SRProject Sun RockCorporate continuity dossier

ORION RENTAL SOCIMI · GOVERNANCE / MANAGEMENT CONTINUITY · UPDATED 5 SEPTEMBER 2026

Orion Rental SOCIMI: the later corporate node that binds legacy actors to a wider board, manager, investors and market infrastructure.

Orion Rental SOCIMI is relevant to the Sun Park reconstruction because its public corporate structure places two actors already documented in the earlier Sun Park record — Francisco Mario Matos Matas and José Daniel Acosta Matos — inside a later listed-company board, while Orion's management is publicly identified as AGM Canary Asset Management and RIC Capital presents Orion as a RIC-backed investment project.

Temporal firewall. Orion was constituted in June 2023. It therefore cannot be treated as a participant in the 2011–2022 Sun Park events. Nor does board membership, investment, audit, market listing or professional service establish knowledge of, participation in, or responsibility for earlier alleged misconduct. Orion matters here as a later governance, disclosure, due-diligence and reputational-continuity node.

DOCUMENTED CORPORATE LINKS

What actually binds the actors — without inference.

Sun Park record 2011–2022 → FMMM as Community administrator / secretary-administrator and JDAM as 2022 chair / project actor → Orion board from 2024 includes FMMM + JDAM + Enrique Guerra Suárez and a wider group of businesspeople → AGM Canary Asset Management is appointed Orion's attorney and is publicly identified as Orion's manager → RIC Capital presents Orion / Hinojeros III as a RIC investment project → Orion accesses listed-company capital-market infrastructure and new investors.
Official / company self-publication

FMMM

Orion's current governance page identifies Francisco Mario Matos Matas as a board member and also as a board member of AGM Canary Asset Management. Project Sun Rock's earlier primary-source reconstruction separately documents FMMM in the Sun Park Community administration chain through 2011–2022.

Official / company self-publication

José Daniel Acosta Matos

Orion identifies José Daniel Acosta Matos as a board member, president of Grupo Acosta Matos and president of AGM Canary Asset Management. The Sun Park record separately places JDAM as chair of the 4 February 2022 Community meeting and as the project author described in those minutes.

Management bridge

AGM + RIC

BORME records AGM Canary Asset Management as Orion's attorney. RIC Capital's own project page identifies Orion Rental SOCIMI, S.A. as operator and AGM Canary Asset Management, S.L. as management, describing Hinojeros III as a private project intended to materialise RIC investment.

RecordDocumented factWhat it does not prove
BORME · 9 Apr 2024Orion moved from sole administrator to a board. The registered appointments included Francisco Mario Matos Matas, José Daniel Acosta Matos and Enrique Guerra Suárez, alongside Víctor Martí Gilabert, Ángel Medina Padrón and other named directors.No collective knowledge or liability; each director's knowledge, disclosure and acts must be proved individually.
BORME · 20 May 2024AGM Canary Asset Management, S.L. was registered as Orion's attorney.Appointment does not establish unlawful management or knowledge of Sun Park.
Orion governance · current captureFMMM, Enrique Guerra and JDAM are publicly presented on Orion's board; JDAM is also identified as AGM president and Guerra/FMMM as AGM board members.Corporate proximity is not proof of conspiracy, concealment or common criminal purpose.
RIC Capital · Orion projectRIC identifies Orion as owner/operator of Hinojeros III, AGM as management and an €8.5m project using private investment intended to materialise RIC.A RIC structure is not itself improper and is separate from the proof required for any Sun Park allegation.
BORME · 2 Jul 2026 capital increaseOrion announced a capital increase of up to approximately €2.5m, with rights and new shares handled through Portfolio / Euroclear structures and provision for discretionary allocation of remaining shares.Investors, Portfolio, Euroclear and other market participants are not thereby implicated in earlier disputes or alleged wrongdoing.

GIL MARER'S EXPRESS ALLEGATION / ANALYTICAL THESIS

“Predatory inclusion”: reputation and resources as a shield and a sword.

Gil Marer's words and thesis: the alleged repeat modus operandi is one of “predatory inclusion”: existing actors, after what Gil alleges was “clandestine non-compliance” accompanied by “chronic deliberate concealment” and “non-disclosure”, bring existing and new individuals and entities into a wider structure and cause their reputation, institutional credibility, capital, network, professional standing, muscle power and resources to be lent to the perimeter. In Gil's formulation, that can turn a new actor — even one not proved to know the underlying history — into a “forced collaborator” and into both a “shield and a sword”, an “illicit shield and an illicit sword”, protecting and advancing what he describes as the whole scheme or “house of cards.”

Attribution boundary. Those expressions are Gil Marer's allegations and analytical language. This page does not state as fact that Orion, its directors, investors, auditors, advisers, Portfolio, Euroclear or any other new participant was coerced, deceived, failed a legal duty, concealed information or knowingly joined an illicit scheme. The proposition is testable only actor by actor and disclosure by disclosure.

Why Orion is probative of the question, not the answer

The significance is structural. Two legacy actors from the Sun Park chronology appear in a later vehicle whose board includes additional established businesspeople and whose management, investment and market architecture extends the network well beyond the original dispute. That makes a finite due-diligence question unavoidable: what was disclosed to whom, when, by whom, and what did each recipient independently verify?

THE DISCLOSURE / DUE-DILIGENCE TEST

The “shield and sword” thesis only survives if the missing disclosure bridges can be proved.

1 · Legacy fact
What history existed?

Identify the exact Sun Park proceedings, complaints, judgments, appeals, ownership disputes, Community records, RIC-related questions and actor-specific allegations that existed before each Orion appointment, investment or market step.

2 · Disclosure
What was actually disclosed?

Board packs, conflicts registers, related-party files, subscription documents, investor memoranda, management contracts, legal opinions, audit correspondence, market disclosures and diligence requests must show the information supplied or omitted.

3 · Knowledge
What did each person know?

FMMM and JDAM must be tested against their own earlier documented roles. Enrique Guerra, Víctor Martí Gilabert and every other director must be assessed separately. Shared board membership cannot substitute for individual knowledge.

4 · Reliance / reputational effect
Was another actor's standing used?

Test whether investors, directors, advisers, auditors, public bodies or market infrastructure were invoked as reassurance, validation or leverage in another transaction or public narrative — and whether they had the material facts necessary to give that reassurance knowingly.

5 · Benefit and causation
What did the inclusion enable?

Trace capital, guarantees, finance, access to RIC, subsidies, contracts, permissions, market admission, publicity and counterparty confidence. A benefit must be linked to the alleged omission rather than inferred from chronology alone.

6 · Innocent alternative
What if the wider board knew nothing?

That possibility remains live. If a new director, investor or provider was not told material background and did not independently know it, the evidence may support Gil's concept of a “forced collaborator” as an unwitting reputational/resource layer — but it would not justify accusing that new actor of intentional wrongdoing.

Repository rule: “predatory inclusion” is not proved by networking density. It requires a sequence: legacy exposure → duty or practical reason to disclose → material omission or misleading presentation → entry of a new actor/resource → reliance or enabling effect → actor-specific benefit/causation. If those bridges are absent, the criminal or dishonest inference must be rejected or reduced.

The new actors are not presumed collaborators.

Orion's board publicly includes Víctor Martí Gilabert, Ángel Medina Padrón, Francisco López González, Anil Partap Harjani, Oscar Díaz Melián, Jesús Díaz Quintana, Manuel Padrón Padrón, Francisco Mario Matos Matas, Enrique Guerra Suárez and José Daniel Acosta Matos. The existence of a common board is a governance fact. It is not evidence that the other directors knew of or endorsed Gil's allegations concerning Sun Park.

That distinction is central to the thesis itself: if “predatory inclusion” occurred, some later participants may be relevant precisely because their reputation or resources were allegedly recruited without full disclosure. Their board packs, conflict checks and diligence records are therefore potentially exculpatory as well as probative.

Right of reply and correction. Orion Rental SOCIMI, AGM Canary Asset Management, RIC Capital, every director, investor, auditor, adviser, Portfolio, Euroclear and every person or entity mentioned may provide corrections, contrary evidence or exculpatory documents. Silence is not admission.

Interlinked repository routes

Community instrumentalisation
2011 onward: debt, voting, authority, records and propagation.Minutes 2011–2022
FMMM, JDAM and the documented pre-Orion chronology.CAM / Acosta Matos control record
Actor-specific allegations and evidential limits.7 June 2018
Material-control dossier and primary witness evidence.Material updates
Repository-wide evidential and procedural changes.Versión española
Mirror of this governance-continuity dossier.

PUBLIC CONTROL SOURCES

Sources used to fix the corporate facts.

External self-publication and registry records establish corporate facts within their scope. They do not adjudicate the Sun Park allegations. Project Sun Rock's earlier pages remain responsible for the underlying Sun Park record and its own evidential boundaries.

PD-SP-ORION-NOTICE-20260905 · 2026-09-05

Notices, sources and decisions — individual registration

Every date links to its event and source. Sending, receipt, registration, incorporation, review and decision are different states. Commercial proximity and receipt of allegations do not transfer criminal responsibility. Due diligence and subsequent conduct are tested actor by actor.

  1. Document / event
  2. Sent → received
  3. Review → decision
  4. Effects: separate proof
Portfolio Stock Exchange · OUTBOUND_COMMUNICATION

2024-12-07 · PD-SP-EVT-0159

Gil Marer sent an Orion disclosure complaint to Portfolio customer-service and contact functions. The message advances allegations concerning legacy actors and requests a compliance review.

The body names CNMV as a copied party, but the actual recipient metadata contains no CC recipients. This transmission does not establish delivery to CNMV, any breach or the truth of the allegations. Its use of prospectus is source wording, not a statement that CNMV approved a prospectus.

Fuente / Source PD-SP-SRC-0004

CNMV · OUTBOUND_COMMUNICATION

2024-12-09 · PD-SP-EVT-0160

A separate forward of the Orion complaint was sent to the CNMV information/reclamations route.

Sent-message evidence does not establish receipt, internal routing, review or acceptance of allegations.

Fuente / Source PD-SP-SRC-0005

CNMV · OUTBOUND_COMMUNICATION

2024-12-09 · PD-SP-EVT-0161

Another distinct forward of the Orion complaint was sent to the CNMV complaints service.

This is a separate transmission, not a second underlying complaint finding or proof of examination.

Fuente / Source PD-SP-SRC-0006

CNMV · OUTBOUND_COMMUNICATION

2024-12-09 · PD-SP-EVT-0162

A third separately timed forward was sent to the CNMV whistleblowing route used by the sender.

The outbound address alone does not prove that the communication entered a protected case, was examined, or established wrongdoing.

Fuente / Source PD-SP-SRC-0007

Portfolio / named individual escalation · OUTBOUND_COMMUNICATION

2024-12-10 · PD-SP-EVT-0163

Gil forwarded the Orion/CNMV material to Martin Graham and requested confirmation of safe receipt.

A sent individual escalation does not establish that its recipient read it or circulated it to the full Portfolio board. The recipient's capacity is not inferred from the email address.

Fuente / Source PD-SP-SRC-0008

Portfolio Stock Exchange · INSTITUTIONAL_ACKNOWLEDGEMENT

2024-12-12 · PD-SP-EVT-0164

Portfolio confirmed that the information had been received and logged, promised review and confidential preservation, and stated that it would engage with CNMV or other relevant authorities for context.

The stated future regulatory liaison is not evidence that liaison actually occurred. Acknowledgement is not endorsement of the complaint.

Fuente / Source PD-SP-SRC-0009

Portfolio / CNMV / individual escalation · OUTBOUND_COMMUNICATION

2025-01-17 · PD-SP-EVT-0165

Gil sent a further escalation concerning Orion, alleging regulatory failures and media suppression, to Portfolio's channel, CNMV routes and the named individual escalation recipient.

These are the sender's allegations. Sending the escalation does not prove its allegations, a failure of statutory duty, receipt by every recipient or board circulation.

Fuente / Source PD-SP-SRC-0010

Portfolio Stock Exchange · OFFICIAL_NOTIFICATION

2025-03-21 · PD-SP-EVT-0166

Portfolio reported an internal investigation over three months, collection of data and review of sources. It said the assessment was completed, subject to possible extension on new evidence, and requested official authority documents rather than merely copies of filed complaints.

This is Portfolio's reported assessment status, not an exonerating judgment or a finding of fraud. Later correspondence referring to 22 March does not replace the retained 21 March message timestamp.

Fuente / Source PD-SP-SRC-0011

Portfolio Stock Exchange · OUTBOUND_COMMUNICATION

2025-03-23 · PD-SP-EVT-0167

Gil followed up with Portfolio, thanked it for the response and proposed in-person collaboration.

An offer to collaborate is not evidence that a meeting took place or that further evidence was accepted.

Fuente / Source PD-SP-SRC-0012

Cajasiete · OUTBOUND_COMMUNICATION

2025-12-02 · PD-SP-EVT-0168

Gil asked Cajasiete's channel manager for receipt/case-opening confirmation, independence and conflict assurances, confidentiality and protection before providing a structured evidential submission.

This preliminary request does not itself prove delivery of the full evidence, formal admission or a legally adjudicated protected status.

Fuente / Source PD-SP-SRC-0013

Cajasiete · INSTITUTIONAL_ACKNOWLEDGEMENT

2025-12-10 · PD-SP-EVT-0169

Cajasiete directed Gil to its internal reporting system and gave assurances of independence, confidentiality, non-retaliation and recusal/reassignment if a potential conflict were identified.

The assurances and channel invitation are documented; actual conflict checks and substantive investigation are not established by this email.

Fuente / Source PD-SP-SRC-0014

Cajasiete · OFFICIAL_NOTIFICATION

2026-04-28 · PD-SP-EVT-0170

Cajasiete notified inadmission of communication 6. Its stated reasons included public information/rumour, possible personal conflict outside the organisation, scope exclusions and inability to investigate. It said the information would be destroyed.

The notice proves the stated reasons and announced action, not their legal correctness, the original submission's complete contents or actual destruction. The native submission date and attachment manifest remain open.

Fuente / Source PD-SP-SRC-0015

CNMV · OUTBOUND_COMMUNICATION

2026-08-20 · PD-SP-EVT-0171

CNMV's later acknowledgement identifies a new RICPE communication sent on 20 August. This date-specific communication is registered from that recipient confirmation.

The complete native 20 August submission and attachment manifest have not been reconciled in this release. The acknowledgement does not establish acceptance of its allegations.

Fuente / Source PD-SP-SRC-0018

Portfolio Stock Exchange · OUTBOUND_COMMUNICATION

2026-08-22 · PD-SP-EVT-0172

Gil corrected two earlier attachment failures and actually sent four ES/EN visual exhibits with the San Telmo/PwC source routes. He requested consolidation, preservation and appropriate internal escalation, including the board where applicable.

The earlier two sends must not be credited with delivery of these four exhibits. The visual exhibits are explanatory indexes, not primary findings. Board circulation was requested, not presumed.

Fuente / Source PD-SP-SRC-0016

CNMV · OFFICIAL_ACT_UNCLASSIFIED

2026-08-25 · PD-SP-EVT-0173

CNMV's signed decision records receipt on 25 August of public-information request 2026114903 covering RICPE/Sun Park/MYND source versions, Series F/G, conditions, conflicts, controls and advisers.

This is intake attested by the later decision, not a newly located standalone receipt. The relationship with the separately registered 24 August REGAGE event PD-SP-EVT-0152 is a reconciliation question, not assumed identity.

Fuente / Source PD-SP-SRC-0020

Portfolio Stock Exchange · INSTITUTIONAL_ACKNOWLEDGEMENT

2026-08-26 · PD-SP-EVT-0174

Portfolio confirmed receipt of the four exhibits on 22 August, inclusion in the file opened in December 2024, consolidation of requests 81/82, preservation, contextual review and referral to relevant internal functions. It identified its Legal/Compliance head as custodian.

This does not identify every board recipient, prove full-board circulation, constitute an express formal reopening decision or establish misconduct. The source's affirmative review/preservation statements must be preserved, not rewritten as silence.

Fuente / Source PD-SP-SRC-0017

CNMV · INSTITUTIONAL_ACKNOWLEDGEMENT

2026-08-27 · PD-SP-EVT-0175

CNMV's infringement-reporting function acknowledged the new RICPE communication sent on 20 August.

Acknowledgement proves receipt, not investigation, an adverse finding, clearance, or a supervisory decision.

Fuente / Source PD-SP-SRC-0018

Cajasiete · OUTBOUND_COMMUNICATION

2026-08-27 · PD-SP-EVT-0176

Gil requested a genuine Aweswell/Matkator financing meeting and internal referral to management, risk, commercial and institutional-relations functions. He asked for objective title, ECO valuation, LTV, debt-service, KYC and litigation criteria for his own proposal, not another client's confidential information.

The request does not prove internal delivery to the named officers, acceptance of finance, comparability of actual underwriting or a response. No financial concession is made a condition for withholding an allegation.

Fuente / Source PD-SP-SRC-0019

CNMV · OFFICIAL_DECISION

2026-09-04 · PD-SP-EVT-0177

The signed CNMV decision extends the transparency-request response period by one additional month because of the volume and complexity of the information requested. The decision is separate from its covering email.

This is a deadline extension, not refusal of access, a substantive disclosure decision, refusal to investigate, clearance or finding on the allegations. The printed registry time has no stated timezone.

Fuente / Source PD-SP-SRC-0020

CNMV · EMAIL_TRANSPORT

2026-09-04 · PD-SP-EVT-0178

CNMV's transparency function transmitted the attached response to the request received on 25 August and asked Gil to acknowledge receipt.

This records the covering transmission only. Its unstated-zone timestamp is not directly comparable to the decision's printed registry time; no new merits conclusion or acknowledgment by Gil is inferred.

Fuente / Source PD-SP-SRC-0021

Verifiable public questions to Cajasiete

  1. Which borrower, principal, deed and collateral properties formed the exact Cajasiete facility, and which dates document approval, drawdown and registration? The approximate EUR1m recollection is not yet documentarily settled.
  2. Which title documents, insolvency orders, suspension, funded-exit/Ona materials, litigation and valuations were reviewed, by whom and when? The question does not presume the bank had prior knowledge.
  3. Which conflict, related-party and due-diligence checks supported relationships involving Orion, AGM, RICPE and Acosta Matos, and what material history did legacy actors supply?
  4. How was inadmission of communication 6 reconciled with the bank's own relevant financing or investment relationships? What did the independent reviewers actually examine?
  5. Was information retained, transferred or destroyed after the notice? Explain the non-confidential basis and audit trail; protected information belongs with competent reviewers.
  6. What reassessment and internal referral followed later notices? Are comparable title, valuation, risk and litigation criteria applied to the Aweswell/Matkator proposal, without seeking another client's confidential information?

Portfolio — conduct after notice

The March response reports a completed review and possible extension. The August response confirms preservation, incorporation and contextual review. The testable issue is what material-disclosure, conflict, market-adviser, competent-function and regulatory-liaison analysis actually occurred. Neither total silence nor circulation to the full board is presumed.

CNMV — separate channels and acts

The forwards, infringement-reporting acknowledgement and transparency request are not collapsed into one proved case. The 4 September decision extends the deadline: it does not refuse access or decide the allegations.

Coverage and unresolved questions

20 individual events; six attachment descriptors. This is not a certificate of historical completeness.

  • Recover Cajasiete communication 6 native submission, date, attachments, admissibility worksheet, conflict checks and preservation/deletion audit. Announced destruction is not completed destruction.
  • Identify the exact Cajasiete facility, borrower, principal, deed, collateral fincas and dates. Gil's approximate EUR1m recollection, the 2018 locales sale, the 2022 adjudication and the reported 2023 security entry must not be collapsed into one proved transaction. The suspension/funded-exit relationship requires the relevant orders and dated financing documents.
  • Obtain the actual Portfolio board/committee distribution and decision record. Individual escalation and relevant-functions referral do not prove circulation to every director.
  • Reconcile the two earlier 22 August emails and separate Requests 81/82 acknowledgements individually; do not backdate delivery of the four exhibits to those failed-attachment sends.
  • Recover the complete native 20 August RICPE submission and its attachment manifest, beyond the recipient's date-specific receipt confirmation.
  • Reconcile CNMV incoming 2026114903 on 25 August with the separate 24 August REGAGE event PD-SP-EVT-0152; preserve both records until documentary identity is established.
  • Shared governance, a disclosed investment or an acknowledged complaint does not establish common control, lack of legal independence, concealment, reliance, intent or criminal responsibility. Test knowledge, disclosure and subsequent conduct actor by actor.

Canonical communications register (JSON) · Source / event crosswalk

Sun Park/MYND and Orion: distinct but interconnected branches.

Sun Park/MYND and Orion are distinct but interconnected branches. The documented RICPE, AGM, Pamalexsha and Acosta Matos links remain within one analysis; neither a Sun Park-to-Orion asset flow nor any actor’s knowledge or liability follows automatically. The FMMM inquiry is preserved but is not the exclusive connection.

Read the clarified two-branch architecture →