# DECLARATION 013 — GIL MARER ATTRIBUTED FUNCTIONAL CONVERGENCE INTO THE ACOSTA MATOS PERIMETER

**Declarant:** Gil Marer  
**Date:** 25 August 2026  
**Status:** ATTRIBUTED PARTY POSITION WITH SOURCE-GRADED SUPPORT — NOT AN ADJUDICATED FINDING OF CONSPIRACY, SUCCESSION OR CRIMINAL LIABILITY  
**Scope:** 2011 Community claimant/governance/legal perimeter → Pamanil/Pamalexsha and Community-administration continuity → Prieto/Cogolludo corporate bridges → CAM credit, title, voting, security and material-control capacities → Acosta Matos / RICPE / HNT-MYND / later corporate perimeter.

## 1. Gil Marer's attributed proposition

Gil Marer states that the private actors and structures involved in the alleged 2011 capture or reconfiguration of the governing organ of the Comunidad de Propietarios Sun Park did not disappear as an unrelated historic faction. His position is that they progressively **“morphed” into the Acosta Matos perimeter**.

The word **“morphed”** is preserved as Gil's metaphor for an alleged process of:

- functional succession;
- convergence of roles;
- continuity of representation and administration;
- transfer or accumulation of title, voting and creditor positions;
- adoption of the earlier Community machinery by later CAM/Acosta Matos actors;
- continuation of knowledge, documentation and practical control through overlapping people and entities; and
- eventual concentration of benefit, project control and operating position in the later Acosta Matos/CAM/RICPE/HNT-MYND structure.

It does **not** mean that every named person became legally identical to CAM, that every company merged into an Acosta Matos company, or that a single criminal agreement is already proved.

## 2. Strongest defensible formulation

The strongest present formulation of Gil's allegation is:

> The claimant, Community-governance, legal and administrative perimeter visible in 2009–2011 progressively converged, through identifiable people, entities, titles, representations, corporate offices, voting mechanisms and later transactions, with the CAM/Acosta Matos perimeter that acquired credit, units, Community influence, security/access capacity, material control and later project benefit. The evidence is strongest for several direct bridges and supports a serious continuity and ratification investigation. It remains weaker or open for a universal handover, one uninterrupted legal entity, a common criminal purpose from 2011, or the direct incorporation of every earlier actor into the later perimeter.

## 3. Direct documentary bridges

### 3.1 Original claimant/owner perimeter → later CAM title and voting route

The controlled JV 1260/AP 89 reconstruction identifies AMENEM and TENGOLF within the original claimant perimeter. The 18 May 2018 Community voting record contains the AMENEM/Shaila Cogolludo 0.385% line as the effective vote-qualified interest identified in that control. A separate title chain records Finca 8718, formerly associated with TENGOLF/AMENEM, transferring to CAM by deeds of 23 and 31 May 2018, immediately before the 7 June 2018 material-control event.

**Grade:** `DIRECT DOCUMENTARY CONTINUITY / FINCA-SPECIFIC`.

**Limit:** this does not prove that every original claimant transferred to CAM, that CAM directed the 2011 litigation, or that the 2011 owners shared CAM's later purpose.

### 3.2 Community/Molina legal perimeter → Prieto Puente → Antonio Cogolludo

The controlled record places Juan Carlos Prieto Puente representing Asunción Aizpurúa Sánchez / Roque Prieto and later appearing as a Community/Molina-side lawyer. Official company records then place Prieto and Antonio Cogolludo Rojas together as administrators of SANTA LUCIA REAL ESTATE, S.L., with Antonio later becoming sole administrator and Prieto becoming an attorney-in-fact.

**Grade:** `DIRECT REPRESENTATION CHAIN + DIRECT CORPORATE BRIDGE`.

**Limit:** the company bridge does not itself prove a Sun Park mandate, unlawful coordination, knowledge transfer or criminal purpose.

### 3.3 Antonio Cogolludo → Pamalexsha / Noalpa / Community offices

Official records identify Antonio Cogolludo Rojas as initial sole administrator of PAMALEXSHA SERVICIOS INTEGRALES, S.L. and EXPLOTACIONES NOALPA, S.L. The Sun Park record places Antonio representing Molina-linked interests and later holding Community office during the 2017–2018 security/access period.

**Grade:** `DIRECT CORPORATE + COMMUNITY CAPACITY CONTINUITY`.

**Limit:** each Sun Park act, title, power and instruction must still be established separately.

### 3.4 Pamanil → Pamalexsha functional transition

The 22 June 2011 ACTA records Pamanil in the governance/administration sequence. Communications in 2014 identify Francisco Mario Matos Matas and Shaila María Cogolludo Ramos in the Pamanil/Community perimeter. The 2016 Community materials then include a Pamalexsha administration budget and later sources continue to identify Pamalexsha in Community administration/secretarial functions.

**Grade:** `DOCUMENTED FUNCTIONAL TRANSITION`.

**Limit:** no merger, universal succession, complete assignment of contract, files, funds, keys or obligations has yet been proved.

### 3.5 FMMM continuity into the later Acosta Matos-linked corporate perimeter

The controlled record places Francisco Mario Matos Matas in Community/Pamanil administration from 2011, directly exposed in 2016 to the accounting, governance, concurso and creditor-transfer issues, and continuing as secretary-administrator in the 2017–2018 Community/security structure. Official 2024 records then identify FMMM and José Daniel Acosta Matos as directors of ORION RENTAL SOCIMI, S.A. and identify FMMM as a power-holder of AGM CANARY ASSET MANAGEMENT, S.L.

**Grade:** `STRONG DIRECT PERSONAL AND CORPORATE CONTINUITY`.

**Limit:** later office does not prove that FMMM acted with an Acosta Matos purpose in 2011 or that knowledge was criminally shared.

### 3.6 Community/AC implementation channel → CAM reliance and benefit

The controlled insolvency record documents an AC-originated request for Community security, Community implementation of security/access functions, AC authorisation or acknowledgement of identified access routes, Community-generated debt/certification material adopted or used in the concurso, and later CAM reliance on the same Community/AC structure. CAM subsequently combined creditor, unit-owner, Community-participant, bidder/purchaser and project capacities.

**Grade:** `DOCUMENTED FUNCTIONAL CONVERGENCE AND MUTUAL RELIANCE`.

**Limit:** coordination and reliance are not by themselves proof of a secret criminal agreement.

### 3.7 2022 Community/project convergence

The later Community record identifies direct Acosta Matos voting, José Daniel Acosta Matos in the presidency, continued FMMM secretary-administrator/banking functions and approval of the CAM project and works.

**Grade:** `DIRECT LATER-STAGE CONVERGENCE`.

**Limit:** a 2022 configuration does not retroactively prove the state of mind or agreement of every actor in 2011.

## 4. Actor-by-actor convergence grades

| Actor / structure | Bridge into later Acosta Matos perimeter | Present grade | Principal limit |
|---|---|---|---|
| AMENEM / TENGOLF claimant perimeter | 2018 vote/title chain and CAM acquisition of a traced unit | direct, finca-specific | no universal claimant-to-CAM transfer proved |
| Asunción Aizpurúa / Roque Prieto perimeter | Aizpurúa → Prieto representation → Prieto/Antonio company bridge | strong functional/representational chain | no direct Acosta mandate or benefit proved for Aizpurúa |
| Juan Carlos Prieto Puente | Community/Molina role → SANTA LUCIA with Antonio | direct | no proof that SANTA LUCIA acted in Sun Park or carried a criminal purpose |
| Esteban López Noriega | Community-side role → professional partnership with Prieto | direct to Prieto; indirect to Acosta axis | no direct Acosta Matos company/mandate located |
| Antonio Cogolludo Rojas | Molina representation → Pamalexsha/Noalpa/Santa Lucia → Community presidency/security period | direct and strong | act-specific authority and title remain necessary |
| Shaila María Cogolludo Ramos | Pamanil communications → 2018 vote/title line → later Noalpa/Pamalexsha powers | mixed direct/strong continuity | later powers cannot be backdated |
| Francisco Mario Matos Matas | 2011 Community/Pamanil → 2016 knowledge → 2018 implementation → 2024 ORION/AGM with JDAM | direct and strongest personal continuity | later corporate role does not prove original criminal intent |
| Pamanil / Pamalexsha | administration/document function carried across changing provider labels | functional transition supported | legal succession and complete asset/file transfer open |
| Álvaro Campanario Hernández | original owner/governance/litigation architecture | direct historic role; later convergence open | no direct Acosta company, instruction or handoff proved |
| Francisco de Borja Rodríguez-Batllori Laffitte | alleged adoption, delegation, reliance and enabling of the converging perimeter | separate AC-enablement hypothesis | he is not automatically a private member of the Acosta Matos perimeter |
| CAM / JDAM / LPAM | credit, title, Community, access/control and later project axis | direct later perimeter | each instruction, asset and benefit remains actor-specific |

## 5. What the evidence permits—and does not permit—the project to say

### Supported as a serious allegation

- the earlier Community/claimant structure and the later Acosta Matos perimeter are connected by multiple independent bridges;
- some bridges are personal, some corporate, some title-based, some voting/governance-based and some functional;
- later actors adopted, relied upon or benefited from machinery originating in the earlier Community dispute;
- knowledge and documents may have travelled through continuing actors, particularly where direct exposure and later office are established;
- the convergence is relevant to ratification, causation, benefit, conflicts, independent verification and alleged shadow administration.

### Not yet established

- a literal merger of all actors into one company or legal group;
- that every named actor shared one purpose;
- that Campanario formally handed a plan or file to Prieto, López Noriega, CAM or the Acosta Matos family;
- that the Acosta Matos actors directed the 2011 takeover;
- that later corporate association proves earlier criminal intent;
- that every Community act or transaction was unlawful;
- that Rodríguez-Batllori was himself part of the private Acosta Matos perimeter rather than an allegedly enabling officeholder;
- a single uninterrupted criminal conspiracy from 2011 to the present.

## 6. Criminal-investigation significance

Functional convergence can be relevant to criminal analysis where it helps prove, actor by actor:

- continuity of knowledge;
- continuity or adoption of a false or contested premise;
- identity of the person who controlled a document, vote, title, instruction or asset;
- ratification of earlier acts;
- material assistance or indispensable contribution;
- concealment or failure to disclose a conflict;
- causation and beneficiary identity;
- de facto/shadow management of discrete estate functions; and
- whether later conduct supplies corroboration of an earlier purpose.

It cannot substitute for proof of the required mental element. Later convergence is corroborative context, not automatic retrospective proof.

## 7. Evidence required to close the convergence map

Priority evidence includes:

1. native 2009–2012 client files, powers, retainers and handover communications;
2. certified 2011 ACTAs, attendance, powers and complete accounting/debt material;
3. Pamanil and Pamalexsha contracts, bank records, files, keys, invoices, personnel and transition records;
4. complete Prieto/López Noriega retainers, invoices, conflicts/dispensas and client instructions;
5. historic Registry/deed/payment chains for AMENEM, TENGOLF, Roque Prieto, Montelanza/Molina and CAM acquisitions;
6. native CAM credit-assignment and mandate records;
7. Community elections, title qualifications and voting ledgers for 2017, 2018 and 2022;
8. AC communications, authorisations, diligence, conflict disclosures and independent verification records;
9. 7 June 2018 calls, messages, video/photo originals, security/locksmith instructions and payment trail;
10. RICPE/HNT/MYND, ORION and AGM conflict, governance, due-diligence and related-party records.

## 8. Future-thread instruction

Future threads must treat this declaration as Gil Marer's attributed convergence theory and then use the structured convergence map to grade every edge as:

- `DIRECT_DOCUMENTARY`;
- `STRONGLY_SUPPORTED_FUNCTIONAL`;
- `ATTRIBUTED_INFERENCE`; or
- `OPEN_NOT_LOCATED`.

They must never convert the metaphor “morphed” into an undocumented legal merger or use one actor's bridge to transfer knowledge, intent or criminal responsibility to another.

**Canonical boundary:** the evidence supports a substantial multi-bridge convergence investigation. It does not yet establish universal absorption or one continuous criminal agreement.