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Case 2019CV000128 Document 1 Filed 08-12-2019 Page 5 of 20 <br /> former Camp property made clear that WLCRV was taking steps to develop its proposed RV <br /> Park and mixed-use resort. WLCRV is asserting that its ongoing redevelopment is permitted as a <br /> "continuous use"of the property as a religious camp. It is not. WLCRV is redeveloping the <br /> property into a for-profit resort and campground for RVs. <br /> 6. WLCRV's proposed resort and RV campground is a change in use from the <br /> former Bible Camp use. WLCRV's for-profit business use of the Camp property requires that it <br /> obtain a conditional use permit("CUP") from the County and, on information and belief, several <br /> other permits. WLCRV is refusing to seek that CUP and is currently unilaterally undergoing <br /> construction activities at the property. Plaintiff believes these construction and redevelopment <br /> activities are not permitted and are in violation of County and Town Ordinances. WLCRV is <br /> claiming that it does not need permits as it is only re-instituting the former Bible Camp use at the <br /> property. That is inaccurate but would not matter because the property has not been used as a <br /> Bible Camp for over 12 months and as such, has lost its legal non-conforming use(i.e. <br /> "grandfathered") status more than a year ago. <br /> 7. A controversy is apparent and ongoing. Plaintiff CCoBWL is seeking the Court's <br /> review of that controversy and a declaration regarding the rights of the parties. The Court is <br /> empowered to review and determine the current legal status of what is now WLCRV's property, <br /> and with that, the applicability of the County zoning code and other applicable land use <br /> ordinances. Plaintiffs seek an order declaring the rights of the parties and providing appropriate <br /> equitable relief. <br /> PARTIES <br /> 8. Plaintiff, Concerned Citizens of Big Wood Lake, U.A. ("CCoBWL") is a <br /> Wisconsin non-stock corporation established under Wisconsin Ch. 184 stats.,with its principal <br /> place of business at 22592 Assembly Drive Grantsburg, WI 54840. CCoBWL is an association <br /> 5 <br />