IN RE: ABANDONED MOBILE HOME

OF JAMES SMITH JR. & SUSAN SMITH

NOTICE OF HEARING

A hearing on HARR, LLC’s Verified Complaint to declare as abandoned and uninhabitable the mobile home of James Smith Jr. and Susan Smith located at the Northfield Falls Mobile Home Park, Lot #14, 147 Falls Mobile Home Park in Northfield Falls, Vermont has been set for February 23rd, 2026 at 1:00 p.m. You may participate in the hearing either in person at the Vermont Superior Court, Washington Unit, Civil Division located at 65 State Street in Montpelier, Vermont or remotely via WEBEX video. The WEBEX Login Information is as follows:

App: Cisco Webex Meeting

Website: https://vtcourts.webex.com

Meeting Number: 2339 098 0087

Password: Civil1

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) 828-2091.

Date: January 29, 2026 Judicial Assistant

VERIFIED COMPLAINT FOR ABANDONMENT

PURSUANT TO 10 V.S.A. § 6249(i) (Uninhabitable)

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

1. HARR, a Vermont domestic limited liability company with a principal place of business in Berlin, County of Washington, State of Vermont, is the record owner of a mobile home park known as the Northfield Falls Mobile Home Park (the “Park”), located in the Town of Northfield Falls, Vermont.

2. James Smith and Susan Smith (the “Smiths”) are the record owners of a certain mobile home described as a 2006 14’ x 80’ mobile home, bearing Serial #007-017-193A-000-14 (the “Mobile Home”) located on Lot #14, Northfield Falls Mobile Home Park, 147 Falls Mobile Home Park in Northfield Falls, Vermont. See attached Bill of Sale.

3. The Smiths leased a lot in the Park for their mobile home from HARR pursuant to a written lease. The Smiths paid a security deposit in the amount of $345.00 to HARR. See attached Lease.

4. The Smiths are both deceased. James Smith’s date of death is April 7, 2025 and Susan Smith’s date of death is August 16, 2006. See attached Death Certificates.

5. No petition to open a probate estate has been filed for either Smith per the Washington County Probate Court.

6. The last known resident of the mobile home was James Smith. The mobile home has been abandoned and is unoccupied. The Mobile Home is in poor condition. James Smith’s brother Steve Smith indicated to HARR that no family member had any interest in the mobile home and that they had no intention of paying the lot rent or the bank payments on the Mobile Home.

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 Northfield are current according to the Town Clerk. See attached Tax Bill & email from Town Clerk.

b. UCC Financing Statement #06-199555 to Tammac Holdings Corporation, dated June 12, 2006 on record with the Vermont Secretary of State’s Office. See attached UCC Financing Statement.

8. Mobile home storage fees continue to accrue at the rate of $523.00 per month. Rent, storage fees and late charges due HARR as of January, 2026 total $5,263.00. Court costs and attorney’s fees from this action to date exceed $1,000.00. See attached Account History.

9. HARR sent written notice by certified mail to the Town of Northfield on December 18, 2025 of HARR’s intent to commence this abandonment action as required by statute. See attached.

10. The mobile home is uninhabitable. Randy Rouleau, duly authorized agent for HARR will testify under oath as to the poor and unlivable condition of this mobile home at the abandonment hearing.

WHEREFORE, HARR 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 that is unfit for human habitation to Park owner

HARR 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 28, 2026.

HARR, LLC

BY: Nadine L. Scibek

Attorney for HARR, LLC

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 28, 2026 BY: Randy Rouleau

Duly Authorized Agent for HARR, LLC