You could ask some of the VICE programmers. They might have some idea
if they emulated it. (I just started X128 into CPM and it works just
great.)
I thought it was modeled after the kaypro machines, since thats the
compatability they went for with cp/m.
That sounds right from the little I've read. It boots from the Z80 and
unless told to switch to the C64 or C128 modes it continues on the Z80
as some Kaypro compatible.