IN RE: ABANDONED MOBILE HOME

OF JUSTIN LOOMIS

NOTICE OF HEARING

A hearing on The Housing Foundation, Inc.’s Verified Complaint to declare abandoned and uninhabitable the mobile home of Justin Loomis located at the Fernwood Manor Mobile Home Park, Lot #40A, 104 East Street in Bolton, Vermont has been set for March 4, 2026 at 10:00 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 Zoom video. The Zoom Login Information is as follows:

App: “Zoom Workplace” or “Zoom Cloud Meetings”

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Meeting ID Number (access code): 160 481 0861

Meeting Passcode: 426268

If you do not have a computer or sufficient bandwidth, to appear by phone dial (833) 435-1820. When prompted enter the meeting ID number listed above, listen for the prompt, and enter the meeting ID followed by the “#” key. Then, enter the passcode followed by the “#” key if prompted and press “#” to skip the participant ID. If you have technical difficulties, call the Court at (802) 863-3467

Date: February 3, 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 pursuant to 10 V.S.A. § 6249(i) 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 Fernwood Manor Mobile Home Park (the “Park”), located in the Town of Bolton, Vermont. The Park is managed by the Vermont State Housing Authority.

2. Justin Loomis (“Loomis”) is the record owner of a certain mobile home described as a 1978 Oxford mobile home, 72’ x 14’, bearing Serial #OHM486, (the “Mobile Home”) located at the Fernwood Manor Mobile Home Park, Lot #40A, 104 East Street in Bolton, Vermont according to the Town of Bolton Land Records. See attached Vermont Mobile Home Bill of Sale.

3. Loomis leased a lot in the Park from HFI pursuant to a written lease. Loomis paid a security deposit in the amount of $250.00 to HFI. See attached Lease.

4. Loomis’s last known mailing address is 104 East Street, Waterbury, VT 05676.

5. The mobile home has been abandoned and is empty/unoccupied. The last known resident of the mobile home was Loomis. All of Loomis’s personal property is believed to have been removed from the mobile home and utility services have been terminated. The Park’s Counsel has communicated with Loomis with respect to his intentions with her mobile home. On November 25, 2025 Loomis contacted the Park’s Counsel via telephone and stated that he was working on moving or selling the mobile home. To date, Loomis has not sold the mobile home nor removed it from the Park. See attached.

6. Loomis was evicted from the Park for nonpayment of rent on or about September 4, 2025 by the Chittenden County Sheriff’s Department. The mobile home has been vacant since that time. The Court issued a Judgment Order and Writ of Possession to HFI on August 6, 2025. See The Housing Foundation, Inc. v. Loomis, Vermont Superior Court, Chittenden Civil Unit, Case No. 25-CV-01340. See attached.

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

a. Loomis is in arrears on obligations to pay property taxes to the Town of Bolton, Vermont in the aggregate amount of $276.15, plus interest and penalties. See attached copy of Tax Bill and Delinquent Tax Report.

b. Maybe subject to UCC Financing Statement #07-212672 to Tammac Holdings Corporation dated October 2, 2007 filed with the Vermont Secretary of State. See attached UCC Financing Statement.

8. Mobile home storage fees continue to accrue at the rate of $532.00 per month. Rent/ storage fees due HFI through January, 2026 total $5,694.63. Attorney’s fees and court costs incurred by HFI currently exceed $2,000.00.

9. HFI sent written notice by certified mail to the Town of Bolton on January 6, 2026 of its intent to commence this action. See attached.

10. The mobile home is uninhabitable. Katie Edmunds, Property Manager, 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 which is unfit for human habitation to the Park owner

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 January 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.

January 30, 2026 BY: Katie Edmunds

Duly Authorized Agent for HFI