State Of Vermont Superior Court, Civil Division, Caledonia Unit Case No. 26-Cv-05264, IN RE: ABANDONED MOBILE HOME OF DORIS GOMEZ, NOTICE OF HEARING, A hearing on Lamoille Housing Partnership, Inc.’s Verified Complaint to declare as abandoned and uninhabitable the mobile home of Doris Gomez located at the Evergreen Manor Mobile Home Park, Lot #4, 72 Spruce Drive in Hardwick, Vermont has been set for Thursday, November 5, 2026 at 2:45 p.m. You may participate in the hearing either in person at the Vermont Superior Court, Caledonia Unit, Civil Division located at 1126 Main Street, Suite 1 in St. Johnsbury, Vermont or remotely via Zoom video. The Zoom Login Information is as follows:

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Date: October 02, 2026

Alan Glassman

Vermont Superior Court Judicial Assistant

VERIFIED COMPLAINT FOR ABANDONMENT

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

NOW COMES Lamoille Housing Partnership, Inc. (“LHP”), by and through its counsel Nadine L. Scibek, and hereby complains as follows:

1. LHP, a Vermont domestic nonprofit corporation with a principal place of business in Morrisville, County of Lamoille, State of Vermont, is the record owner of a mobile home park known as the Evergreen Manor Mobile Home Park (the “Park”), located in the Town of Hardwick, Vermont.

2. Doris Gomez (“D. Gomez”) is the record owner of a certain mobile home described as a 1987 Skyline Hampshire mobile home, 14’ x 70’, bearing Serial #2216-0297 (the “Mobile Home”) located on Lot #4, Evergreen Manor Mobile Home Park, 72 Spruce Drive in Hardwick, Vermont. See attached Bill of Sale.

3. D. Gomez leased Lot #4 in the Park from LHP pursuant to a written lease. D. Gomez paid a security deposit to LHP in the amount of $229.00. See attached Lease.

4. D. Gomez is deceased. Her date of death was November 22, 2021. See attached State of Vermont Death Certificate.

5. After D. Gomez’s passing, her brother-in-law, Rudolph Gomez (“R. Gomez”), occupied the mobile home and leased Lot #4 in the Park from LHP pursuant to a written lease. R. Gomez died on February 6, 2026. See attached Lease and State of Vermont Death Certificate.

6. The last known resident of the mobile home was R. Gomez. The mobile home has been abandoned and is unoccupied. On August 20, 2026 LHP’s Attorney spoke with D. Gomez’s son, Roland Gerhart. Mr. Gerhart was informed that the mobile home was uninhabitable and that there was delinquent lot rent owed in the amount of $4,160.00 to LHP. Mr. Gerhart indicated that he believed D. Gomez had left him the mobile home in her Will. Mr. Gerhart was informed that he would need to open an estate with the Caledonia County Probate Court in order to transfer the title of the mobile home. Mr. Gerhart indicated that he would open an estate as soon as possible. To date, no estate has been opened in the Caledonia Probate Court. LHP has not heard anything further from Mr. Gerhart or any other individual regarding this mobile home.

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

a. D. Gomez is in arrears on obligations to pay property taxes to the Town of Hardwick, Vermont in the amount of $376.97, plus interest and penalties for delinquent taxes. See attached Tax Bill & Delinquent Tax Report.

8. Mobile home storage fees continue to accrue at the rate of $424.00 per month. Rent, storage fees and late charges due LHP as of September, 2026 total $4,584.00. Court costs and attorney’s fees from this action to date exceed $1,000.00. See attached Account History.

9. LHP sent written notice by certified mail to the Town of Hardwick on August 12, 2026 of LHP’s intent to commence this abandonment action as required by statute. See attached.

10. The mobile home is uninhabitable. April Kelly, duly authorized agent for LHP will testify under oath as to the unlivable condition of this mobile home at the hearing.

WHEREFORE, LHP 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

LHP 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 September 30, 2026.

LAMOILLE HOUSING PARTNERSHIP, INC.

BY: Nadine L. Scibek

Attorney for LHP

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 30, 2026

BY: April Kelly

Duly Authorized Agent for LHP