20 July 2021
RICPE recorded 54 CAM, 190 LPB and 18 third-party properties, future/conditional CAM ownership, an unsigned LOI and full DD not begun.
INSOLVENCY → COMMUNITY → RICPE/RIC → HNT → GC/836/P06 → ERDF → MYND
The institutional chain must always return to the same hotel, assets, works and employment.
Each instrument has its own legal basis. That separation does not answer whether the same cost, property, value, job or availability was used more than once.
SUBSTANTIATED ALLEGATION · NOT AN AUDIT CONCLUSION
Project Sun Rock alleges double or triple funding and several institutional lives of the same Sun Park/MYND Yaiza hotel. The outstanding evidence must confirm or exclude overlap in assets, works, invoices, costs, value and employment between the Community, RICPE/RIC, HNT, the regional incentive and ERDF.
25 October 2026 · documented source and procedural update
Gil Marer’s filed account addresses document recovery, access and grant conditions
In Madrid supplement REGAGE26e00091804140 and CTBG supplement REGAGE26e00091804303, Gil Marer states that he recovered five document categories after the 24 October morning filings and describes a later CSV-bearing report occurrence, the April–June access record and distinct criteria versions. His filed account no longer maintains current non-obtainment of those copies. The receipts establish registration and inventory; they do not independently establish that recovery history. Historical availability and complete delivery remain open.
The individual actilla places the proposed ownership condition at the grant-validity endpoint; it does not transfer civil title or prove the condition met. The 7 June 2022 Ministry entry is not proof of the first valid regional application. Exclusion of demolition costs is a verification question, not proof of funded demolition or payment. The Dyrecto corporate channel is not proof of a person’s mandate or knowledge. Laura Patricia Acosta Matos remains the canonical identity.
The supplements preserve contrary April–June records and adverse judicial/fiscal decisions, maintain NO DESISTO in the independent CTBG claim and seek finite verification. Receipt and attachment identity do not establish admission, investigation, eligibility compliance or criminal responsibility. The complete dated correction is linked below; prior narrative remains as historical context.
The correct chain is not a sequence of seals validating one another
1 · InsolvencyLPB perimeter, estate, value and authority.
2 · ExtraconcursalMatkator and third parties: separate title and rights.
3 · CommunityAlleged 2018 refurbishment/finance.
4 · RICPE/RICProject, DD, valuation, approval and capital.
5 · HNT / GC/836/P06Beneficiary, investment, subsidy and 60 jobs.
6 · ERDFPercentage, expenditure, payment and control.
7 · MYNDCurrent use, revenue, employment and value.
Serial reliance: every gate must identify what it checked against original sources and what premise it inherited. A testimony, deed, registration, RIC suitability decision, grant award or ERDF plaque does not automatically resolve historic title, authority, earlier costs or absence of overlap.
Controlled data
RICPE / HNT
The controlled record attributes a €6,573,703.10 Series F/G total to the 2023 audited accounts; the exact split remains open.
GC/836/P06 + ERDF
Published investment €11,469,714, subsidy €3,440,914.20, 60-job commitment; ERDF expressly identified.
The matrix every authority should be able to answer
| Gate | What it had to check | What it cannot presume | Required production |
|---|---|---|---|
| IA / Court | LPB assets, value, authority and effect on estate/creditors | That an external project did not affect the insolvency or that third-party assets were absorbed | Complete index, filings, orders, communications and treatment of each finance/work life. |
| RICPE | Promoter, title, DD, valuation, conflict, approval, conditions and use | That the CAM/RICPE relationship or an acquisition expectation replaced title/authority | Policies, committee, board, recusals, waivers, contracts, drawdowns and monitoring. |
| AEAT / Canary RIC bodies | Investment, beneficiary, suitability and fiscal requirements | That fiscal suitability warranted every civil-title issue or excluded other support | Binding reports, decrees, memorandum, valuation, other sources and compliance. |
| Regional incentives | Beneficiary, availability, investment, eligible costs, finance and employment | That award proved final payment, absence of double funding or full compliance | GC/836/P06 file, aid declarations, costs, payments, checks and employment. |
| ERDF / controls | Percentage, eligibility, paid expenditure, certification, audit trail and cumulation | That the plaque alone proves amount, regularity or control outcome | Operation, certifications, invoices, verifications, audits, corrections and recovery. |
| MYND/HNT operator | Spaces, contracts, workforce, revenue, property/rights and financed assets | That integrated operation equals integrated ownership | PMS, inventory, contracts, payroll, revenue, property use and fixed-asset accounting. |
Double/triple-funding tests
Same invoice / work
Compare every invoice and works certificate across Community, RICPE/RIC, GC/836/P06 and ERDF.
Same employment
Compare the 60 jobs, alleged approximately 86 and actual workforce/FTE person by person and period by period.
Same asset / value
Compare properties, availability, valuations, security, post-works value and exclusion of LPB/Matkator/third-party assets.
Coexistence of instruments does not prove wrongdoing, but their legal separation does not prove absence of overlap. The result must come from a consolidated source-and-use statement, invoice table and employment table.
Alleged layers requiring native files
Community · ≈€4.5m
Full-refurbishment approval/commitment alleged for November 2018. Minutes, vote, authority, finance, works and IA/Court bridge remain required.
RICPE · ≈€4.9m / ≈86
June-2023 layer identified by Project Sun Rock. It must be reconciled with €6,573,703.10, its components and GC/836/P06.
Operation · ≈50 FTE
Alleged hotel requirement. Test through payroll, Social Security, rosters, outsourcing and hotel/group scope.
Orion is not the final link in this funds chain
RICPE founded Orion and a RICPE→Orion architecture is documented. Orion must remain a separate branch. No claim is made that RICPE/HNT finance, regional subsidy, ERDF, MYND revenue or LPB/Matkator value reached Orion without a specific bank, accounting or patrimonial bridge.
For Sun Park, the current Orion question is limited to how FMMM moved from a paid Sun Park/Community property-administrator role into the later Pamalexsha/AGM/Orion perimeter and what relevance that has to his duties, knowledge, independence or conflicts.
Required outcome
One reconciliation with seven tables: assets/rights; instruments; invoices/costs; employment; valuations; disclosure to each institution; and prerequisites/waivers. If there was no overlap, those tables should prove it. If overlap existed, they must quantify it and identify decisions, beneficiaries, controls, corrections and remedies.