Bill Bowlen, younger brother of Broncos owner Pat Bowlen, asked a Colorado District Court on Thursday to remove the three-person trust in control of the team “due to their failure to uphold Pat Bowlen’s wishes and act in the best interest of Pat Bowlen, his family and the Broncos.”

Since Pat Bowlen stepped aside from his day-to-day duties in 2014 to battle Alzheimer’s, Joe Ellis, Rich Slivka and Mary Kelly have served as trustees for the Pat D. Bowlen Trust. Ellis, as the Broncos’ president and CEO, is the team’s point person at league meetings and runs the team’s day-to-day operations.

According to the petition filed in Arapahoe County District Court in Centennial, Bill Bowlen said the trustees “have conflicts of interest that impair their ability to act impartially in Pat Bowlen’s best interest.” He also wants the trust removed as Pat Bowlen’s power of attorney.

Bill Bowlen asked the court to appoint an independent party to serve as “conservator” (protector) of Pat Bowlen’s estate. He said the trustees “wield almost total control over the Broncos .. with no accountability.”

“I am a huge fan of the Broncos, and have been for decades,” Bill Bowlen said. “Unfortunately, over the past 15 years, I’ve noticed that the operation of the Broncos has deteriorated, while my brother’s health has worsened.

“I have real concerns with these trustees, their conduct and how they got to the positions they are in. They have little or no accountability to anybody but themselves. They have not complied with the rules of the NFL and I am uncomfortable with the way they have handled my brother’s affairs. I know what his wishes were, and these individuals are definitely not following them.”

On Thursday night, Dan Reilly, legal counsel for the Pat Bowlen Trust (and Mary Kelly’s husband), said in a statement: “Although we are currently reviewing this matter, we are aware that the counsel submitting this complaint on behalf of Bill Bowlen is the same one that has been representing Beth Bowlen-Wallace. The trustees will continue to execute Pat Bowlen’s long-standing succession plan for the Denver Broncos in compliance with all NFL ownership policies.”

In the 21-page petition obtained by the Denver Post, Bill Bowlen said the trustees have come up short in five areas: Acting in Pat Bowlen’s best interest, acting in good faith, acting to Bowlen’s benefit, performing their duties “so as not to create a deep conflict of interest that impairs their ability to act impartially,” and they have not done enough to “preserve and implement,” Bowlen’s estate and succession plan.

Two of Pat Bowlen’s daughters have expressed interest in succeeding their father.

In May, hours after Beth Bowlen-Wallace, one of Pat Bowlen’s two children from his first marriage, went public with her goal of succeeding her father, the trust responded by saying she is, “not capable or qualified at this time,” to run the Broncos.

In the petition filed Thursday, Bill Bowlen reiterated his support of Bowlen-Wallace by saying he and “other senior members of the Bowlen family believe that Beth is capable and qualified of assuming operational control of the (Broncos).”

Until Thursday, Bowlen-Wallace’s succession plan, which she presented to the trustees earlier this year, was not public. But details emerged in Bill Bowlen’s petition, chiefly that Beth would eventually transfer “controlling ownership in the near future to another Bowlen child.” Bowlen-Wallace’s plan also included management level opportunities for other Bowlen children if they desired.

Last week, Brittany Bowlen, said her “ambition and goals,” are to eventually run the organization. It is believed that Ellis and Co. are prepared to groom the 28-year old Bowlen once she rejoins the Broncos’ front office.

In February 2015, the trustees established a criteria of sorts for any of the seven Bowlen children interested in succeeding their father that includes senior management experience, a certain level of education and subjective qualities like character and leadership ability. But the trustees made it clear the document was not a checklist that, if satisfied, would automatically allow them to succeed their father.

Not included in the petition were the salaries being paid to Ellis, Slivka and Kelly for serving as trustees. That will come out during the discovery process via civil subpoenas if the petition goes down the legal road.

An explosive part of the petition includes Bill Bowlen saying he believes Pat, “did not fully understand the nature of the documents he signed that major made changes to his estate planning and created the fiduciary position with broad powers that the three trustees currently hold.”

The petition states that when Pat Bowlen established a new revocable trust in March 2009, he “likely did not have the required capacity to revoke the 2002 trust or create (the new) trust. The petition points out that less than two months prior, Bowlen told The Denver Post he was experiencing “severe memory loss,” and he was “very concerned” about his condition.

Bill Bowlen owned a stake in the Broncos until selling his share to Pat Bowlen in 2002. The petition said Pat Bowlen owns 76 percent interest in the Broncos and his brother, John, owns the remaining interest. Upon Pat’s passing, his stake in the team will be evenly split among his seven children.

Bill Bowlen said he will not have a financial gain if the petition is a success, but did so with a “goal to help and support” his brother, Pat’s family and the Broncos.

“The three trustees have refused to implement a long-term succession plan that adheres to Pat Bowlen’s long-stated goal of ensuring that his children … retain management and control of the team,” Bill Bowlen said. “Instead, the current trustees have done everything they can to delay Pat Bowlen’s children from assuming management and control of the team, in violation of their fiduciary duties.”