Molina and Muruga; Roque Prieto was separately present/represented in the meeting perimeter.

When the existing Community President/Secretary were absent, Campanario explained the need to appoint meeting officers. Asunción Aizpurúa was appointed to preside and **Campanario himself became Secretary of the meeting**.

Campanario then explained a separate challenge brought by owners he represented against the 25-May-2009 Community resolutions, including the alleged deprivation of voting rights and Community-fee issues. He proposed that the Community **allanarse** to that challenge; the ACTA records approval.

The meeting then elected Asunción Aizpurúa President representing Roque Prieto, appointed other officers and authorised litigation/procurador powers.

### Accountability conclusion for Campanario

This is a strong, non-speculative proposition:

> Campanario cannot be treated as a lawyer who encountered the Sun Park dispute only when drafting JV1260. Primary evidence places him inside the Community's governance and litigation architecture ten months before the 23-Dec-2011 claim, representing most of the same claimant group, acting as meeting Secretary and proposing procedural strategy.

That establishes **knowledge opportunity, role continuity and integrated legal/governance participation**. It does **not**, by itself, establish that he knowingly made a false statement or intended to deceive a court.

For criminal/procedural culpability, the missing questions are actor-specific:

- Did Campanario know that a material statement in the claim or appeal was false or materially misleading?
- What did he know about the 2008 accession/participation position of each unit?
- What did he know about the status and purpose of the maintenance keys?
- What exact representation did he make when the 28-May-2012 evidence was placed before the AP?
- Did any misrepresentation cause the AP's reversal?

## 5. 22-Jun-2011: primary evidence of the debt → vote → authority mechanism

The 22-Jun-2011 ACTA records:

- Asunción Aizpurúa as President;
- Francisco Mario Matos Matas as administrator;
- LPB represented with a very substantial majority coefficient;
- a separate list of **owners entitled to vote after verification that they were up to date in Community obligations**.

That voting-right list substantially reproduces the later JV1260 claimant perimeter: Roque Prieto, Francisco Molina, Acciones Canarias, Amenem, Amenem/Tengolf, Muruga and closely associated units/persons. LPB does not appear in the voting-right list despite its much larger represented coefficient.

The same meeting discusses/reframes historic Community/CEXP costs and debts, including the proposition that there was no alternative but to claim Community quotas, and then uses the voting-right perimeter to approve measures concerning debts/recovery, the CEXP maintenance relationship, Pamanil administration and other governance matters.

### Strongest public-safe allegation

> The recovered ACTA documents a mechanism in which the same minority-owner perimeter that would shortly bring JV1260 appears as the effective voting-right perimeter, while LPB's much larger represented interest is outside that list, at the same meeting in which historic debt attribution and recovery are being recalculated and governance authority is exercised.

This is a **documented mechanism**. Whether the debt was legally valid, whether the voting exclusion complied with horizontal-property law, and whether any person knowingly fabricated debt or authority require separate legal and evidential proof.

## 6. 23-Dec-2011 claim: strongest challenge to its factual framing

The strongest investigation is not whether the plaintiffs had any legitimate grievance — the source set shows real disputes, repeated demands and evidence capable of supporting a genuine owner-possession concern.

The question is whether the pleading's origin narrative was **materially incomplete or selectively framed** in a way that mattered to the court.

The pleading's strong formulation — CEXP took the keys `manu militari` from July 2008, without title or payment, despite repeated refusals to join — must be tested against:

- the plaintiffs' presence/representation at the 29-Apr-2008 CEXP-creation meeting;
- their actual unit-by-unit accession/non-accession position;
- the 26-May-2008 cession structure;
- all payments/distributions or absence thereof;
- their later 2009–2011 Community litigation and governance activity;
- the distinction between holding a maintenance copy and excluding an owner from possession;
- the exact detective and notarial evidence.

### Current grade

**MATERIAL OMISSION / MISCHARACTERISATION RISK: STRONG INVESTIGATIVE ISSUE; INTENT NOT PROVED.**

## 7. 23-Feb-2012: the plaintiffs themselves created the procedural bridge to Monterecco

The one-page amendment is especially important because it shows who initiated the equation.

It says that the plaintiffs had learned the previous day of a **change in exploitation of the complex** and therefore **expanded the demand** against the new exploitation company Monterecco Sun Park, S.L. It invokes the same address/telephone/fax and registry/change-of-exploitation documents and carries forward the original claim.

The amendment also describes the original defendant using an `S.L.` formulation even though CEXP is a distinct Community/exploitation body. Treat this as an entity-identity error requiring explanation, not proof of fraud.

### Canonical conclusion

`PLAINTIFF_ORIGINATED_PROCEDURAL_EQUATION` = **VERIFIED**.

But the precise legal mechanism remains to be reconstructed from the procedural order admitting the amendment:

- additional defendant?
- procedural succession?
- alleged new possessor?
- continuation of exploitation?

Do not call it a corporate conversion.

## 8. CEXP's allanamiento: a major correction against an over-aggressive theory

The AP judgment itself records that CEXP filed an allanamiento but **expressly rejected the plaintiffs' assertion that CEXP had been exploiting the 18 apartments**. It nevertheless placed copies of keys at the owners' disposal at reception.

Contemporaneous incoming-side legal correspondence, preserved as non-public litigation context, indicates that Gil/Patricia/Garrigues themselves considered/instructed an allanamiento because they did not oppose the owners receiving their apartments/keys. The keys were described as maintenance copies and delivery was considered a CEXP responsibility.

### Required correction

Current evidence does **not** support an allegation that the plaintiffs secretly controlled, procured or collusively manufactured CEXP's allanamiento.

The forensic issue is different:

> Was the qualified allanamiento — return the keys/possession while expressly denying the alleged exploitation — later flattened into a broader factual admission that CEXP had possessed/exploited the units and then passed possession to Monterecco?

## 9. Sentencia 122/2012: the first court found no proof against Monterecco

The 7-May-2012 first-instance judgment:

- accepts CEXP's allanamiento and decrees the requested possession/key relief against CEXP;
- does not convert CEXP's qualified factual denial into an express merits finding that CEXP had tourist-exploited the units;
- records Monterecco's defence that it operated only LPB units, did not possess the plaintiffs' units and had no such CEXP relationship;
- **finds insufficient proof against Monterecco and absolves it**, with costs against the plaintiffs on that branch.

This is the controlling baseline before the appeal.

## 10. AP 89/2014: the reversal turns on a post-first-instance evidential event

AP 89/2014 accurately records the procedural history, including the qualified CEXP allanamiento and the first-instance rejection against Monterecco.

The appellants argued that the evidence showed both CEXP and Monterecco effectively possessed the apartments and requested veil lifting based on close links with LPB.

The AP then relies materially upon an **acta notarial of 28-May-2012 admitted as new evidence in second instance**, after the first-instance judgment. It reasons that the plaintiffs' keys were at reception; Monterecco was then the tourist operator; Monterecco had copies of the keys which CEXP `al parecer` had handed to it and Monterecco accepted; and this helped justify the amendment and establish possession. The court also relies on earlier Pedro Coll statements concerning unitary tourist exploitation and on entity/personnel links.

It ultimately reverses the Monterecco result and applies veil-lifting reasoning.

### Forensic importance

The decisive transformation is therefore not simply:

`2011 facts → 2014 judgment`.

It is:

`2011 pleaded possession theory`
→ `CEXP qualified allanamiento`
→ `first instance: no proof against Monterecco`
→ **`28-May-2012 post-judgment key-delivery event`**
→ `AP inference of Monterecco possession / close instrumental relationship`
→ `reversal`.

## 11. The maintenance-key discrepancy: strongest current procedural-overreading hypothesis

Contemporaneous material located during this pass includes sheets expressly headed substantially **“ENTREGA DE LLAVES DE MANTENIMIENTO”** / CEXP maintenance keys. Incoming counsel correspondence likewise treated them as CEXP maintenance copies to be returned to the owners pursuant to the CEXP allanamiento, while discussing Community emergency-copy retention.

The key sheet also contains unit-number cross-mappings/ambiguities. A contemporaneous incoming-side communication records that an incorrect apartment list was initially signed and that at least one LPB apartment number/key was delivered instead of another numbered unit, requiring correction.

### Strongest defensible allegation now

> There is a serious source-based question whether a remedial return of **maintenance copies** following CEXP's qualified allanamiento was later treated on appeal as affirmative proof that Monterecco possessed the plaintiffs' apartments. If the complete 28-May notarial act and the appellants' evidence filing show that the maintenance/remedial character was omitted, materially misstated or knowingly transformed into a different possession narrative, that could materially strengthen a maquinación/fraude-procesal analysis. On the present record, the inference is not yet enough to attribute deception to a specific claimant or lawyer.

This is currently the highest-value P1 evidential gap.

## 12. Actor-specific accountability — do not use collective guilt

### 12.1 Álvaro Campanario Hernández — HIGH INVESTIGATIVE RELEVANCE

**Verified role facts:**
- represented most/all of the future JV claimant perimeter inside the 2-Feb-2011 Community meeting;
- became Secretary of that meeting;
- explained his clients' pre-existing Community litigation and proposed an allanamiento strategy;
- later signed/ran the 23-Dec-2011 JV1260 claim;
- remained plaintiffs' lawyer on appeal.

**Strong allegation:** integrated governance/litigation role and first-hand access to the underlying Community context.

**Not established:** knowing falsehood, intent to deceive, manipulation of evidence or criminal agreement.

### 12.2 Manuela Cabrera de la Cruz — PROCEDURAL REPRESENTATIVE / LOW CURRENT SUBSTANTIVE CULPABILITY

Verified as the procuradora in the original claim/amendment. No present evidence establishes that she originated or knew any false substantive proposition. Do not infer guilt from filing representation.

### 12.3 Araceli Colina Naranjo — APPEAL PROCURADORA / LOW CURRENT SUBSTANTIVE CULPABILITY

AP record identifies her on the appeal. Actual appeal and new-evidence filings must be recovered before assessing any role in the characterization of 28-May material.

### 12.4 Asunción Aizpurúa — HIGH GOVERNANCE / KNOWLEDGE RELEVANCE

Not a named JV plaintiff, but central to the 2011 Community architecture:
- President installed 2-Feb-2011 representing Roque Prieto;
- leads 22-Jun debt/reallocation/voting/governance process;
- involved in the later key-return context.

Her role is highly relevant to knowledge and provenance, but no criminal conclusion follows merely from office-holding or adverse decisions.

### 12.5 The seven plaintiffs — MIXED / ACTOR-BY-ACTOR RECONSTRUCTION REQUIRED

**Good-faith evidence:** longstanding owner complaints; key/access demands; tourism complaint; detective evidence; genuine disagreement over exploitation/possession.

**Adverse investigative evidence:** integrated Community-governance role; debt/vote mechanism; very strong 2011 litigation/governance coordination through common counsel; claimant-originated Monterecco extension; potential overbreadth in the `manu militari` origin framing.

No collective criminal culpability is presently established.

## 13. The 2018 CAM connection — documentary convergence, not retroactive conspiracy

### 13.1 18-May-2018 Community meeting

The primary ACTA records:

- AMENEM/Shaila Cogolludo — one unit / 0.385%;
- LPB — approx. 72.976%;
- Antonio Cogolludo — local interest;
- CAM — approx. 13.034%;
- Borja Rodríguez-Batllori representing LPB;
- Laura Acosta Matos representing CAM;
- total present/represented approximately 86.715%.

But in the separate section identifying **owners with voting rights after checking Community-payment status**, the ACTA lists only the AMENEM/Shaila Cogolludo 0.385% line.

The meeting then considers LPB/Borja's request concerning unauthorised access/occupation and authorises Community security/access control up to the stated monthly limit, repeatedly recording approval unanimously by those present with voting rights.

### Evidential significance

AMENEM was one of the original JV1260 plaintiffs. The recovered record therefore documents this continuity:

`2011 claimant-owner perimeter`
→ `2011 debt/voting-right architecture`
→ `2011–2014 possession litigation`
→ `18-May-2018 claimant-linked owner line is the only line listed as entitled to vote`
→ `security/access mechanism approved`
while `CAM/Laura + LPB/AC Borja are present/represented`.

That is a **direct institutional/governance bridge** between the flagship case perimeter and the 2018 control architecture.

It is not proof that Amenem, CAM, Laura or Borja shared a criminal plan.

## 14. Finca 8718: direct claimant-company → CAM title continuity immediately before 7 June

A separate registry chain concerns **Finca 8718 / apartment 180 / unit 222**, which is not one of the 18 JV1260 litigation units.

The prior-title record identifies a Tengolf/Amenem ownership perimeter. The later registry note records CAM acquisition in two steps:

- 33.33% by deed dated **23-May-2018**;
- 66.67% by deed dated **31-May-2018**.

This title consolidation occurred immediately after the 18-May meeting and before the documented **7-Jun-2018 material-control event**.

### Current high-value sequence

`18-May-2018: claimant-linked 0.385% line is only listed voting-right line; CAM/Laura and LPB/Borja present`
→ `Community security/access control approved`
→ `23-May: first CAM acquisition share in Finca 8718`
→ `31-May: remaining CAM acquisition share`
→ `7-Jun: documented material-control event`.

This is a highly material **convergence sequence** requiring transaction, communication and consideration evidence.

Do not state that the sales funded, rewarded or were consideration for the 18-May vote unless primary evidence proves that proposition.

## 15. What can now be alleged strongly

### Allegation A — Integrated claimant/counsel governance–litigation architecture

**Status: STRONGLY SUPPORTED / PRIMARY-DOCUMENTED STRUCTURE.**

The same lawyer represented the future claimant perimeter inside Community governance, acted as meeting Secretary and proposed Community procedural strategy, then represented the plaintiffs in the eviction claim and appeal.

### Allegation B — Debt/vote filtering enabled minority decision authority

**Status: PRIMARY-DOCUMENTED MECHANISM; LEGAL VALIDITY OPEN.**

The 22-Jun-2011 ACTA shows LPB's large represented interest outside the voting-right list and a claimant-linked minority perimeter inside it at the same time historic debt attribution and governance measures were being approved.

### Allegation C — The 2011 claim's origin narrative may have omitted material 2008 context

**Status: STRONG INVESTIGATIVE HYPOTHESIS.**

The `manu militari` framing must be reconciled with the formal April/May 2008 creation/cession process known to the corporate claimants and with unit-by-unit participation status.

### Allegation D — Plaintiffs created the procedural equation by which Monterecco was brought into the existing case

**Status: VERIFIED.**

The 23-Feb-2012 amendment itself proves the initiative came from plaintiffs after learning of a change in exploitation.

### Allegation E — The appeal may have transformed a remedial maintenance-key return into proof of Monterecco possession

**Status: STRONGEST OPEN PROCEDURAL-FRAUD / OVERREADING HYPOTHESIS.**

The AP uses the post-judgment 28-May key event to reverse first instance. Contemporaneous records describe the keys as CEXP maintenance copies. The complete notarial act and appellate filing are required to attribute any mischaracterisation to a person.

### Allegation F — The 2011 claimant perimeter later converged with CAM's 2018 access/control architecture

**Status: VERIFIED CONVERGENCE; INTENT/AGREEMENT OPEN.**

Amenem-linked 0.385% is the only line listed with voting rights at the 18-May-2018 meeting where CAM/Laura and LPB/Borja are present and the security mechanism is authorised. Tengolf/Amenem title in separate Finca 8718 then passes to CAM by 23/31-May before 7-Jun.

## 16. What cannot responsibly be alleged yet

Do **not** presently publish as fact that:

- the plaintiffs committed estafa procesal;
- Campanario knowingly deceived either court;
- the 28-May notarial act was falsified;
- CAM caused or financed the 2011 litigation;
- CAM had an agreement with the plaintiffs in 2011;
- the CEXP allanamiento was secretly procured by the plaintiffs;
- Finca 8718 was consideration or reward for a vote/security decision;
- AP 89/2014 was corrupt or knowingly unlawful.

Each requires additional actor-specific evidence.

## 17. Legal characterization control

Use three separate frameworks:

1. **LEC art. 247** — procedural good faith, manifest abuse of right, fraud of law/procedure;
2. **LEC art. 510.1.4** — extraordinary civil review where a final judgment was unjustly obtained through maquinación fraudulenta, requiring a malicious procedural mechanism and causal effect/indefensión, not merely a wrong legal route or an adverse judgment;
3. **CP art. 250.1.7** — criminal estafa procesal where evidence is manipulated or analogous procedural fraud causes judicial error and a prejudicial resolution.

The Supreme Court's 23-Oct-2024 desahucio-precario revision ruling is an important limiting comparator: use of an allegedly inappropriate procedural route is not itself maquinación; the stronger category requires a malicious act that prevents or materially distorts defence. Other Supreme Court revision cases show that concealment of material facts/identity known to the claimant can qualify where it actually produces procedural defenselessness.

For JV1260, the present legally material question is therefore not `the plaintiffs used a desahucio action`, but:

> Did a claimant or representative knowingly withhold, distort or re-characterise material facts/evidence — especially the origin/participation context or the maintenance-key event — in a way that materially caused the appellate court to infer Monterecco possession and reverse the first-instance result?

That element is not closed yet.

## 18. P1 keystone evidence queue

Recover before any promotion of the criminal/procedural-fraud grade:

1. complete **11-Jun-2012 appeal brief** (AP record identifies f. 706–716);
2. filing/motion by which the **28-May-2012 notarial act** was offered/admitted in second instance;
3. complete **28-May-2012 notarial act** (AP identifies f. 718 et seq.);
4. complete **11-Jul-2012 Monterecco opposition** (AP identifies f. 818–821);
5. CEXP's actual qualified **allanamiento filing** (f. 656–657);
6. complete 2008 unit-by-unit CEXP accession/non-accession schedule for each of the 18 units;
7. exact identity of the 29-Apr-2008 10.01% non-participating vote;
8. full Doc 10 private-detective report and Doc 11 Community certificate from the original claim;
9. proof of what appellants/counsel knew about the maintenance-key character when the new evidence was submitted;
10. the 23-May and 31-May-2018 Finca 8718 sale deeds, consideration, instructions and communications;
11. systematic registry scan for any additional JV1260 plaintiff/person/company → CAM transfers;
12. communications around the 18-May-2018 security vote and 7-Jun control event.

## 19. Publication / website instruction

The flagship case page should now show a visibly separate **Reverse-engineered finding** layer:

### Documented chain

`2008 CEXP formation`
→ `2-Feb-2011 counsel/governance integration`
→ `22-Jun-2011 debt/vote filter`
→ `23-Dec-2011 JV1260`
→ `23-Feb-2012 claimant extension to Monterecco`
→ `qualified CEXP allanamiento`
→ `7-May-2012 no proof against Monterecco`
→ `28-May maintenance-key/remedial event`
→ `13-Jan-2014 AP reversal`
→ `18-May-2018 claimant-linked voting line + CAM/AC presence`
→ `23/31-May Finca 8718 → CAM`
→ `7-Jun material control`.

### Investigative question

> Did a legitimate owner-possession dispute become, through the integration of governance, debt/vote filtering, claimant-driven procedural equation and later treatment of post-judgment evidence, a broader institutional proposition that was subsequently usable far beyond the narrow original 18-unit dispute?

### Criminal gate

> Serious procedural-fraud questions are now source-based, but no criminal finding is made. The appellate brief and complete 28-May notarial act are required before attributing deception or intent to a claimant or lawyer.

## 20. Deletion continuity

A new thread must recover from this file:

1. the full 18-unit claimant map;
2. all five corporate plaintiffs' presence/representation at 29-Apr-2008 CEXP formation;
3. Campanario's 2-Feb-2011 governance + claimant-representation + Secretary role;
4. the 22-Jun-2011 debt/vote filtering mechanism;
5. the plaintiffs' 23-Feb-2012 Monterecco extension;
6. the corrected understanding of CEXP's qualified allanamiento;
7. first-instance no-proof finding as to Monterecco;
8. AP's use of 28-May post-judgment key evidence;
9. maintenance-key context as a P1 discrepancy, not a proved fraud;
10. Amenem-linked 0.385% as the only line listed with voting rights at 18-May-2018 meeting with CAM/Laura and LPB/Borja present;
11. Finca 8718 Tengolf/Amenem → CAM on 23/31-May-2018, separate from the 18 lawsuit units;
12. 7-Jun-2018 as the later material-control threshold;
13. no present proof that CAM directed the 2011 litigation or that any named claimant/lawyer committed a crime.

**Deletion-safe once merged to `main`, subject to the P1 evidence queue above.**