State of Vermont Superior Court, Civil Division, Chittenden Unit, Case No. 26-CV-03694. In Re: Abandoned Mobile Home Richard Hough.

Notice Of Hearing

A hearing on Woodland Shores Park, RLLP’s verified Complaint to declare the mobile home of Richard Hough located at the Woodland Shores Mobile Home Park (2005 Commodore 14’x72’ with a serial number of CD43951A) on Lot #49, 12 Hawthorne Lane in Colchester, Vermont to authorize the transfer without a public auction, so it may be removed and disposed of, has been set for July 16, 2026 @11:00AM.

Date: June 30, 2026 Civil Division Clerk.

VERIFIED COMPLAINT FOR ABANDONMENT

NOW COMES Woodland Shores Park, RLLP, by and through its attorney, Bennett & Zaikowski, P.C., and hereby makes this their complaint:

1. Woodland Shores Park, RLLP is a Vermont Registered Limited Liability Partnership which is the record owner of a mobile home park known as Woodland Shores Mobile Home Park, located in the Town of Colchester, Vermont (“the Park”).

2. Woodland Shores Park, RLLP is a duly authorized Vermont Registered Limited Liability Partnership with a principal place of business in Colchester, Chittenden County, Vermont. (“Woodland Shores”)

3. Richard Hough (“Hough”) is the owner of a certain mobile home, described as a 2005 Commodore 14’ x 72’ with a serial number of CD43951A, (the “Mobile Home”), located on a lot at the Park. Exhibit 1.

4. Upon information and belief, “Hough” is deceased and no estate has been opened.

5. The last known mailing addresses for “Hough” are 12 Hawthorne Lane, Lot 49, Colchester Vermont, 05446 and P.O. Box 3051, Burlington, Vermont, 05408.

6. “Hough” leased a lot in the Park from Woodland Shores under the terms of a Lease Agreement and occupied the mobile home lot known as 12 Hawthorne Lane, Lot 49, Colchester, Vermont, 05446. Exhibit 2.

7. The mobile home has been abandoned. The last known resident at the mobile home was Richard Hough.

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

a. Upon information and belief, Richard Hough is in arrears on obligations to pay property taxes to the Town of Colchester, Vermont.

9. Upon information and belief, the mobile home is unfit for human habitation due to the following issues:

a. The heating system is not functioning;

b. Upon information and belief, the home was not winterized after the occupant vacated;

10. Uriah Wallace is a person disinterested in the mobile home or mobile home park who is able to sell the mobile home at a public auction.

11. The last known employer of “Hough” is unknown.

12. Lot rent has not been paid since May 1, 2023 and the outstanding amount owed since May 1, 2023 is $20,631.61 through June 2026.

13. Woodland Shores sent written notice to the Town Clerk of the Town of Colchester on May 15, 2026, of Plaintiff’s intent to commence this action. See copy of certified letter to Julie Graeter dated May 15, 2026, attached as Exhibit 3.

14. Woodland Shores sent written notice to the Treasurer of the Town of Colchester on May 15, 2026, of Plaintiff’s intent to commence this action. See copy of certified letter to Julie Graeter dated May 15, 2026, attached as Exhibit 4.

15. Woodland Shores sent written notice to the Owner of the Home and most recent occupant, Richard Hough, at his mailing address on May 15, 2026 of Plaintiff’s intent to commence this action. See copy of certified letter to dated May 15, 2026, attached as Exhibit 5.

16. Woodland Shores sent written notice to the Owner of the Home and most recent occupant, Richard Hough, at his mobile home on May 15, 2026 of Plaintiff’s intent to commence this action. See copy of certified letter to dated May 15, 2026, attached as Exhibit 6.
WHEREFORE, Plaintiff respectfully requests that the Honorable Court enter an order in Plaintiff’s favor as follows:

1. Declaring that the mobile home has been abandoned and is unfit for habitation;

2. Granting judgment in favor of Plaintiff and against the mobile home owner for past due and unpaid rent through the date of judgment, together with Plaintiff’s court costs, publication and mailing costs, and Plaintiff’s counsel fees incurred in connection with this matter.

3. Approving transfer of the Woodland Shores Park, RLLP pursuant to 10 V.S.A. §6249(i).

4. In the alternative to (3) if the home is found fit for human habitation, approving the sale of the mobile home at a public auction to be held within 15 days of the date of judgment, pursuant to 10 V.S.A. §6249(h).

DATED June 29, 2026

Woodland Shores Park, RLLP

Angela N. Zaikowski

Attorney for Woodland Shores

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.

June 19, 2026 BY: Dieter Mulac
Duly Authorized Agent for Woodland Shores