STATE OF VERMONT SUPERIOR COURT CIVIL DIVISION ORANGE UNIT DOCKET NO. 24-2-20 Oecv IN RE: ABANDONED MOBILE HOME OF COREY & KIMBERLY BRADLEY NOTICE OF HEARING A hearing on The Housing Foundation, Inc.’s Verified Complaint to declare as abandoned and uninhabitable the mobile home of Corey & Kimberly Bradley, located at the Mobile Acres Mobile Home Park, 191 Sesame Street, Lot #12 in Braintree, Vermont has been set for March 5, 2020 at 8:30 a.m. at the Vermont Superior Court, Orange Unit, Civil Division, located at 5 Court Street, Chelsea, Vermont. Dated February 11, 2020 Lisa Eastman, Deputy Clerk/Docket Clerk VERIFIED COMPLAINT FOR ABANDONMENT PURSUANT TO 10 V.S.A. § 6249(i) (Uninhabitable) NOW COMES The Housing Foundation, Inc. (“HFI”), by and through its counsel Nadine L. Scibek, and hereby complains pursuant to 10 V.S.A. § 6249(i) as follows: 1. HFI, a Vermont non-profit corporation with a principal place of business in Montpelier, County of Washington, State of Vermont, is the record owner of a mobile home park known as the Mobile Acres Mobile Home Park (the “Park”), located in the Town of Braintree, Vermont. 2. Corey & Kimberly Bradley (“Bradleys”) are the record owners of a certain mobile home (the “Mobile Home”) described as 1988 Titan Champion, 17’ x 80’, bearing Serial #508-146T-1212, located at the Mobile Acres Mobile Home Park, Lot #12, 191 Sesame Street in Braintree, Vermont according to the Town of Braintree Land Records. See attached Bill of Sale. 3. Bradleys leased a lot in the Park from HFI pursuant to a written lease. Bradleys paid HFI a security deposit of $340.00. 4. Bradleys’ last known mailing address is 191 Sesame Street, #12, Braintree, Vermont 05060. 5. The mobile home has been abandoned and is empty. The last known residents of the mobile home were the Bradleys. All of Bradleys’ personal property is believed to have been removed from the mobile home and utility services have been terminated. The Park attempted to communicate with Bradleys with respect to their intentions with their mobile home and has received no response. 6. Bradleys were evicted from the Park for non-payment of rent on September 26, 2019. A Judgment Order for the outstanding lot rent and court costs was entered against Bradleys on July 1, 2019 in the amount of $2,716.17. See The Housing Foundation, Inc. v. Bradley et. al., Vermont Superior Court, Orange Civil Unit, Docket No. 76-5-19 Oecv. 7. The following security interests, mortgages, liens and encumbrances appear of record with respect to the mobile home: a. Bradleys are in arrears on obligations to pay property taxes to the Town of Braintree, Vermont in the aggregate amount of $596.40, current taxes are $307.19, plus interest and penalties. The delinquent property taxes are now a lien on the property. b. The Housing Foundation, Inc. v. Bradley et. al., Judgment Order dated July 1, 2019. 8. Mobile home storage fees continue to accrue at the rate of $390.00 per month. Rent, storage fees, and late charges due HFI as of February 4, 2020 total $4,644.62. Attorney’s fees and court costs incurred by HFI currently exceed $2,000.00. 9. HFI sent written notice by certified mail to the Town of Braintree on January 7, 2020 of Plaintiff’s intent to commence this action. See attached. 10. The mobile home is uninhabitable. Thomas Young, Property Manager, will testify under oath as to the poor and unlivable condition of this mobile home at the abandonment hearing. WHEREFORE, HFI respectfully requests that the Honorable Court enter an order as follows: 1. Declare that the mobile home as been abandoned; 2. Transfer the mobile home which is unfit for human habitation to the Park owner, HFI without a public auction so that it may be removed and disposed of accordingly. 3. Order pursuant to 10 V.S.A. § 6249(j) that the mobile home and any security deposit paid be conveyed to the Park Owner in “as is” condition, and free from all liens and other encumbrances of record. DATED AT Burlington, Vermont this 4th day of February, 2020. By: Nadine L. Scibek, Attorney for The Housing Foundation, Inc. DATED at Burlington, Vermont this 4th day of February, 2020. By: Thomas Young, Duly Authorized Agent The Housing Foundation, Inc. VERIFICATION STATE OF VERMONT CHITTENDEN COUNTY, SS. At Burlington, on this 4th day of February, 2020, Thomas Young, duly authorized agent of The Housing Foundation, Inc., owner of the Mobile Acres Mobile Home Park in Braintree, Vermont, being first duly sworn, made oath that he has read the foregoing Complaint, and that the facts contained therein are true. Before me, Notary Public – Nadine L. Scibek Commission Expires: 1/31/21 Lic. #157.0007638

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