I believe your not a million miles off the mark however there does seem to be almost a vendetta being carried out by the CAA dept involved. I understand that in some instances paperwork is being sort on work and repairs to the aircraft often from 10, 20, 30 or more years ago, often long before TFC took ownership of the aircraft. Apparently there is no time limit as to how far back the CAA can look. How many of us have an aeroplane with a patch or a repaired dint that was done prior to your ownership that you have no paperwork to cover?
The Head of this CAA dept is certainly earning a reputation - I wont say what for.
I wish TFC all the best in resolving these issues, other organisations are aware.