IN RE: ABANDONED MOBILE HOME OF TODD TOWSLEY

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. Todd Towsley is the record owner of a certain mobile home (the “Mobile Home”) described as 1973 Hillcrest, Model Skyline, 12’ x 70” (Serial no. 0211-2472G) located at the Riverview Commons Mobile Home Park, Lot #40, 210 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 268 at Page 264. (A copy of the first page of said bill of sale is attached hereto as Exhibit1)

3. Todd Towsley leased a lot in the Park from Falcon Management Company pursuant to a written lease. There is no security deposit.

4. Todd Towsley’s last known mailing address is 210 Lower Circle, Richmond, VT 05477.

5. The mobile home has been abandoned and is empty. Falcon Management Company, Inc. evicted Todd Towsley from the lot in the park (Chittenden Unit Civil Docket no. 24-CV02265, Falcon Management Company Inc. V. Todd Townley) 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 September 1, 2025. To date, Todd Towsley has made no effort to remove the mobile home. Falcon Management Company staff has allowed Mr. Towsley to retrieve personal items from the mobile home.

6. Counsel for Falcon Management Company, Inc. has attempted to communicate via text writing with Mr. Towsley on August 25, 2025 regarding his intentions with the vacant mobile home. He has failed to respond. Counsel also emailed Mr. Towsley on January 12, 2026 asking about his intentions with 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 $1,157.87.

2. Vermont State Employees Credit Union has a Judgment Order in the amount of $7,942.42, as of June 25, 2025 in Volume 278 Page 10 in said Land Records;

3. There is a State of Vermont Tax Lien dated November 9, 2023, in the amount of $2,760.73, recorded in Volume 272 at Page 42 in the Town of Richmond Land Records;

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

5. Unpaid Rent since Judgement, Judgment amount, and service fees due Falcon

Management Company, Inc. as of December 31, 2025 total $6,905.00. Attorney fees and court costs incurred by Falcon Management Company, Inc. currently exceed $5,000.00.

Falcon Management Company, Inc. sent written notice by certified mail to the Town of Richmond on November 24, 2025 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.

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 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 15th day of January, 2026.

Falcon Management Company, Inc.

By:
/s/ Peter B. Schubart
Peter B. Schubart, Esq.,
80 Midas Drive, South Burlington, VT 05403
(802) 829-0237 / peter@schubartlaw.com

VERIFICATION

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.

Date: JAN. 15, 2026

/s/ Jeffrey Bishop
Jeffrey Bishop, Duly Authorized Agent, Falcon Management Company, Inc.