1 · Protection of the estate
The claimant says Sun Park was a hotel and productive unit material to LPB's estate and asks what inventory, access, preservation, valuation, expert, revenue-recovery and control measures followed documented warnings.
2 · The 2018 funded exit
The complaint presents the ONA/Clubotel alternative and Stoneweg/Varia, Elaia/Lagoon and other financing routes as a possibility requiring a payoff figure, coordination and temporal protection. What reached the administrator, what he transmitted to the Court and what response he gave must be verified.
3 · Material control from June 2018
A shift in access, keys, security, guests and operation is alleged. The correct examination is act by act: title, instruction, affected space, actor, administrator knowledge, response and effect on LPB, Matkator and third parties.
4 · OB REM transaction and €400,000
The complaint connects the 28 November 2018 deed, the 20 March 2019 validation request, the 24 October 2019 order and later banking, accounting, registry and restitution treatment. It does not say the money disappeared; it asks for complete traceability.
5 · Promontoria–CAM assignment
It asks which assignment version and schedules the administrator held, which price or allocation method he knew, how he promoted substitution of creditor, what happened to Preliminary Disclosure 1041/2017, and how the title was later reconciled with the operative amount.
6 · Credit, threshold and final amount
Recognised credit, mortgage cap, interest, improvement threshold, realisation value, alleged write-off, extinguished credit and possible surplus must be distinguished. Different numbers do not prove an offence; they require the documentary and accounting bridge.
7 · 2021–2022 bidding and adjudication
The complaint seeks reconciliation of the bidding appearance, offers, publicity, third-party access, orders, the 25 January 2022 report, the 21 February deed, release of charges and registry entries.
8 · Final accounts
The evidential close requires the general ledger, CAM sub-account, €400,000 supports, final accounts, banking annexes, objections, approval or pending status, and correspondence with assets removed or transferred.