VERIFIED COMPLAINT FOR ABANDONMENT PURSUANT TO TITLE 10 V.S.A. § 6249(i} (Uninhabitable)

NOW COMES Falcon Management Company, Inc., by and through counsel Peter B. Schubart, and hereby complains pursuant to Title 10 V.S.A. § 6249(i) as follows:

1. Falcon Management Company, Inc., a Vermont domestic business corporation with a principal place of business in the Town of Richmond, County of Chittenden, State of Vermont, is the record owner of a mobile home park known as the Riverview Commons Mobile Home Park (the “Park”), located in Richmond, Vermont.

2. Catherine A. Burritt is the record owner of a certain mobile home (the “Mobile Home”) described as 1977 Skyline, 14’ x 70’ (Serial no. 0216-0452K) located at the Riverview Commons Mobile Home Park, Lot #155, 378 Meadow Lane in Richmond, Vermont. A Mobile Home Bill of Sale dated September 11, 1998, is of record in the Town of Richmond Land Records. (A copy of the bill of sale is attached hereto as Exhibit 1)

3. Catherine A. Burritt leased a lot in the Park from Falcon Management Company pursuant to a written lease. There is no security deposit.

4. Catherine A. Burritt is deceased. A review of the Vermont Judiciary website indicates that no Probate Estate has been opened for Catherine A. Burritt.

5. The mobile home has been abandoned and is empty. A Notice to Vacate was sent to the Decedent’s son-in -law, Jeff Andrews, who occupied the mobile home on lot #155 in the park after Mrs. Burritt’s passing. The letter is attached hereto as Exhibit 2. Upon information and belief, Mr. Andrews moved out of the mobile home on or about April 15, 2026. To date, no party has made effort to remove the mobile home.

6. Falcon Management Company, Inc. has had no communication with the last known occupant of the mobile home, Jeff Andrews.

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

1. Taxes are owed to Town of Richmond in the amount of $2,773.02.

2. Mobile home storage fees continue to accrue at the rate of $615.00 per month. The total unpaid rent is now $5,120.00.

Falcon Management Company, Inc. sent written notice by certified mail to the Town of Richmond on July 21, 2026 of intent to commence this action. (See attached Exhibit 3).

The mobile home is uninhabitable. Jeffrey Bishop, Property Manager for the Park, will testify under oath as to the poor and unlivable condition of this mobile home at the abandonment hearing. (Exhibit 4)

WHEREFORE, Falcon Management Company, Inc. 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 Park owner Falcon Management Company, Inc. without a public auction so that it may be removed and disposed of accordingly.

3. Order pursuant to 10 V.S.A. § 6249(i) that the mobile home and any security deposit paid be conveyed to Falcon Management Company, Inc. in “as is” condition, and free from all liens and other encumbrances of record.

DATED AT South Burlington, Vermont this 20th day of August, 2026.

Falcon Management Company, Inc.

By: /s/ Peter B. Schubart

Peter B. Schubart, Esq.,

80 Midas Drive, South Burlington, VT 05403

(802) 829-0237/ peter@schubartlaw.com