COUNSEL HISTORY CORRECTION · INSIDE + OUTSIDE THE INSOLVENCY

Luis Miguel López Gómez: what was actually filed, preserved and pursued?

The located record changes an important explanatory premise. Former LPB counsel cannot accurately be reduced to “they did not challenge the liquidation”. Under Luis Miguel López Gómez (ICAM 71.483), LPB repeatedly challenged the calculation inputs, treatment of earlier filings, auction/adjudication mechanics and access to appellate review.

Correct forensic question. What did each former adviser identify, preserve, file and pursue; what corrective route was legally available; what response followed; what failed to reach merits review; and where, if anywhere, did strategy, timing, evidence, exhaustion or follow-through fall short?
Completeness boundary. This is the corpus located or positively identifiable in the controlled repository/Gmail/Drive review as of 30 August 2026. It is not a certified complete denominator of every filing ever made. The court/LAJ certified chronological and per-piece index remains P0.

Located / identifiable filing-remedy lineage

#Date / forumFiling or remedyControlled statusPrincipal significance
11 Dec 2020 · JM1 · S05Allegations on CAM interest calculationLexNET receipt 1202010372434856Challenged timing/finality of interest input used in liquidation/bid mechanics.
21 Dec 2020 · JM1 · S05Allegations on AC / Community claimsLexNET receipt 1202010372438581Placed the AC/Community calculation issue formally before the court.
3Jan/Feb 2021 · JM1Reposición against Auto 25 Jan 2021Filed; later court disposition confirms. Exact receipt still to isolate.Expressly alleged both 1-Dec filings had been ignored “as if they simply did not exist”; invoked incongruencia omisiva and challenged interest/Community inputs.
4Feb 2021 · JM1Exceptional nullity incident — 2019/2020 liquidation-order familyFiled/admitted; exact receipt/final version pendingArticle 24, patent error, reasoning/exhaustiveness and legality of the direct-realisation route.
519 May 2021 · JM1Protesta preserving objectionsLater filed pleading recites prior filingPreserved issues for later appeal.
624 May 2021 · JM1Reposición against Providencia 12 MayFiled; later disposition confirms. Receipt pending.Challenged in-person licitación against quoted plan safeguards: BOE Portal, 20 days, publicity/current data and deposits.
731 May 2021 · JM1Reposición against Auto 18 MayFiled; later disposition confirms. Receipt pending.Core plan-compliance objection: third-party bidder notice/offer, CAM improvement/deposit, absence of plan-compliant auction and definitive CAM approval.
88 Jun 2021 · JM1 → APAppeal against Auto 6 MayFiled; later inadmission/Queja confirmsCarried the omitted-filings, maxima, Community, overvaluation, loss-of-opportunity and par-conditio issues toward higher review.
922 Jun 2021 · TCFirst located constitutional amparo, RA 4268/2021Filed; TC proceeding and later inadmission locatedConstitutional exhaustion/access-to-review track.
105 Jul 2021 · JM1Allegations on publicity / market interferenceSource + filing receipt located; exact receipt metadata still being folded into canonical registerRequested AC report, protection against transfer pending review and reopening with plan safeguards; reserved civil/criminal action.
117 Jul 2021 · APQueja 740/2021Filed copy located; AP outcome locatedSought appellate fiscalización of definitive liquidation acts; AP 16-Nov-2021 later became part of the appealability lineage.
1220 Jul 2021 · JM1Allegations / new-document productionSource copy located; formal receipt to reconcileAsked the court to consider new material affecting sale/subasta and to revisit the route with plan safeguards.
132 Jan 2022 · JM1Protesta preserving objectionsLater filed pleading recites prior filingPreservation for later appeal.
144 Feb 2022 · JM1 · S05Protesta against 26-Jan clarification AutosSent LexNET 202210466939566 · ack 1202210466939566Expressly preserved disagreement and announced direct/deferred appeal.
1528 Feb 2022 · JM1 → APAppeal — two 15-Oct-2021 Autos and preserved earlier decisionsLexNET 202210473582179 · hash 094fbdbd…Principal attempted merits-review bridge for the May/Oct liquidation sequence.
1628 Mar 2022 · AP Sec.4Queja 375/2022Filed copy + later AP proceeding locatedExpressly argued that liquidation acts contrary to plan-approval orders must be reviewable and that de facto plan change should not evade formal modification.
1716 Jan 2023 · AP Sec.4Exceptional nullity incident — Queja 375/2022Sent 202310547846140 · ack 1202310547846140Continued Article 24 / access-to-review challenge after Queja dismissal.
182023 · TCSecond constitutional amparo, 2811/2023Petition + TC proceeding/inadmission locatedExplicitly preserved the May-2021 auction/adjudication and reviewability questions through constitutional exhaustion.
192 Nov 2023 · calificaciónLPB appeal against judgment 163/2023Counsel contemporaneously confirmed filing; exact LPB appeal/receipt not yet located in reviewed threadDo not misattribute the Gil/Pink appeals that were mistakenly re-sent in that email chain. Recover LPB's native appeal before publishing its substantive grounds.

Why this matters to the judge/LAJ analysis

The primary chronology demonstrates that the plan-compliance and review-access issues were raised repeatedly before the eventual outcome. That strengthens a knowledge/notice inquiry. It does not prove that the judge or LAJ deliberately concealed anything, or that every submission was legally well-founded. The next question is what the court and LAJ actually did with each filing and whether the available appellate route ever produced merits review of the definitive-adjudication objections.

Open the plan / judge / LAJ compliance audit →

Former counsel: neither blanket excuse nor scapegoat

An adverse outcome is not proof that counsel failed. A filed pleading is not proof that counsel exhausted the best available strategy. Every team must be audited using the same chain: mandate → knowledge → advice → draft → filing → receipt → evidence supplied → remedy → court/LAJ response → further challenge → outcome → strategic alternative.

Accordingly, possible shortcomings by former lawyers remain open, but they must be measured against the filings they actually made and the procedural environment they encountered.

Current Sixto representation

The later Sixto representation should be described by documented method rather than comparative rhetoric. The located record supports a more source-controlled, issue-separated sequence including formal substitution, document packs, AC-removal/fees work, access/information requests and later procedural analysis. Each Sixto filing should be subjected to the same receipt → decision → challenge → implementation test. No public page should imply that current counsel automatically adopts every Por Derecho allegation.

Machine register and next recovery objects

Full machine-readable filing inventory → · Controlling counsel/judge/LAJ governance →

P0 recovery remains: missing native receipts for the Jan/Feb-May/Jul-2021 families; native 19-May-2021 and 2-Jan-2022 protest filings; AP receipts for both Quejas; exact LPB 2-Nov-2023 calificación appeal; and reconciliation against the certified chronological/per-piece docket.