VERIFIED COMPLAINT FOR ABANDONMENT
PURSUANT TO 10 V.S.A. 6249i (UNINHABITABLE)

NOW COMES Plaintiff North Avenue Cooperative, Inc. by and through counsel Steven J. Kantor, and hereby makes this complaint:

1. Plaintiff North Avenue Cooperative, Inc, is a Vermont Cooperative Housing Corporation which was formed by the owners of mobile homes to own and manage the North Avenue Mobile Home Park (the “Park”).

2. Bernard R. Crowley (deceased) (“Defendant”) is the record owner of a certain 1965 mobile home with a total of 928 square feet located in the Park at 30 Avenue C in Burlington, Vermont.

3. Defendant’s last known mailing address is 30 Avenue C in Burlington, VT.

4. Defendant leased a lot in the Park under the terms of a written uniform Mobile Home Lot Lease. He passed away on December 13, 2025 and no one has resided in the mobile home since that time.

5. The last known resident at the mobile home was Defendant Bernard R. Crowley.

6. Defendant’s sister Laurie Sabens confirms that surviving family members have abandoned any interest in the mobile home. No petition to open a probate estate has been filed for Bernard Crowley per confirmation from the Chittenden Probate Division on January 14, 2026.

7. No liens or encumbrances appear of record with respect to the mobile home.

8. The mobile home is unsafe and unfit for habitation. The Affidavit of Timothy Seagroves, filed herewith, verifies the uninhabitable condition of the mobile home.

9. Mobile home lot rent has not been paid since November, 2025 and continue to accrue at the rate of $430.00 per month. Court costs and attorneys’ fees incurred by North Avenue Cooperative, Inc. continue to accrue.

WHEREFORE, Plaintiff respectfully requests that the Honorable Court enter an order as follows:

1. declaring that the mobile home has been abandoned; and

2. declaring that the mobile home is unfit for human habitation pursuant to 10 V.S.A. §6249(i); and

3. approving transfer of the mobile home to the Plaintiff without a public sale in “as is” condition, free and clear of all liens, taxes and all other encumbrances of record pursuant to 10 V.S.A. 6249(j).

DATED AT Burlington, this 15 day of January 2026.

NORTH AVENUE COOPERATIVE, INC.

/s/ Steven J. Kantor
Steven J. Kantor, Esq.
Doremus Kantor & Zullo
346 Shelburne Road, Suite 603
P.O. Box 445
Burlington, VT 05402-0445
(802) 863-9603

Attorney for NORTH AVENUE COOPERATIVE, INC.

VERIFICATION

I understand that the statements in the above Complaint are true and accurate to the best of my knowledge and belief.

DATED AT Burlington, Vermont this 15 day of January 2026

/s/ Timothy Seagroves

Timothy Seagroves, Duly Authorized Agent of

NORTH AVENUE COOPERATIVE, INC

STATE OF VERMONT

CHITTENDEN COUNTY, SS.

At Burlington, in said County and State, this 15th day of January 2026, personally appeared Timothy Seagroves, Duly Authorized Agent of NORTH AVENUE COOPERATIVE, INC., and he swore to the truth of the foregoing.

Before me,
/s/ Jack M. Kantor
Notary Public State of Vermont
JACK M. KANTOR
Notary Public, State of Vermont
My Commission Number: 157.0015206
My Commission Expires: Jan. 31, 2027

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