IN RE: ABANDONED MOBILE HOME

OF JENNIFER MARTIN

NOTICE OF HEARING

A hearing on Lamoille Housing Partnership, Inc.’s Verified Complaint to declare as abandoned and uninhabitable the mobile home of Jennifer Martin located at the Evergreen Manor Mobile Home Park, Lot #11, 9 Spruce Drive in Hardwick, Vermont has been set for Wednesday, November 19, 2025 at 1:00 p.m. You may participate in the hearing either in person at the Vermont Superior Court, Caledonia Unit, Civil Division located at 1126 Main Street, Suite 1 in St. Johnsbury, Vermont or remotely via WEBEX video. The WEBEX Login Information is as follows:

App: Cisco Webex Meeting

Website: https://vtcourts.webex.com

Meeting Number: 2336 403 5020

Password: Civil

If you do not have a computer or sufficient bandwidth, you may call (802) 636-1108 to appear by phone. (This is not a tollfree number). When prompted enter the meeting ID number listed above, followed by the pound symbol (#). You will be prompted to enter your attendee number (which you do not have). Instead, press pound (#). If you have technical difficulties, call the Court at (802) 748-6600.

Date: October 30, 2025
Alan Glassman

Vermont Superior Court Judicial Assistant

VERIFIED COMPLAINT FOR ABANDONMENT

PURSUANT TO 10 V.S.A. § 6249(i) (Uninhabitable)

NOW COMES Lamoille Housing Partnership, Inc. (“LHP”), by and through its counsel Nadine L. Scibek, and hereby complains pursuant to 10 V.S.A. § 6249(i) as follows:

1. LHP, a Vermont non-profit corporation with a principal place of business in Morrisville, County of Lamoille, State of Vermont, is the record owner of a mobile home park known as the Evergreen Manor Mobile Home Park (the “Park”), located in Hardwick, Vermont.

2. Jennifer Martin (“Martin”) is the record owner of a certain mobile home (the “Mobile Home”) described as 1977 Fleetwood, 14’ x 46’ located at the Evergreen Manor Mobile Home Park, Lot #11, 9 Spruce Drive in Hardwick, Vermont. The Town of Hardwick has no record of a Bill of Sale recorded for the Mobile Home in its Land Records.

3. Martin leased a lot in the Park from LHP pursuant to a written lease. Martin paid a security deposit to LHP in the amount of $360.00.

4. Martin’s last known mailing address is 1877 Hollow Road, Hinesburg, VT 05461.

5. The mobile home has been abandoned and is empty. To LHP’s knowledge, the Mobile Homes has never been lived in by Martin as she bought the Mobile Home to renovate it. There appears to be no personal property of Martin in the Mobile Home.

6. Counsel for LHP has attempted to communicate in writing with Martin on September 19, 2025 regarding her intentions with the mobile home. She has failed to respond. See attached.

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

a. The Town of Hardwick has stated that it has no record of a mobile home on this Lot and the parcel is closed with the Town of Harwick, so there are no taxes owed to the Town.

b. Electric fees may be owed to the Hardwick Electric Department.

8. Mobile home storage fees continue to accrue at the rate of $384.00 per month. Rent, storage fees, and late charges due LHP as of October, 2025 total $8,124.00. Attorney’s fees and court costs incurred by LHP currently exceed $850.00.

9. LHP sent written notice by certified mail to the Town of Hardwick on September 19, 2025 of Plaintiff’s intent to commence this action. See attached.

10. The mobile home is uninhabitable. Kales O’Brien, Property Manager for the Park, will testify under oath as to the poor and unlivable condition of this mobile home at the abandonment hearing.

WHEREFORE, LHP 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 Park owner LHP 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 October 29, 2025

LAMOILLE HOUSING PARTNERSHIP, INC.

BY: Nadine L. Scibek

Attorney for LHP

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.

October 29, 2025
BY: Lisa Call

Duly Authorized Agent for LHP