Separate responsibilities. One connected economic and evidential reality.

Subject: Request for inter-Bar deontological coordination, determination of institutional route, preservation and time-defined response — Sun Park / MYND Yaiza — ICALPA DIP 79/2026 and DIP 80/2026 / ICATF / ICAM 1487/26

Dear President, Secretary and members of the competent body of the Consejo Canario de Colegios de Abogados,

My name is Gil Marer. I write in my own name and in the legitimate interests of Aweswell Limited and Matkator, S.L., in connection with the Sun Park / MYND Yaiza matter and the professional-regulatory files and communications already existing before several Bars. I also act as a reporting person / whistleblower in relation to matters already notified to public authorities, invoking the safeguards applicable under Law 2/2023 where relevant.

This communication does not ask the Consejo Canario to merge legally distinct disciplinary matters, to predetermine misconduct, or to decide criminal, insolvency or judicial liability outside its competence. It asks for a clear regional institutional route for connected professional-conduct questions that are already distributed across more than one territorial Bar and that share a substantial evidential and economic context.

The context is important. Our position begins with the Aweswell / LPB / Matkator / Sun Park business platform and an alleged staged displacement of practical control beginning in 2017–2018. The evidence we have preserved does not jump from that period to the later 2022 adjudication/formalisation: it includes a 31 January 2019 Acosta Matos web capture presenting “Hotel Lava Verde”, at the Sun Park address, among “Hoteles propios”; 2019–2020 pilot-room and whole-hotel refurbishment activity; 2020 CAM / Meeting Point project discussions; and the November 2020 RIC Private Equity investor presentation of Sun Park before HNT / MYND formalisation. The later Acosta Matos / RICPE-linked hospitality ecosystem then expanded materially in hotels, rooms, employment, turnover, investment vehicles, international brands and public-support interfaces.

Gil Marer’s present provenance allegation is that 100% — not a lesser percentage — of the later asset, income, commercial-relationship, reputational/institutional-access and capital-access position of the Acosta Matos / RICPE-linked perimeter derives directly or indirectly from that displaced platform. I do not ask the Consejo Canario to accept that proposition as proved. It is the reporting party’s causal/provenance allegation, and each asset, income stream, relationship, professional act and recovery route must be independently tested. Nor do I ask the Council to infer wrongdoing from employment, investment, professional advice, public support or institutional relationships. The concern is that the later accumulation of legitimate jobs, investment, operating income, professional mandates and public interfaces can create economic embeddedness and moral-hazard incentives that make independent historical scrutiny more, not less, important.

The professional-regulatory position is already inter-Bar in fact, not merely in theory.

1. ICALPA DIP 79/2026 concerns the CAM-side professional presentation and use of CAM, Community and RICPE-related material. It was opened on 27 May 2026 and remains a distinct preliminary matter.

2. ICALPA DIP 80/2026 concerns the professional conduct of the court-appointed Insolvency Administrator of Luchy Playa Blanca, S.L.U., including what he independently verified, adopted, reported, protected, implemented and accounted for from the position of the debtor and estate. It was also opened on 27 May 2026 and remains separate from DIP 79.

3. ICATF is separately relevant to Tenerife-based lawyers and to communications already made concerning former counsel and professional-custody questions.

4. In Madrid, ICAM Preliminary File 1487/26 expressly ordered, on 1 July 2026, that the decision and a copy of the file be sent to the territorially competent professional body in Tenerife in respect of acts considered outside Madrid. We are still seeking certification of the actual transmission, receipt and Tenerife reference.

5. The evidential perimeter also involves former or later professional environments including PwC / Landwell, San Telmo / RSM, Garrigues, Cuyás / Grant Thornton and Cuatrecasas. Their presence does not create collective liability. It creates finite questions of mandate, knowledge, former-client duties, conflicts, custody, preservation, payment/source of funds and document migration which must be addressed actor by actor.

There is also a preventive procedural-integrity issue that we already raised expressly with ICALPA on 10 June 2026. At that time we did not allege that pressure or interference had occurred inside the Bar. We identified a structural risk: a file connected with large economic, professional and institutional interests may attract informal approaches, third-party calls, attempts to learn the rapporteur’s preliminary view or other non-procedural communications. We therefore requested reinforced safeguards of independence, confidentiality, traceability and non-interference. Consistently with that position, we now ask that any rapporteur, investigator or responsible person appointed by the Canary Council be conflict-cleared in advance, independent in fact and appearance, genuinely willing to pursue the necessary finite enquiries, and given sufficient institutional backing to resist any informal contact or pressure that may arise. If any materially relevant external approach occurs, we ask that it be logged and that any representation or document enter only through a formal, traceable and contradictable channel. This is a preventive request designed to protect the Council and the rapporteur; it does not assert that such contacts have occurred.

For that reason, I respectfully ask the Consejo Canario:

(a) to acknowledge receipt, assign a reference and identify the organ or person responsible for considering this communication;

(b) to state whether it considers that the matters should remain procedurally separate while being subject to a common regional framework for evidential preservation, competence, referral and traceability;

(c) to identify the proper regional route for recurring deontological questions that are not confined to one individual file or one constituent Bar;

(d) to explain what participation, abstention or recusal safeguards will be applied where the matter concerns the handling of files or conduct within a constituent Bar whose officeholders also participate in the Consejo Canario;

(e) before appointing any rapporteur or instructor for this matter, to carry out and document an adequate conflict check and review of relevant professional, economic or institutional relationships; and to ensure that the person appointed has sufficient independence, continuity, time and institutional backing to carry the matter through to a reasoned outcome. We do not assert that any particular pressure will occur. We do ask, in light of documented historical episodes of professional pressure within this same perimeter, that any call, informal approach, representation or material contact outside the file by an interested or connected person be logged and channelled into the formal record, avoiding non-traceable decision paths;

(f) to indicate whether the Council considers that any part of the matter should be referred, consulted or otherwise brought to the Consejo General de la Abogacía Española, and by what route;

(g) to preserve, within the lawful scope of its powers, the institutional and professional-regulatory records necessary to maintain the distinction between individual responsibility and common evidence; and

(h) to provide a written and time-defined institutional route, even if its initial response is only to identify competence, the next procedural step and a reasonable timetable for further analysis.

Given the current nature of the matters and the existence of active professional, judicial and prosecutorial tracks, I would be grateful for acknowledgement and identification of the responsible organ/person within three working days of receipt.

I would also be grateful, if possible, for an initial substantive response within ten working days of receipt, even if that first response consists only of confirming the institutional route considered appropriate, any coordination or preservation measures regarded as necessary, and a reasoned timetable for further analysis. I do not present those periods as statutory deadlines or as an ultimatum. The purpose is to obtain a clear, traceable and time-defined institutional indication.

In parallel, and with full respect for the competence of each body, we are preparing a separate communication for the Consejo General de la Abogacía Española on the genuinely national or inter-Bar questions. We are aware of the CGAE response RS-001022/2026, which stated that the Consejo General does not hear ordinary individual complaints against lawyers at first instance. The national communication will therefore not ask the CGAE to replace the territorial Bars or the Consejo Canario; it will ask only about the national/systemic and inter-Bar dimension that may properly fall within its functions.

I would be grateful if this communication could be formally recorded and if any reply could be given in writing so that the institutional route remains fully traceable.

Yours faithfully,

Gil Marer
for himself and in the legitimate interests of Aweswell Limited and Matkator, S.L.
Official correspondence: sbu001@monterecco.com