# 2015 creditor / HAYA / Uría correspondence — controlled source note

Date of source recovery: 4 September 2026  
Scope: April–July 2015 LPB / Sun Park creditor-enforcement perimeter  
Status: **PRIMARY CONTEMPORANEOUS CORRESPONDENCE + REPORTED COMMUNICATIONS; CLIENT / MANDATE / CONTENT NOT FULLY ESTABLISHED**

## Evidential rule

This note separates what the native correspondence proves from what participants reported about conversations with third parties. It does **not** establish that Uría Menéndez represented HAYA, the Administrador Concursal, Bankia or SAREB on every referenced step. It does not establish a professional conflict, improper information flow, collusion or wrongdoing.

## 28 April 2015 — reported HAYA → Uría documentation path and Javier González communication

A native email sent from the Sun Park side to Cuatrecasas on 28 April 2015 records the sender's contemporaneous account of what local enforcement lawyer César Guadalupe Plaza had said by telephone. The email reports that:

- on 9 April, **Ana María Tabada Pinzón of HAYA** had asked the local lawyer for the case documentation so that it could be passed to **Uría Menéndez in Madrid**;
- **Javier González Guimaraes-Da Silva**, identified with Uría Madrid, later called the local lawyer and, according to the email, said that they wanted to continue with the proceeding;
- the local lawyer had not received an official communication from Bankia about the credit transfer and said he needed instructions from the party with authority to instruct him.

**What this proves:** a primary contemporaneous email exists recording these reported communications and identifying HAYA, Uría Madrid and Javier González within the creditor/enforcement information-flow perimeter.

**What it does not prove:** the email is not the native HAYA instruction, the native HAYA→Uría transmission, the native Javier González communication or an Uría engagement letter. It therefore does not by itself establish Uría's client, mandate, matter number, authority to instruct the local lawyer or the legal ownership of the credit.

## 29–30 April 2015 — direct counter-evidence on a HAYA mandate

The same native Cuatrecasas thread records Cuatrecasas attempting to speak directly with the Uría lawyer. On 30 April 2015 Rosa Gual Tomás reported back after that contact:

> “Acabamos de hablar con Uría y nos han trasladado que todavía no tienen el encargo de realizar actuación alguna en nombre de Haya.”

English translation:

> “We have just spoken with Uría and they have told us that they do not yet have instructions to take any action on behalf of Haya.”

The email then directed any clarification to a HAYA portfolio manager.

**Evidential consequence:** this is material counter-evidence against publishing that Uría was already retained to act for HAYA as of 30 April 2015. The earlier reported HAYA→Uría documentation path and Javier González communication remain relevant, but they cannot be collapsed into a proved HAYA retainer.

## 30 April–4 May 2015 — creditor identity / local-lawyer capacity remained unsettled in the correspondence

Further messages in the same thread record Cuatrecasas reporting, on information obtained from other lawyers, that the enforcement proceeding was being pursued for **SAREB rather than Bankia**, and on 4 May that César Guadalupe Plaza had confirmed acting in the proceedings on behalf of SAREB. Other messages used HAYA/Cerberus ownership language, but those statements are professional/correspondence reports rather than the native assignment instrument.

**Evidential consequence:** the 2015 chain must distinguish at least: Bankia, SAREB, HAYA as interlocutor/servicer, any Cerberus context, the local enforcement lawyer, and Uría. Asset-specific title and authority require the transfer instrument, servicing mandate and court-file substitution/appearance records.

## 3 July 2015 — reported Administrador Concursal → Javier Rubio Sanz contact

A separate preserved 3 July 2015 communication contains the contemporaneous line:

> “ya tenemos el nombre del abogado de URIA con quien el AC ha hablado, se llama Javier Rubio Sanz.”

English translation:

> “we now have the name of the URIA lawyer with whom the AC has spoken; his name is Javier Rubio Sanz.”

This supports a **documented reported AC–Uría communication**. It does not by itself establish that Uría represented the Administrador Concursal, a retainer, the identity of Rubio Sanz's client, the mandate or what information was exchanged.

## Proposition matrix

| Proposition | Source character | Status | What it proves | What remains open |
|---|---|---|---|---|
| HAYA material was reportedly being passed toward Uría Madrid in April 2015 | primary contemporaneous email reporting a third-party conversation | DOCUMENTED REPORTED COMMUNICATION | contemporaneous evidence of a HAYA→Uría information-flow report | native transmission, recipient, client, mandate, content |
| Javier González reportedly called the local lawyer about continuing the proceeding | primary contemporaneous email reporting a third-party conversation | DOCUMENTED REPORTED COMMUNICATION | identifies Javier González/Uría in the enforcement chronology | native call record/email, client, authority, instruction |
| Uría had a HAYA mandate by 30 April 2015 | Cuatrecasas email after speaking with Uría | **CONTRADICTED / NOT ESTABLISHED AT THAT DATE** | records Uría saying it did not yet have instructions to act for HAYA | whether/when any later HAYA mandate opened |
| Local lawyer acted for SAREB | Cuatrecasas follow-up reporting direct confirmation from the local lawyer | STRONG SUPPORTING EVIDENCE | contemporaneous capacity report | native appearance, power, substitution and court-file record |
| AC spoke with Javier Rubio Sanz | separate 3 July 2015 preserved correspondence | DOCUMENTED REPORTED COMMUNICATION | contemporaneous reported AC–Uría contact | client, retainer, mandate, content, information flow |

## Production / preservation targets

1. Native HAYA email of 9 April 2015 and its attachments / metadata.
2. Native transfer of the case file to Uría Madrid and recipient list.
3. Native Javier González communication with César Guadalupe Plaza and any related time entry.
4. Uría matter-opening / engagement metadata for the relevant creditor/enforcement matter: client identity, opening date, matter number, scope and conflict check.
5. Any later HAYA engagement that post-dates the 30 April “no instructions” communication.
6. SAREB / HAYA servicing and instruction records for the specific LPB credit.
7. Court-file appearance/substitution records and the underlying assignment instrument.
8. Native records of the 3 July 2015 AC–Javier Rubio Sanz communication, including participants, subject matter and any Uría matter/time entry.

## Publication-safe conclusion

**The 2015 record places Uría Menéndez within the LPB/Sun Park creditor-enforcement communications and contains separate contemporaneous reports involving Javier González Guimaraes-Da Silva and Javier Rubio Sanz. The same record also contains important counter-evidence: on 30 April 2015 Cuatrecasas reported that Uría said it did not yet have instructions to act for HAYA. The precise Uría client, mandate, authority and information flow must therefore be established from native engagement and matter records rather than inferred from proximity.**