NOTICE OF HEARING
A hearing on The Housing Foundation, Inc.’s Verified Complaint to declare abandoned the mobile home of Louis Belval Sr. located at the Birchwood Manor Mobile Home Park (1987 Skyline Jay, 14’ x 70’, bearing Serial No. 18160403W) located on Lot #66, 63 Dewey Drive in Milton, Vermont, to authorize the transfer without public auction, so it may be removed and disposed of, has been set for Thursday, May 28, 2026 at 10:30 a.m. in person at the Vermont Superior Court, Chittenden Unit, Civil Division located at 175 Main Street in Burlington, Vermont.
Date: May 5, 2026 Nancy L. Bean, Judicial Assistant
Chittenden Unit
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 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 Birchwood Manor Mobile Home Park located in the Town of Milton, Vermont (the “Park”). The Park is managed by the Vermont State Housing Authority.
2. Louis Belval Sr. (“Belval”) is the record owner of a certain mobile home, described as a 1987 Skyline Jay, 14’ x 70’, bearing serial number 18160403W (the “Mobile Home”), located on Lot #66, Birchwood Manor Mobile Home Park, 63 Dewey Drive in Milton, Vermont. See attached Bill of Sale.
3. Belval and his wife, Mary Lew Belval leased a lot in the Park for the mobile home from HFI pursuant to a written lease. Mary Lew Belval vacated the Mobile Home in or about November, 2024 and conveyed her ownership interest in the Mobile Home to Belval. Belval paid a security deposit in the amount of $298.00 to HFI. See attached Lease and Vermont Property Transfer Tax Return.
4. Belval is deceased. His date of death is September 25, 2025. See attached Death Certificate.
5. No petition to open a probate estate has been filed for Belval per the Chittenden County Probate Court.
6. The last known resident of the mobile home was Belval. The mobile home has been abandoned and is unoccupied. After Belval’s death, his son, Louis Belval Jr. contacted the Park Owner on February 17, 2026 and indicated that: he had wanted nothing to do with the Mobile Home; he was not going to be filing an estate with the Probate Court; and HFI could do what it wanted with the Mobile Home.
7. The following security interests, mortgages, liens and encumbrances appear of record with respect to the mobile home:
a. Property taxes to the Town of Milton are current according to the Town Clerk. However, current year taxes in the amount of $477.42 are due May 15, 2026. See attached Tax Bill and email from Town of Milton.
b. Belval is in arrears on obligations to pay water bills to the Town of Milton, Vermont in the aggregate amount of $461.48, plus any additional interest and penalties. The delinquent water bills are now a lien on the property. See attached email from Town of Milton.
8. Mobile home storage fees continue to accrue at the rate of $436.00 per month. Rent, storage fees and late charges due HFI as of April, 2026 total $2,194.63. Court costs and attorney’s fees from this action to date exceed $750.00. See attached Account History.
9. HFI sent written notice by certified mail to the Town of Milton on March 5, 2026 of HFI’s intent to commence this abandonment action as required by statute. See attached.
10. The mobile home is uninhabitable. Tyler Willis, Property Manager and duly authorized agent for the Park owner, 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 has been abandoned;
2. Transfer the mobile home that is unfit for human habitation to 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 April 30, 2026.
THE HOUSING FOUNDATION, INC. BY: Nadine L. Scibek
Attorney for HFI
I declare that the above statement is true and accurate to the best of my knowledge and belief. I understand that if the above statement is false, I will be subject to the penalty of perjury or other sanctions in the discretion of the Court.
April 30, 2026
BY: Tyler Willis
Duly Authorized Agent for HFI
