IN RE: ABANDONED MOBILE HOME

OF BARBARA PAYNE (A/K/A BARBRA PAYNE)

NOTICE OF HEARING

A hearing on The Housing Foundation, Inc.’s Verified Complaint to declare as abandoned and uninhabitable the mobile home of Barbara Payne located at the Fernwood Manor Mobile Home Park, Lot #30A, 171 East Street in Bolton, Vermont has been set for Thursday, September 17, 2026 at 8:45 a.m. in person at the Vermont Superior Court, Chittenden Unit, Civil Division located at 175 Main Street in Burlington, Vermont.

Date: August 18, 2026

Nancy L. Bean, Judicial Assistant

Chittenden Unit

VERIFIED COMPLAINT FOR ABANDONMENT

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

NOW COMES The Housing Foundation, Inc. (“HFI”), by and through its counsel Nadine L. Scibek, and hereby complains as follows:

1. HFI, a Vermont non-profit corporation with a principal place of business in Montpelier, County of Washington, State of Vermont, is the record owner of a mobile home park known as the Fernwood Manor Mobile Home Park located in the Town of Bolton, Vermont (the “Park”). The Park is managed by the Vermont State Housing Authority.

2. Barbara Payne (a/k/a Barbra Payne) (“Payne”) is the record owner of a certain mobile home, described as a 1982 Oxford, bearing serial number OHM2046 (the “Mobile Home”), located on Lot #30A, Fernwood Manor Mobile Home Park, 171 East Street in Bolton, Vermont. See attached Bill of Sale.

3. Payne leased a lot in the Park for the mobile home from HFI pursuant to a written lease. Payne paid a security deposit in the amount of $505.00 to HFI. See attached Lease.

4. Payne is deceased. Her date of death is April 3, 2026. See attached Death Certificate and Obituary.

5. No petition to open a probate estate has been filed for Payne per the Chittenden County Probate Court.

6. The last known resident of the mobile home was Payne. The mobile home has been abandoned and is unoccupied. Payne did not provide any emergency contact information nor next of kin information to HFI. No one has contacted HFI on behalf of Payne regarding the mobile home.

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

a. Payne is in arrears on obligations to pay property taxes to the Town of Bolton, Vermont in the amount of $450.63, 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 $558.00 per month. Rent, storage fees and late charges due HFI as of August, 2026 total $2,748.00. Court costs and attorney’s fees from this action to date exceed $750.00. See attached Account History.

9. HFI sent written notice by certified mail to the Town of Bolton on June 16, 2026 of HFI’s intent to commence this abandonment action as required by statute. See attached.

10. The mobile home is uninhabitable. Tyler Willis, Property Manager and duly authorized agent for the Park owner, will testify under oath as to the poor and unlivable condition of this mobile home at the abandonment hearing.

WHEREFORE, HFI 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 HFI 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 August 18, 2026.

THE HOUSING FOUNDATION, INC.

BY: Nadine L. Scibek

Attorney for HFI

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.

August 18, 2026

BY: Tyler Willis

Duly Authorized Agent for HFI