VERIFIED COMPLAINT FOR ABANDONMENT PURSUANT TO TITLE 10 V.S.A. § 6249(h)
NOW COMES Falcon Management Company, Inc., by and through counsel Peter B. Schubart, and hereby complains pursuant to Title 10 V.S.A. § 6249(h) 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. Bessie Burritt is the record owner of a certain mobile home (the “Mobile Home”)described as 1977 Vista Mobile Home, 12’ x 70’’ (Serial no. 2280) located at the Riverview Commons Mobile Home Park, Lot #125, 95 Field Lane in Richmond,Vermont. A Mobile Home Bill of Sale dated March 15, 2015, is of record in the Town of Richmond Land Records. (A copy of the bill of sale is attached hereto as Exhibit 1)
3. The Mobile Home Bill of Sale indicates that the mobile home was owned as joint tenants with Evelyn Lunderville. A copy of Evelyn Lunderville’s obituary as posted on www.obituary.com is attached hereto as Exhibit 2.
4. Bessie Burritt died on March 15, 2026. A copy of Bessie Burritt’s obituary as posted on www.obituary.com is attached hereto as Exhibit 3.
5. Bessie Burritt’s last known mailing address is 95 Field Lane, Richmond, VT 05477.
6. The mobile home has been abandoned and is empty. To date, no relatives of Mrs. Burritt have contacted Falcon Management Company , Inc. about acquiring the home. Further, no Probate Estate has been opened for Bessie Burritt.
7. On May 1, 2026, Donna Burritt, relative of the Decedent, Bessie Burritt, turned over keys to the mobile home to Counsel, stating that no one in her family wishes to acquire the home. A copy of the key receipt is attached hereto as Exhibit 4.
8. Falcon Management Company, Inc. sent written notice by certified mail to the Town of Richmond on August 18, 2026, regarding its intent to commence this action. (See attached Exhibit 5).
9. Falcon Management Company, Inc. is not holding a security deposit.
The following security interests, mortgages, liens and encumbrances appear of record with respect to the mobile home:
1. Unpaid Rent due Falcon Management Company, Inc. is $4,350.00 (Exhibit 6). Attorney fees and court costs incurred by Falcon Management Company, Inc. are $2,000.00
2. Mobile home storage fees continue to accrue at the rate of $630.00 per month.
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. Order pursuant to 10 V.S.A. § 6249(h) that Falcon Management Company, Inc. may arrange to have mobile home sold at public auction by the Thomas Hirschak Company of Williston, Vermont.
DATED at South Burlington, Vermont this 1st day of October, 2026.
Falcon Management Company, Inc.
By: /s/ Peter B. Schubart, Esq.
Peter B. Schubart, Esq.,
80 Midas Drive,
South Burlington, VT 05403
(802) 829-0237