12345678910111213141516171819202122232425262728Erin E. Byrnes, No. 021015Lisa S. Wahlin, No. 013979G
, P.C.1850 North Central Avenue, Suite 500Phoenix, Arizona 85004Telephone: (602) 792-1700Facsimile: (602) email@example.com firstname.lastname@example.org Attorneys for Plaintiff Town of Colorado City
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF ARIZONA
TOWN OF COLORADO CITY, an Arizonamunicipality,Plaintiff,v.THE UNITED EFFORT PLAN TRUST,(Dated November 9, 1942, Amended April 10,1946, and Amended and Restated on November 3, 1998); and BRUCE WISAN,Special Fiduciary,Defendants.
COMPLAINT FOR DECLARATORY RELIEF
Plaintiff Town of Colorado City (“Colorado City”) for its Complaint againstDefendants the United Effort Plan Trust and Bruce Wisan, Special Fiduciary for the Trust,states and alleges as follows:
Plaintiff Colorado City is an Arizona municipal government.2.
Defendant the United Effort Plan Trust (hereinafter “the UEP Trust”) is areligious and charitable trust formed in 1942 according to the laws of the State of Utah.3.
Defendant Bruce Wisan is a Utah resident and, at all times relevant hereto,was the court-appointed Special Fiduciary of the UEP Trust. In that capacity, BruceWisan purports to oversee and administer the Trust’s assets, including much of the real property located in Colorado City, Arizona.