VERIFIED COMPLAINT FOR ABANDONMENT PURSUANT TO TITLE 10 V.S.A. § 6249(i} (Uninhabitable)

NOW COMES Falcon Management Company, Inc., by and through counsel Peter B. Schubart, and hereby complains pursuant to Title 10 V.S.A. § 6249(i) as follows:

1. Falcon Management Company, Inc., a Vermont domestic business corporation with a principal place of business in the Town of Richmond, County of Chittenden, State of Vermont, is the record owner of a mobile home park known as the Riverview Commons Mobile Home Park (the “Park”), located in Richmond, Vermont.

2. Dale Cusson a/k/a Dale Cousson is the record owner of a certain mobile home (the “Mobile Home”) described as 1974 Hillcrest, Model FDR3, 12’ x 70’ (Serial no. 04111772G) located at the Riverview Commons Mobile Home Park, Lot #18, 122 Lower Circle in Richmond, Vermont. A Mobile Home Bill of Sale dated August 30,2022, is of record in the Town of Richmond Land Records in Volume 238 at Page 52. (A copy of said bill of sale is attached hereto as Exhibit 1)

3. Dale Cusson a/k/a Dale Cousson leased a lot in the Park from Falcon Management Company pursuant to a written lease. There is no security deposit.

4. Dale Cusson a/k/a Dale Cousson’s last known mailing address is 122 Lower Circle, Richmond, VT 05477.

5. The mobile home has been abandoned and is empty. Falcon Management Company, Inc. evicted Dale Cusson a/k/a Dale Cousson from the lot in the park (Chittenden Unit Civil Docket no. 25-CV-02012, Falcon Management Company Inc. v. Dale Cusson) and more than ninety days have elapsed since the Sheriff’s office put Falcon Management Company, Inc. in possession of the lot by shutting off power and water to the home and changing the locks on or about April 22, 2026. To date, Dale Cusson a/k/a Dale Cousson has made no effort to remove the mobile home. Falcon Management Company staff has allowed Mr. Cusson to retrieve personal items from the mobile home.

The following security interests, mortgages, liens and encumbrances appear of record with respect to the mobile home:

1. Taxes are owed to Town of Richmond in the amount of $1,327.75.

2. Mobile home storage fees continue to accrue at the rate of $615.00 per month.

3. Unpaid Rent since Judgment, Judgment amount, and service fees due Falcon Management Company, Inc. as of June 25, 2025 exceed $15,254.49. Attorney fees and court costs incurred by Falcon Management Company, Inc. Since the judgment date of June 23, 2025 are $2,585.00.

Falcon Management Company, Inc. sent written notice by certified mail to the Town of Richmond on July 21, 2026 of its intent to commence this action. (See attached Exhibit 2).

The mobile home is uninhabitable. Jeffrey Bishop, Property Manager for the Park, will testify under oath as to the poor and unlivable condition of this mobile home at the abandonment hearing. His affidavit is attached hereto as Exhibit 3.

WHEREFORE, Falcon Management Company, Inc. 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 which is unfit for human habitation to Riverview Commons park owner Falcon Management Company, Inc. without a public auction so that it may be removed and disposed of accordingly.

3. Order pursuant to 10 V.S.A. § 6249(i) that the mobile home and any security deposit paid be conveyed to Falcon Management Company, Inc. in “as is” condition, and free from all liens and other encumbrances of record.

DATED AT South Burlington, Vermont this 18th day of August, 2026.


Falcon Management Company, Inc.

By:

Peter B. Schubart, Esq.,

80 Midas Drive, South Burlington, VT 05403

(802) 829-0237/ peter@schubartlaw.com