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(hereinafter “WORLD PHANTASY”), is a purported resort management and travel agency operating as

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the designated servicing agent for the YUCATAN timeshare program. WORLD PHANTASY’s last

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known address is listed as Calle Eusebio A. Morales, Edificio Atlantida, P Baja, APDO, 8301 Zona 7

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Panama.

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5.

Respondent Michael E. Kelly (“KELLY”) is the founder and president of YUCATAN and, in

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this capacity, KELLY oversees and controls both YUCATAN operations and the resulting proceeds.

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KELLY’S last known address is that of his company headquarters, 3222 Mishawaka Avenue, South

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Bend, Indiana, 46615.

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6.

Respondent Lori Kelly is joined in this action under A.R.S. § 44-2031(C) solely for purposes

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of determining the liability of the marital community.

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7.

At all times relevant hereto, KELLY and Lori Kelly were acting for their own benefit, and for

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the bene it or in furtherance of the marital community.

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8.

YUCATAN, RHI, WORLD PHANTASY, and KELLY may collectively be referred to as

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“RESPONDENTS.” Lori Kelly may be referred to as “Respondent Spouse.”

Docket No. S-03539A-03-0000

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4.

Respondent

World

Phantasy

Tours,

Inc.,

a/k/a

Majesty

Travel

and

Viajes

Majesty,

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III.

FACTS

Arizona Revised Statutes (A.R.S.) § 44-1801(25).

sale of securities to the general public in Arizona in the form of investment contracts as defined by

10. To date, at least 5 Arizona-based YUCATAN sales agents have been identified selling

YUCATAN’s investment product to well over three hundred investors.

timeshare units in one of various resort properties throughout Mexico and Central America.

9.

Since at least 1999, RESPONDENTS have been directly or indirectly engaged in the offer and

11. The YUCATAN investment opportunity is based on what the issuing company terms its

“Universal Lease Program,” a program which purportedly offers investors the opportunity to purchase

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