IN RE: ABANDONED MOBILE HOME

OF BONNIE SICELY

NOTICE OF HEARING

A hearing on Champlain Housing Trust, Inc.’s Verified Complaint to declare as abandoned the mobile home of Bonnie Sicely located at the French Hill Manor Mobile Home Park, on Lot #104, a/k/a 104 French Hill Manor in Williston, Vermont and to approve the sale of the mobile home at a public auction has been set for November 13, 2025 at 10:45 a.m. You may participate in the hearing either in person at the Vermont Superior Court, Chittenden Unit, Civil Division located at 175 Main Street in Burlington, Vermont or remotely via WEBEX video. The WEBEX Login Information is as follows:

App: Cisco Webex Meeting

Website: https://vtcourts.webex.com

Meeting Number: 129 647 6521

Password: CIVIL2

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) 863-3467.

Date: October 16, 2025
Nancy L. Bean, Judicial Assistant

Chittenden Civil Division

VERIFIED COMPLAINT FOR ABANDONMENT

PURSUANT TO 10 V.S.A. § 6249(h) (Auction)

NOW COMES Champlain Housing Trust, Inc. (“CHT”), by and through its counsel Nadine L. Scibek, and hereby complains as follows:

1. CHT, a Vermont non-profit corporation with a principal place of business in Burlington, County of Chittenden, State of Vermont, is the record owner of a mobile home park known as the French Hill Manor Mobile Home Park (the “Park”) located in the Town of Williston, Vermont.

2. Bonnie Sicely (“Sicely”) is the record owner of a certain mobile home described as a 1994 Liberty mobile home, 14’ x 70’, bearing serial No. 08L63848 (the “Mobile Home”), located on Lot #104, French Hill Manor Mobile Home Park, 104 French Hill Manor in Williston, Vermont (the “Lot”). See attached Vermont Mobile Home Uniform Bill of Sale.

3. Sicely leased the lot in the Park for the mobile home from CHT pursuant to a written lease. She did not pay a security deposit. See attached Lease.

4. Sicely is deceased. Her date of death is July 6, 2025. See attached Death Certificate.

5. After Sicely’s passing, on August 27, 2025 Sicely’s son, Shawn Sicely contacted CHT and it’s counsel and indicated that the family had decided to walk away from the mobile home. Mr. Sicely stated that the family had removed all Sicely’s belongings which they wanted to keep and advised that the family would not be pursuing any action with the probate court. See attached email.

6. On October 6, 2025, CHT’s Counsel checked the Vermont Judiciary Public Portal and confirmed that no estate had been opened for Sicely.

7. The last known legal occupant of the Mobile Home was Sicely. The mobile home has been abandoned and has been unoccupied since her death.

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

a. Sicely is in arrears on obligations to pay property taxes to the Town of Williston, Vermont in the aggregate amount of $1,749.78, plus interest and penalties. The delinquent property taxes are now a lien on the property. See attached Tax Bill & Delinquent Tax Report.

9. Uriah Wallace, a duly licensed Vermont auctioneer, is a person disinterested in the Mobile Home and the mobile home park who is able to sell the mobile home at a public auction.

10. Mobile home storage fees continue to accrue at the rate of $522.00 per month. Rent, storage fees and late charges due the Park as of October, 2025 total $10,466.96. Court costs and attorney’s fees incurred by the Park in this action currently exceed $750.00.

11. The Park sent written notice by certified mail to the Town of Williston on May 2, 2025 of its intent to commence this abandonment action. See attached.

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

1. Declare that the mobile home has been abandoned;

2. Approve the sale of the mobile home at a public auction to be held within 15 days of the date of judgment, pursuant to 10 V.S.A. § 6249(h); and

3. Grant judgment in favor of the Park Owner CHT and against the mobile home for past due and unpaid rent and mobile home storage charges through the date of judgment, together with CHT’s court costs, publication and mailing costs, auctioneer’s costs, winterization costs, lot cleanup charges, attorney’s fees incurred in connection with this matter and any other costs incurred by CHT herein.

DATED this 10th day of October, 2025.

CHAMPLAIN HOUSING TRUST, INC.

BY: Nadine L. Scibek

Attorney for CHT

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 10, 2025
By: Taheem Baptiste, Duly Authorized Agent for CHT