27 · 09 · 2026

Documented investor bridge and current RSM review

Same hotel, same period, two professional functions requiring reconciliation. The full 30 November 2021 video, the 2020 webinar and contemporaneous 2022 controls support the specific bridge: Eduardo Sánchez said the firm introduced clients into the RICPE investment connected to Sun Park while the AC acted within the San Telmo professional perimeter. This must not be reduced to brand proximity. Obtain introduction/subscription, project-allocation, fee, conflict, file-access and communication records.

Current review confirmed: on 23 September 2026 RSM confirmed review of the additional August and September documents and reconsideration of its analysis; it explained a filtering problem and requested use of its channel for traceability. This establishes review activity, not a liability conclusion.

The official San Telmo integration announcement identifies Javier Rodríguez-Batllori Laffitte, Eduardo Sánchez Iglesias and Javier de Bethencourt Gallego. Javier and Francisco de Borja Rodríguez-Batllori Laffitte, the AC, are distinct and connected people, as documented below. Integration neither proves that the AC joined RSM nor automatically transfers responsibility for historical conduct. AC–Eduardo coordination and any transmission of insolvency information need their own evidence.

Family and corporate connection supported by the sources: the investigation report received on 8 May 2018 identifies Javier Rodríguez-Batllori Laffitte as Francisco de Borja’s brother on page 28 and states that they worked at the same firm. This remains a private investigation report, not a civil-registry certificate; the original and unrelated personal details are not published. The 11 September 2018 BORME, entries 371214–371215, records Francisco Javier as a professional partner and the cessation of Francisco de Borja and Eduardo Sánchez as joint administrators. Cessation from that office does not mean departure as a partner. The 10 July 2024 BORME, entry 308341, p. 32821, records the transfer of 500 shares from Francisco de Borja to Francisco Javier and the former’s removal as a professional partner; registration was on 3 July 2024. This establishes a specific corporate bridge. A third brother at San Telmo has not been established. Kinship and shareholdings do not alone prove knowledge, coordination or misconduct.

Inter-Bar examination: mandates, fees and incentives

SOURCE → PROFESSIONAL OVERLAP → RECORDS

A public statement. A documented overlap. Records that can resolve the question.

This page separates the direct source from the documentary bridges around it. It does not convert professional association into proof of coordination.

Editorial and evidential boundary. The public source establishes Eduardo Sánchez’s statement. Separate records address the RICPE–Sun Park project chronology and Francisco de Borja Rodríguez-Batllori Laffitte’s insolvency-administrator and professional roles. Taken together, they justify a finite request for traceability. They do not by themselves establish coordination, transfer or misuse of insolvency information, unlawfulness or liability.

Last evidence review: 19 August 2026.

1. The direct public source

Speaker: Eduardo Sánchez, San Telmo partner.

“bueno, nosotros en el despacho… en esa primera inversión… metimos unos cuantos clientes”

Working English translation: “well, we at the firm… in that first investment… brought in several clients.”

Programme: “Enrique Guerra, en #UnCaféenSanTelmo”, San Telmo Abogados y Economistas, 30 November 2021.

Statement: 08:08–08:12. Context reviewed: 07:57–08:27. Transcript: pages 29–30 of 85.

2. Proposition-by-proposition evidence map

IDPropositionPresent supportWhat it does not prove
S1Eduardo Sánchez made the quoted statement.Public video, timestamp and preserved transcript.That every client mentioned entered Sun Park.
S2“That first investment” is connected to the RICPE project chronology associated with Sun Park.Separately cited brochure, webinar, certificate and project chronology.That the four-second quotation alone identifies Sun Park or establishes complete title.
S3Francisco de Borja Rodríguez-Batllori Laffitte served as insolvency administrator in Concurso 36/2012 concerning LPB.Separate procedural and professional records.Shared files, knowledge or coordination with Eduardo Sánchez.
S4The two professional roles are historically linked to the San Telmo perimeter during relevant periods.Date-sensitive professional records, treated separately.That institutional association equals a conflict, information transfer or breach.

3. What the image’s “same asset” shorthand means

Same hotel complex and connected project perimeter—not one undivided legal asset. LPB was the debtor in Concurso 36/2012; the whole Sun Park complex was not automatically the insolvency estate. The shorthand does not erase Matkator or third-party title and does not assert that every unit formed part of LPB’s estate.

Insolvency life

LPB, Concurso 36/2012, estate assets, creditors, liquidation and the court-appointed insolvency administration.

Investment life

RICPE, investor introductions, promoter/project records, due diligence, financing and the public Sun Park chronology.

The reconciliation question

Which controls kept matters, information, access and professional duties separate—and what contemporaneous records demonstrate that?

4. Records capable of resolving the question

  • Matter-opening and engagement records.
  • Conflict checks, scope and approvals.
  • Client-introduction and referral records.
  • Any referral or remuneration arrangements.
  • Investor allocation to projects.
  • Investor-onboarding and AML/KYC controls.
  • File, team and system separation.
  • Document-management and access logs.
  • Communications with RICPE and project promoters.
  • Event preparation and source materials.
  • Billing, time entries and matter codes.
  • Independent review, abstention or consent records.

This is a request for traceability, not unrestricted disclosure of client identities or privileged communications. Process, date, scope, responsibility, custody and verification can often be demonstrated through redaction, certification or independent review.

5. Right of reply and correction

San Telmo, RIC Private Equity, the professionals named and any materially affected party are invited to provide source-backed correction, context or records. Any material and verifiable correction will be incorporated with equivalent visibility. Silence is not treated as proof.