You are right. Well, that is unforgivable. We don't need dummy keys. We need working ones!Hi Paul
It sounds a bit odd but I think also the upper C# and D keys are dummy keys.
If you follow the linkage from key to flaps you won't notice dedicated flaps.
Also if you count the total no of flaps you end up at 37 - which fits Stan's model-name saying "Giulietti 37".