A hearing on The Housing Foundation, Inc.’s Verified Complaint to declare as abandoned and uninhabitable the mobile home of Jason Richards located at the Birchwood Manor Mobile Home Park (1966 Atlantic FK, 54’ x 10’, Serial No. 2598) on Lot #24, 148 Dewey Drive in Milton, Vermont, to authorize the transfer without public auction, so it may be removed and disposed of, has been set for June 18, 2026 at 11:15 a.m. in person at the Vermont Superior Court, Chittenden Unit, Civil Division located at 175 Main Street in Burlington, Vermont.

Date: May 28, 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 Birchwood Manor Mobile Home Park (the “Park”), located in the Town of Milton, Vermont. The Park is managed by the Vermont State Housing Authority.

2. Jason Richards (“Richards”) is the record owner of a certain mobile home described as a 1966 Atlantic FK, 54’ x 10’, bearing Serial #2598 (the “Mobile Home”) located at the Birchwood Manor Mobile Home Park, Lot #24, 148 Dewey Drive in Milton, Vermont according to the Town of Milton Land Records. See attached Vermont Mobile Home Bill of Sale.

3. Richards leased a lot in the Park from HFI pursuant to a written lease. Richards paid a security deposit in the amount of $308.00 to HFI. See attached Lease.

4. Richards’s last known mailing address is 148 Dewey Drive, Milton, VT 05468.

5. The last known resident of the mobile home was Richards. Richards vacated the Mobile Home on or about January 24, 2026. The mobile home has been unoccupied/abandoned since that time.

6. Richards indicated to HFI via email on January 21, 2026 that he was moving to Florida and he was planning on demolishing the mobile home. HFI”s Counsel attempted to contact Richards via email with respect to his intentions regarding his mobile home. HFI has received no response from Richards. Richards has stopped communicating with HFI. See attached correspondence.

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

a. Property taxes to the Town of Milton are current according to the Town Clerk. However, current year taxes in the amount of $220.92 are due May 15, 2026. See attached Tax Bill and email from Town of Milton.

b. Richards is in arrears on obligations to pay water/sewer bills to the Town of Milton, Vermont in the aggregate amount of $1,374.04, plus interest and penalties. See attached email from Town of Milton.

8. Mobile home storage fees continue to accrue at the rate of $436.00 per month. Rent/ storage fees due HFI through May, 2025 total $2,600.63. Attorney’s fees and court costs incurred by HFI currently exceed $900.00.

9. HFI sent written notice by certified mail to the Town of Milton on April 13, 2026 of its intent to commence this action. See attached.

10. The mobile home is uninhabitable. Property Manager Tyler Willis 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 May 26, 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.

May 26, 2026

BY: Tyler Willis

Duly Authorized Agent for HFI