IN RE: ABANDONED MOBILE HOME
OF PHILIP L. CROMER

NOTICE OF HEARING

A hearing on The Housing Foundation, Inc.’s Verified Complaint to declare as abandoned and uninhabitable the mobile home of Philip L. Cromer located at the Mountain View Mobile Home Park, Lot #41, 69 Patricia’s Place in Hinesburg, Vermont has been set for Tuesday, June 3, 2025 at 8:30 a.m. at the Vermont Superior Court, Chittenden Unit, Civil Division located at 175 Main Street, Burlington, Vermont. Do not come to the Courthouse. This will be a remote hearing. To participate in this hearing, the WEBEX Login Information is as follows:

App: Cisco Webex Meeting

Website: https://vtcourts.webex.com

Meeting Number: 2347 939 3273

Password: Civil3

If you do not have a computer or sufficient bandwidth, you may call (802) 636-1108 to appear by phone. (This is not a toll free 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) 863-3467.

Date: May 14, 2025 Nancy L. Bean, Judicial Assistant

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 pursuant to 10 V.S.A. § 6249(i) 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 Mountain View Mobile Home Park (the “Park”), located in the Town of Hinesburg, Vermont. The Park is managed by the Vermont State Housing Authority.

2. Philip L. Cromer (“Cromer”) is the record owner of a certain mobile home described as a 1979, Ritzcraft, Serial No. 0105791853, (the “Mobile Home”) located at the Mountain View Mobile Home Park, Lot #41, 69 Patricia’s Place in Hinesburg, Vermont according to the Town of Hinesburg Land Records. See attached Bill of Sale.

3. Cromer leased a lot in the Park from HFI pursuant to a written lease. See attached Lease.

4. Cromer’s last known mailing address is 69 Patricia’s Place, Hinesburg, VT 05461.

5. Cromer was evicted from the Park on or about January 16, 2025 by the Chittenden County Sheriff’s Office. The Court issued a Partial Judgment for Possession and Writ of Possession to HFI on December 6, 2024 and a Judgment Order on January 29, 2025. See The Housing Foundation, Inc. v. Cromer, Vermont Superior Court, Chittenden Civil Unit, Case No. 24-CV-02891. See attached.

6. The last known resident of the mobile home was Cromer. Cromer is believed to still be residing in the mobile home despite the execution of the Writ of Possession on January 16, 2025. He is trespassing. All utility services have been terminated to the Mobile.

7. Park’s Counsel has communicated with Cromer via letter dated February 10, 2025 with respect to his intentions with his mobile home. As of this date, Cromer has failed to remove his mobile home from the Park or sell it to an approved buyer. See attached.

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

a. Cromer is in arrears on obligations to pay property taxes to the Town of Hinesburg, Vermont in the aggregate amount of $1,192.93, plus interest and penalties. See attached copy of Tax Bill and Delinquent Tax Report.

b. Notice of Federal Tax Lien in the original amount of $19,323.77 dated April 3, 2012 and recorded in Volume 224, Page 600 of the Town of Hinesburg Land Records.

9. Mobile home storage fees continue to accrue at the rate of $491.00 per month. Rent/ storage fees due HFI through May, 2025 total $6,865.76. Attorney’s fees and court costs incurred by HFI currently exceed $2,000.00.

10. HFI sent written notice by certified mail to the Town of Hinesburg on March 24, 2025 regarding its intention to commence this action as required by statute. See attached.

11. The mobile home is uninhabitable. Kellie Flynn, Property Manager, 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 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 May 13, 2025

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.

May 13, 2025 BY: Kellie Flynn
Duly Authorized Agent for HFI