PROCEDURAL STATUS · NOT A MERITS CONCLUSION
The latest controlled status of this route is a provisional dismissal communicated on 21 July 2026. This page explains what that status means, what it does not mean, and why preservation of concrete evidence remains relevant without asserting that the proceeding will be reopened.
Provisionally dismissed · 21 Jul 2026
No presumed allocation: controlled 18 June intake material associates the AC complaint with handwritten daily reference 22, but the official allocation document proving that complaint became DP 1956/2026 has not been located. Until it is obtained, the references remain separate. The removal, remuneration and complaint digest controls any joint analysis. Open it →
The controlled record documents that DP 1956/2026 was opened and that the order communicated on 21 July simultaneously terminated the proceeding and ordered provisional dismissal.
That status should be published as exactly that: provisional dismissal.
Provisional dismissal does not turn the underlying allegations into established facts, but neither should it be described as an acquittal, a free dismissal or a final determination that the alleged events did not occur.
Editorial rule: this page does not publish or summarise private legal advice concerning later procedural choices. Status and possible legal consequences are explained only from public legal sources and controlled procedural material.
Actor-specific object
DP 1901/2026 is the separate criminal route in which Por Derecho has placed the alleged culpability of JDAM, LPAM, CAM / Acosta Matos entities and the other individually identified private actors, always subject to actor-specific proof. DP 1956/2026 does not automatically import those allegations.
The DP 1956/2026 question is different: what the Insolvency Administrator knew, what duty or power was engaged, what he verified or failed to verify, what he supplied to or withheld from the court, what result he implemented, maintained or failed to correct, and how he documented and accounted for it. Evidence may overlap in a limited way; culpability does not.
Public legal rule
Article 641 of Spain's Criminal Procedure Act governs provisional dismissal. Public guidance from the Spanish State Prosecutor General distinguishes that status from free dismissal and explains that, where the legal requirements are met, new data or evidence may permit an application to reopen a provisionally dismissed proceeding. Reopening is not automatic: it depends on the new material, the applicable legal requirements and a decision by the competent judicial body.
Practical consequence: preserving evidence today does not imply guilt and does not predict reopening. It means avoiding the loss of material that may need to be assessed later if a competent authority lawfully requires it.
Criminal Procedure Act · art. 641 (BOE) → · State Prosecutor General Circular 1/2021 (BOE) →
The useful question
More communications or repetition of an allegation are not enough. Any later change of status would need sufficiently concrete and legally relevant material. Categories that could require reassessment, without implying that any one would be sufficient, include:
A later ruling that establishes or materially clarifies a concrete act, duty, loss or causal relationship relevant to the perimeter already examined.
A document not previously in the proceeding that helps individualise knowledge, instruction, authority, accounting treatment, patrimonial destination or consequence of a concrete act.
A professional, regulatory or control decision establishing a specific factual proposition. The mere existence of another file is not enough.
Records held by professional firms or other custodians that provide new evidence about relationships, communications, files, conflicts, instructions or documentary traceability.
The useful perimeter should remain concrete. The working record identifies three document families for reconciliation, without presenting any of them as automatic proof of an offence:
Accounting bridge to reproduce: final texts → CAM offer / liquidation route approved 16 April 2018 → third-party improvement threshold → Provincial Court Order 78/2019 of 23 July 2019 → 2021 competitive process → credit actually extinguished → Protocol 457 → Registry/charge treatment → any surplus → final estate accounts; and, separately, the EUR 400,000 branch. EUR 9,052,251.69 (recognised credit), EUR 13,065,186.68 (six printed components), EUR 102,895.34 (the step from EUR 3,079,104.66 to the EUR 3,182,000 cap) and EUR 13,168,082.02 (stated threshold/consideration) have different functions. The former EUR 12.768m + EUR 400,000 decomposition is unverified and is corrected.
Boundary: the arithmetic identity of the cap step does not prove payability, fraud, falsity, double recovery or notarial knowledge. Identifying those clusters does not authorise a general or prospective investigation of the Insolvency Administrator's entire professional activity. The absence of the complete bridge from the current corpus does not prove that it does not exist; if it exists and reconciles the operation, it may support a lawful explanation.
A later report, production, correction, restitution or accounting reconciliation must be dated and preserved as a later event. It may reduce continuing harm or become genuinely new evidence. It does not rewrite what was done, omitted or known at the earlier date and must not be described either as retroactive exoneration or as proof of prior guilt.
Likewise, a supervisory response within Insolvency 36/2012 is not automatically a criminal merits determination in DP 1956/2026. Any later use must identify the exact new fact it establishes, its source, its date and its relevance to the legal elements being examined.
The July architecture treated it as the private-actor / Control 21 route. The 14 September order treats it as a proceeding for alleged judicial prevarication and records a 29 July prosecution report seeking dismissal. Until certified allocation/index records are obtained, the repository does not state which complaint originally generated DP 1901 or whether there was joinder, reassignment or error.
The 18 June 2026 complaint concerning specified judicial rulings/conduct and its later amplification were associated in intake material with daily reference no. 24. That reference is not a NIG or DP. The new identity collision requires the official destination/allocation trail; it does not justify automatic merger with DP 1901 or DP 1956.
A separate institutional and supervisory route. DI 169/2026 was archived and the CGPJ confirmed processing of Appeal 286/2026. That processing does not establish disciplinary infringement or criminal responsibility.
Provincial Court decisions may produce relevant facts or assessments, but a civil/insolvency ruling does not automatically become a criminal finding.
A separate professional/deontological route. Any decision must be read within its professional competence and for the particular fact it establishes.
RSM, Grant Thornton, CNMV, SNCA or other bodies may hold or produce evidence within their respective perimeters. Cooperation or findings do not by themselves establish criminal responsibility.
Interface rule: separate procedures; distinct objects and legal standards; connected knowledge; limited common evidence; coordinated preservation; individual attribution; no automatic joinder, collective culpability or waiver. DP 1956/2026 is not the forum for determining any eventual responsibility of the Mercantile judge, but a judicial ruling should not be allowed to absorb the Insolvency Administrator's own inputs, omissions, implementation or accounting.
Preservation and cooperation
They are not being asked to support an accusation. They are being asked to preserve documents within their perimeter, identify the correct entity or function and cooperate with any lawful, properly framed request from a competent authority, including a future request if the procedural status of DP 1956/2026 were to change.
The legal possibility of later reopening does not mean there is currently an application to reopen or that any future application would be granted.
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