Young

STATEMENT OF FACTS

Defendant Stanley Hartford is the trust protector and defendant Debbie Fleshman is the trustee of the Carolyn Patricia Young Family Trust. Plaintiff is a current beneficiary of the trust. Plaintiff Christa Ann Young alleges defendants are conspiring to improperly withhold trust funds from plaintiff and from certain charities that the trust dictates should receive a 1 portion of the net income of the trust annually. The alleged purpose of the conspiracy is to preserve assets for the benefit of defendant Debbie Fleshman, who (in addition to being trustee) is a residuary beneficiary of the trust, and will inherit half its proceeds upon plaintiff’s death.

PROCEDURAL HISTORY

Plaintiff filed an ex parte application seeking the suspension of defendants’ powers arising from their respective roles as trust protector and trustee of the trust and appointment of a private professional fiduciary as interim trustee. The trial court granted the ex parte application and issued a

1 We grant defendants’ unopposed first request for judicial notice as to plaintiff’s verified trust petition, the trust documents themselves, plaintiff’s ex parte application, and defendants’…