In Re: Abandoned Mobile Home
Of Tina Miller N/K/A Tina Miller-Merriam

NOTICE OF HEARING

A hearing on Ship Sevin LLC’s Verified Complaint to declare as abandoned the mobile home of Tina Miller-Merriam located at the Triple L Mobile Home Park (a 1997 Commadore Sandpiper, 14’ x 80’, bearing Serial No. CW32197A) located on Lot #61 at 2173 North Road in Hinesburg, Vermont and to approve the sale of the mobile home at a public auction has been set for September 24, 2026 at 10:15 a.m in person at the Vermont Superior Court, Chittenden Unit, Civil Division located at 175 Main Street in Burlington, Vermont.

Date: September 2, 2026

Nancy L. Bean, Judicial Assistant

Chittenden Civil Division

VERIFIED COMPLAINT FOR ABANDONMENT PURSUANT TO 10 V.S.A. § 6249(h) (Auction)

NOW COMES SHIP SEVIN, LLC (“Ship Sevin”), by and through its counsel Nadine L. Scibek, and hereby complains as follows:

1. Ship Sevin, LLC, a Vermont limited liability company with a principal place of business in South Burlington, County of Chittenden, State of Vermont, is the record owner of a mobile home park known as the Triple L Mobile Home Park (the “Park”) located in the Town of Hinesburg, Vermont.

2. Tina Miller n/k/a Tina Miller-Merriam (“Miller-Merriam”) the record owner of a certain mobile home described as a 1997 Commadore Sandpiper, 14’ x 80’, bearing serial No. CW32197A (the “Mobile Home”), located on Lot #61, Triple L Mobile Home Park, 2173 North Road in Hinesburg, Vermont (the “Lot”). See attached Vermont Mobile Home Uniform Bill of Sale.

3. Miller-Merriam leased Lot #61 in the Park from Ship Sevin pursuant to a written lease. Miller-Merriam paid a security deposit in the amount of $350.00 to Ship Sevin. See attached Lease.

4. Miller-Merriam’s last known mailing address is 2173 North Road, Hinesburg, VT 05461.

5. The mobile home has been abandoned and is empty/unoccupied. The last known resident of the mobile home was Miller-Merriam. Miller-Merriam is believed to have removed her personal belongings. Utility services have been terminated to the Mobile Home.

6. Miller-Merriam was evicted from the Park for non-payment of lot rent on April 27, 2026. A Judgment Order for the outstanding lot rent and court costs was entered against Miller-Merriam on February 27, 2026 in the amount of $4,753.73. See Ship Sevin, LLC v. Miller-Merriam, Vermont Superior Court, Chittenden Civil Unit, Case No. 26-CV-03974. See attached Judgment Order, Alias Writ of Possession & Sheriff’s Return of Service.

7. Ship Sevin’s Counsel has attempted to communicate with Miller-Merriam with no response. See attached letter.

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

a. Miller-Merriam is in arrears on obligations to pay property taxes to the Town of Hinesburg, Vermont in the aggregate amount of $3,539.84, plus interest and penalties. The delinquent property taxes are now a lien on the property. See attached Tax Bill & Delinquent Tax Report.

b. Judgment Order in the matter of Ship Sevin, LLC v. Tina Miller-Merriam, Case No. 24-CV-03594 dated May 3, 2025 and recorded in Book 294, Page 46 of the Town of Hinesburg Land Records. See attached.

9. Uriah Wallace, a duly licensed 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 $498.00 per month. Rent, storage fees and late charges due the Park as of August, 2026 total $5,025.00. Court costs and attorney’s fees incurred by the Park exceed $7,000.00.

11. The Park sent written notice by certified mail to the Town of Hinesburg on July 28, 2026 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 Ship Sevin and against the mobile home for unpaid rent and mobile home storage charges through the date of judgment, together with Ship Sevin’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 Ship Sevin herein.

DATED this 1st day of September, 2026.

SHIP SEVIN, LLC

BY: Nadine L. Scibek

Attorney for Ship Sevin

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.

September 1, 2026

By: Cindy Whitham

Duly Authorized Agent for Ship Sevin