in RE: ABANDONED MOBILE HOME

OF ASHLEY WELLS

NOTICE OF HEARING

A hearing on Ship Sevin II, LLC’s Verified Complaint to declare abandoned and uninhabitable the mobile home of Ashley Wells located at the Pinecrest Mobile Home Park, Lot #44, 13 First Street in Morrisville, Vermont has been set for February 17th, 2026 at 8:30 a.m. You may participate in the hearing either in person at the Vermont Superior Court, Lamoille Unit, Civil Division located at 154 Main Street in Hyde Park, Vermont or remotely via WEBEX video. The WEBEX Login Information is as follows:

App: Cisco Webex Meeting

Website: https://vtcourts.webex.com

Meeting Number: 2335 590 2963

Password: LamoilleCR1

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) 888-3887.

Date: January 30, 2026
Ashley Harvey, Judicial Assistant

Lamoille Unit

VERIFIED COMPLAINT FOR ABANDONMENT

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

NOW COMES Ship Sevin II, LLC (“Ship Sevin”), by and through its Counsel Nadine L. Scibek, and hereby complains pursuant to 10 V.S.A. § 6249(i) as follows:

1. Ship Sevin, a Vermont limited liability company with a principal place of business in South Burlington, County of Chittenden, State of Vermont, is the record owner of a mobile home park known as the Pinecrest Mobile Home Park (the “Park”), located in Morrisville, Vermont.

2. Ashley Wells (“Wells”) is the record owner of a certain mobile home described as a 1994 Skyline, 14’ x 72’, bearing serial number 6816-01576 (the “Mobile Home”) located at the Pinecrest Mobile Home Park, Lot #44, 13 First Street in Morrisville, Vermont according to the Town of Morristown Land Records. See attached Bill of Sale.

3. Wells leased a lot in the Park from Ship Sevin pursuant to a written lease. Wells paid Ship Sevin a security deposit of $363.00. See attached Lease.

4. Wells’ last known mailing address is 13 First Street, Morrisville, VT 05661.

5. Wells was evicted from the Park for nonpayment of rent on or about August 19, 2025 by the Lamoille County Sheriff’s Department. The mobile home has been vacant since that time. The Court issued a Judgment and Writ of Possession to Ship Sevin on July 23, 2025. See Ship Sevin II, LLC v. Wells, Vermont Superior Court, Lamoille Civil Unit, Case No. 25-CV-02397. See attached.

6. The mobile home has been abandoned and is empty. The last known resident of the mobile home was Wells. All of Wells’ personal property is believed to have been removed from the mobile home and utility services have been terminated. On August 27, 2025, the Park’s Counsel communicated with Wells via regular mail and email with respect to her intentions with her mobile home. Ship Sevin has received no response from Wells. See attached.

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

a. Wells is in arrears on obligations to pay property taxes to the Town of Morristown, Vermont in the aggregate amount of $1,044.47, plus interest and penalties. Additionally, the Town of Morristown has filed a Notice of Lien on Real Property in the amount of $607.69 dated December 1, 2025 and recorded in Volume 363, Page 296 of the Morristown Land Records. See attached copy of Tax Bill, Delinquent Tax Statement and Notice of Lien on Real Property.

b. Wells is in arrears on obligations to pay electric bills to Morrisville Water & Light Department in the amount of $162.13.

8. Mobile home storage fees continue to accrue at the rate of $435.00 per month. Rent/ storage fees due Ship Sevin through January, 2026 total $5,615.00. Attorney’s fees and court costs incurred by Ship Sevin currently exceed $3,000.00.

9. Ship Sevin sent written notice by certified mail to the Town of Morristown on November 20, 2025 of its intent to commence this action. See attached.

10. The mobile home is uninhabitable. Cindy Whitham, Property Manager, will testify under oath as to the poor and unlivable condition of this mobile home at the abandonment hearing.

WHEREFORE, Ship Sevin 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 January 29, 2026.

SHIP SEVIN II, LLC

BY: Nadine L. Scibek

Attorney for Ship Sevin II, 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 29, 2026
BY: Cindy Whitham

Duly Authorized Agent for Ship Sevin II, LLC