34 On 2 May 2003 the second defendant and the owners of stage one lots, including the plaintiff, entered into a declaration of trust. The deed recited that the second defendant had agreed to sell the stage two lots to Lowe as a single green title lot. It further recited that the second defendant must transfer the stage two lots to the strata company as agent for the owners of the stage one lots ("the trustees"), which must then transfer the new lot, as a single green title lot, to Lowe, that transfer of the stage two lots to the strata company vested legal ownership of the land in the trustees and that they agreed to hold their interest in the land on trust for the second defendant. The trustees acknowledged and agreed that no beneficial interest in the land was to pass to the trustees pursuant to the declaration. The plaintiff, as one of the trustees, acknowledged that it would hold its interest in the land, on trust, momentarily, for the sole purpose of enabling the second defendant to transfer the land to Lowe as a single green title lot and that it did not receive any consideration for acting as trustee in accordance with the terms of the deed. The strata company entered into a similar deed on 28 April 2003.