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<p> [Insert caption.]</p><p>PETITION TO REMOVE TRUSTEE FOR BREACH OF TRUST</p><p>Petitioner Ralph Jones represents that he is interested in this matter as trust beneficiary and states:</p><p>1. The Ed Jones Trust was established on [date] and became irrevocable on the death of Ed Jones on [date of death].</p><p>2. John Jones is the Successor Trustee of the Ed Jones Trust.</p><p>3. The interested persons to this petition are: Name and Relationship Address John Jones, Successor Trustee [address] Stephanie Jones, trust beneficiary [address] Ralph Jones, trust beneficiary [address]</p><p>4. Among other things, the trust requires the Trustee to</p><p> a. account annually to all trust beneficiaries,</p><p> b. file appropriate tax returns,</p><p> c. distribute the net income of the trust on a biannual basis, and</p><p> d. prudently invest and manage the trust assets.</p><p>5. The Successor Trustee, John Jones, has breached his duties as Trustee in the following ways:</p><p> a. He has absolutely failed, refused, and neglected to account to the trust beneficiaries despite the beneficiaries’ frequent requests that he do so.</p><p> b. He has failed to file appropriate tax returns.</p><p> c. Only one distribution has been made from the trust since the death of Ed Jones, with no explanation or information whatsoever as to how the distribution was calculated.</p><p> d. On information and belief, the Successor Trustee has failed to maximize the income of the trust by appropriately and prudently investing the trust assets.</p><p>6. The trust is not registered, but this court has jurisdiction and venue pursuant to MCL 700.7202 and MCL 700.7204. PETITIONER REQUESTS that the court grant the following relief: </p><p>A. Remove John Jones as Successor Trustee.</p><p>B. Appoint Ralph Jones or some other suitable person as Second Successor Trustee.</p><p>C. Enter any other order that will protect the rights of all interested parties in this matter.</p><p>I declare that I have examined this petition and that its contents are true to the best of my information, knowledge, and belief.</p><p>Dated: ______/s/______Ralph Jones, Petitioner</p><p>Prepared by: [Firm name] By: /s/______[Typed name of attorney (P____)] [Address, telephone]</p>
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