INSTITUTIONAL FIRST READ
Test the finite record before evaluating the wider allegation.
Use the same controlled evidence base to inspect source status, contrary material, procedural scope and open gaps.
Boundary. Navigation does not establish joinder, receipt, admissibility, knowledge, reliance, wrongdoing or merits.
When the allegations reversed, did the scrutiny reverse too?
A documented reconstruction of what Spain's Public Prosecution Service knew, what it did, what changed later and what remains unanswered. We do not ask readers to adopt our theory; we ask for a process whose independence, scope and reasoning can be verified.
The story in 60 seconds
The turning point: reversal of roles
2013
Information/economic theory from the insolvency-side context
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Public Prosecution Service
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Gil / Patricia investigated
2018
Gil / Aweswell complain about conduct involving the insolvency administrator / CAM / private perimeter
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Public Prosecution Service
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What independently verifiable scrutiny did the reversed hypothesis receive?
The question is not whether different complaints had to produce the same outcome. It is whether the direction of scrutiny could change when the direction of the allegations changed.
Two causal explanations that should be capable of comparison
Was value improperly displaced from LPB?
The complaint constructed a criminal hypothesis around the LPB–operator relationship, rent/consideration, corporate structure and possible prejudice to LPB and creditors.
What caused or aggravated LPB's economic weakness?
Gil/Patricia's complaints focused on Community governance, voting exclusion, debt attributed to LPB, hotel-wide operating costs, unitary exploitation, access/keys and minority-owner interference.
Is there a document showing that the prosecution service genuinely compared these two explanations of the same economic deterioration?
The standard: knowledge → response → consequence
“No response identified in the reviewed record” does not mean “no response existed”. “Happened afterwards” does not mean “was caused by”.
One number that requires a caveat
97 registrations do not mean 97 investigations
The REG-AGE control contains 75 individually enumerated receipts. A later source reports 97 records in total—90 received and 7 rejected—so 22 remain aggregate-only pending row-level recovery. That demonstrates breadth of notice/registration, not that every annex was personally read or that every matter received substantive investigation.
Separately, the public index independently rows all 156 located mailbox events—101 inbound, 42 outbound, ten self-archives and three unsent drafts. With the 75 receipts and 65 differentiated official acts, notices or correspondence events, the linked register contains 296 event rows. They are related proof layers, not 296 distinct matters.
RECEIVED ≠ EXAMINED ≠ INVESTIGATED ≠ DECIDED ON THE MERITS.
Unitary communications register · Public mailbox index · Source-artifact register
The institutional route
Las Palmas / Arrecife
DI 248, DI 113, DI 22 and later territorial referrals form part of the historical core.
Canary Islands Superior Prosecution Office
DIP 2/2026 and later communications raise questions of correction, scope and supervision.
FGE / Anti-Corruption
Superior and specialist communications demonstrate institutional activity; the public question is what cumulative examination each route actually produced.
GUB 86/2026
The Audiencia Nacional prosecution office dealt with competence and referred the matter to Arrecife. We describe this as routing, not a merits decision.
Territorial competence may be legally correct while leaving a separate question open: who ensures that accumulated evidence is reviewed as a whole?
Las Palmas Provincial Prosecutor's Office: unitary inside/outside-insolvency matrix
Personal attribution is limited to identified acts. Ricardo de Mosteyrín Sampalo signed the 12 March 2019 classification opinion; Elena Herrera Rodríguez signed the substantive 7 May 2019 DI 248/2018 archive decree; Beatriz Sánchez Carreras signed the 16 May notice, not that decree. Beatriz did sign the 8 February 2023 DI 113/2022 archive, the 23 February 2026 copy decision and the February/March 2026 DI 22 decisions. The judgment proves institutional prosecution attendance at the 25 July 2023 hearing; Gil's eyewitness identification of Ricardo is a separate direct source awaiting official individual certification.
| Track / perimeter | Source-controlled act | Documented response or effect | Gap and next control |
|---|---|---|---|
| Inside insolvency · classification 2019–2023 | Opinion signed by Ricardo de Mosteyrín on 12 March 2019; institutional attendance at the 25 July 2023 hearing. | The adverse prosecution frame remained operative in the classification track. The page does not publish an individual 2023 identity as official fact while certification remains missing. | Certify the prosecutor present, corpus and treatment of later facts; follow the RPL 2523/2025 evidence map. |
| Insolvency/extra-insolvency bridge · DI 248/2018 | Gil/Aweswell complaint against the insolvency administrator/CAM; archive decree signed by Elena Herrera on 7 May 2019; later notice signed by Beatriz Sánchez. | The reversed hypothesis was archived while the adverse prosecution classification position was being formed. Concurrence does not prove cause or agreement. | Certified file and requested/performed step matrix by actor, asset, date and conduct. |
| Control, works and title representations · DI 113/2022 | Archive signed by Beatriz Sánchez on 8 February 2023 and copy decision dated 23 February 2026; the decree refers to DP 668/2021. | The modules were treated as already judicialised/placed before the insolvency judge and as disclosing no indicia; the further copy was refused for the reasons stated in the act. | Complete file/index, primary DP 668/2021 chain, investigative steps and actor–asset–date–conduct matrix. |
| Multi-route package · DI 22/2026 | Beatriz Sánchez signed the 11, 13, 16 and 19 February and 2 and 3 March archive/joinder decisions. Acts dated 3 and 30 June and 8 July are attributed only to the office: their signatures have not been verified. | Classification as confused, repetitive, civil/insolvency-related, judicialised, insufficiently concrete or not materially different; later material was absorbed into the already archived container. | Complete index and submission/referral/module versus treatment matrix; signatures for the June/July acts. |
| Extra-insolvency / judicial · procedural identity under audit · DP 1901/2026 | 12 July order linked to DIP 2/2026; 14 September order records a 29 July prosecution report seeking dismissal and orders final dismissal/archive. | A concrete dated prosecutorial act is now documented, but the signed report is not produced. The Control 21 private and daily reference no. 24 judicial intake routes also require allocation reconciliation. | 29 July report, author, source corpus, reasoning, assignment, transmission index and Control 21 / daily reference no. 24 allocation file. |
What this message does not ask readers to ignore
Prosecutors considered there was a sufficient basis to bring the 2013 complaint. The 2014 complaints used highly accusatory language and some legal characterisations may have been weak or contestable. Prosecutors are not obliged to perform every investigative measure requested. Territorial referrals can be legally correct. There is a materially adverse first-instance insolvency culpability judgment under appeal. And later adverse decisions do not themselves prove bias, capture or collusion.
Our question survives those concessions; it does not depend on concealing them.
Ten questions that can be answered with documents
Seven rules for reading the record without converting questions into accusations
REFERRED ≠ INVESTIGATED
ARCHIVED ≠ VALIDATION OF EVERYTHING BEFORE IT
RELATED ≠ IDENTICAL
INSOLVENCY CONTEXT ≠ EVERY ASSET IS INSOLVENCY PROPERTY
LATER ≠ CAUSED BY
INSTITUTIONAL KNOWLEDGE ≠ PERSONAL KNOWLEDGE BY EVERY PROSECUTOR
The public thesis
We do not assert as established fact that the Public Prosecution Service was “captured”. We ask whether an early allocation of credibility, repetition of inherited frames, fragmented files and territorial return could produce functional instrumentalisation even if no individual intended that outcome.
The strongest institutional answer would not be a simple denial. It would identify the review, record, investigative measures and reasoning through which the system can show that it corrected its own frames when the evidence changed.
Formal open letter
Read the full message
We do not ask for a favourable outcome; we ask for a verifiable process
This letter does not ask the Public Prosecution Service to believe our account. It asks it to test our account and to test with the same rigor the accounts, conduct and documents of every other relevant actor.
We do not say every complaint must proceed, every requested step must be performed or every territorial referral is improper. We ask that “the same facts” be tested by date, actor, conduct, asset, injured party and evidence; that LPB, Matkator, the Community and operators not be conflated; and that earlier decisions not turn their factual premises into propositions immune from later evidence.
We do not ask prosecutors to believe us. We ask them to scrutinise us rigorously—and to scrutinise those we identify with the same rigor.
The first frame and the reversal of roles
In December 2013 the Public Prosecution Service filed a criminal complaint against Gil Marer and Patricia Domínguez arising from DI 273/2013. The primary reconstruction now published shows an AC→prosecution chain and a theory mixing 2008–2011 architecture with later 2012–2013 acts; it is therefore audited by actor, date, capacity and evidence, without treating the complaint as truth or claiming that everything predated arrival. In March 2014 those same accused parties submitted an extensive documentary counter-narrative to the Arrecife prosecution office concerning Community governance, minority owners, debt, voting, exploitation and costs. That file was archived in May 2014. In 2018, while the earlier route remained alive, Gil/Aweswell complained about conduct attributed to the insolvency administrator, CAM and other actors.
Can the Public Prosecution Service demonstrate that when the direction of the allegations reversed, the direction of scrutiny reversed with it?
New evidence, new events and distinct perimeters
“Same facts”, “civil/insolvency” and “already judicialised” can be legally correct categories, but they require demonstration. A 2022 transaction could not literally have been investigated in a 2019 archive. Matkator property does not automatically enter LPB's insolvency estate because it sits within the same complex. Community authority over common functions does not itself establish authority over every private space.
Relationship between facts is not identity of facts.
Territorial competence and reconsideration
Territorial competence may legitimately explain many referrals back to Las Palmas/Lanzarote. But deciding which office is competent does not necessarily answer whether later evidence and contradictions received cumulative and independent assessment.
Unity of action should not become unity around an uncorrected factual premise. Hierarchical dependence should not mean hierarchical inheritance of error.
What we ask
We ask for an identifiable and documented review of the complete route; an identity matrix before any renewed “same facts” conclusion; certified reconstruction of DI 248/2018; the final DP 332/2014 order; primary review of the 25 April 2019 rent expert report; identification of treatment after the DIP 2/2026 correction; the prosecution report and subsequent order in DP 1901/2026; follow-through after GUB 86/2026; express separation of LPB, Matkator, Community and operator perimeters; and an answer to the cumulative institutional question.
An invitation to contradict us with documents
If an investigative step we have not located exists, identify it. If a referral included substantive examination, identify it. If facts we regard as distinct are legally identical, explain the identity by comparing their elements. If a contradiction was corrected, incorporate the correction.
We do not want to preserve errors because they favour our position. We want the record to be more accurate than any competing narrative.
The final question
Can prosecutors demonstrate that evidence arising after an archive was examined as new evidence when it truly was new?
We seek no privilege and no immunity. We seek legality, objectivity, impartiality, traceability and verifiable reconsideration.
The strongest answer to a concern about capture or instrumentalisation is not a declaration that it does not exist. It is a process through which that can be verified.
Verify before concluding
The Justice Map contains the institutional chronology, routing, evidence statuses and open questions. The public thesis is designed to be correctable as primary documents are added.
Project Sun Rock / Por Derecho · updated 31 August 2026.
CAEPR IDENTITIES · UNITARY COVERAGE
All 17 Public Prosecution Service members named in this perimeter are identity-confirmed^.
The census separates each identity, capacity and source without turning institutional membership into authorship of every prosecution act. It includes the dedicated record for Ricardo de Mosteyrín Sampalo^.