State of Vermont Superior Court Civil Division Chittenden Unit Case No. 24-Cv-01745 

In Re: Abandoned Mobile Home

Of Lana Weidner (F/K/A Lana Long Hoang) & Hung Nguyen

NOTICE OF HEARING

A hearing on CDI Development Fund, Inc.'s Verified Complaint to declare as abandoned the mobile home of Lana Weidner (f/k/a Lana Long Hoang) and Hung Nguyen located at the North Avenue Co-op, 21 Avenue C in Burlington, Vermont and to authorize the sale by auction has been set for Thursday, June 6, 2024 at 10:00 a.m. You may participate in the hearing either in person at the Vermont Superior Court, Chittenden Unit, Civil Division located at 175 Main Street in Burlington, Vermont or remotely via WEBEX video. The WEBEX Login Information is as follows:

App: Cisco Webex Meetings

Website: https://vtcourts.webex.com

Meeting Number: 129 647 6521

Password: CIVIL2

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) 863-3467.

Date: May 7, 2024 Nancy L. Bean, Judicial Assistant

VERIFIED COMPLAINT FOR ABANDONMENT

PURSUANT TO 10 V.S.A. § 6249(h) (Auction)

NOW COMES NOW COMES CDI Development Fund, Inc. ("CDI"), by and through its counsel Nadine L. Scibek, and hereby complains as follows:

1. CDI, a foreign non-profit corporation with a principal place of business in Shelburne Falls, Massachusetts is the record owner of a mobile home park located on North Avenue in Burlington, Vermont. This Park which was formerly known as Farrington's Mobile Home Park is now known as the North Avenue Co-op (the "Park"). CDI purchased the Park in November, 2015.

2. Lana Weidner (f/k/a Lana Long Hoang) ("Weidner") and Hung Nguyen ("Nguyen") are the record owners of a certain mobile home described as a 1982 Windsor, 14' x 70', bearing serial No. CWT 7014 16023 (the "Mobile Home"), located at the North Avenue

Co-op, 21 Avenue C in Burlington, Vermont. See attached Vermont Mobile Home Uniform Bill of Sale.

3. Weidner leased the Lot in the Park for her mobile home pursuant to an written lease. No security deposit was paid. See attached Member Occupancy Agreement.

4. Weidner's last known mailing address is 3 Avenue E, Burlington, VT 05408.

5. Nguyen's last known mailing address was 21 Avenue C, Burlington, VT 05408. It is believed that Nguyen now resides with Weidner at 3 Avenue E, Burlington, VT 05408.

6. The mobile home has been abandoned and is empty. The last known authorized resident of the mobile home was Nguyen. Nguyen was evicted from the Park for material breach of lease on or about December 12, 2023. Judgment was entered against Weidner on October 20, 2023 in the amount of $2,451.93. See CDI Development Fund, Inc. v. Weidner, Vermont Superior Court, Chittenden Civil Unit, Case No. 23-CV-03572. See attached Judgment Order, Writ of Possession & Sheriff's Returns of Service.

7. Park's Counsel communicated in writing with Weidner on November 28, 2023 regarding her intentions with the Mobile Home. On April 2, 2024 Park's Counsel was contacted by Attorney Beth Demas on behalf of Weidner's son-in-law who wanted to purchase the Mobile Home. Park's Counsel informed Atty. Demas that Weidner's son-in-law would not be approved by the Co-op to buy the Mobile Home due to prior history. Park's Counsel advised Atty. Demas that Weidner must make an effort to sell the Mobile Home or the Park would be proceeding with the court abandonment process. There has been no further communication. The Park has not received any applications from prospective purchasers. See attached.

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

a. Property taxes to the City of Burlington are current and paid in full through June 30, 2024 according to the City Clerk. See attached Tax Bill.

9. Licensed auctioneer Uriah Wallace is a person disinterested in the mobile home and the mobile home park who is able to sell the Mobile Home at a public auction.

10. Mobile home storage fees continue to accrue at the rate of $426.00 per month. Rent due CDI as of May, 2024 totals $1,704.00, plus $1,500.00 for lot cleanup charges. See attached accounting. Court costs and attorney's fees incurred by CDI exceed $3,000.00.

11. CDI sent written notice by certified mail to the City of Burlington on February 23, 2024 of Plaintiff's intent to commence this action. See attached.

WHEREFORE, CDI respectfully requests that the Honorable Court enter an order as follows:

1. Declare that the Mobile Home has been abandoned;

2. Approve the sale of the Mobile Home at a public auction to be held within fifteen (15) days of the date of judgment, pursuant to 10 V.S.A. § 6249(h); and

3. Grant judgment in favor of CDI and against the Mobile Home for past due rent and mobile home storage charges through the date of judgment, together with the Park's court costs, attorney's fees, publication and mailing costs, auctioneer's costs, winterization costs, lot cleanup charges incurred in connection with this matter and any other costs incurred by Park herein.

DATED this 6th day of May, 2024.

CDI DEVELOPMENT FUND, INC.

BY: Nadine L. Scibek

Attorney for CDI

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 6, 2024 By: Silvia Iannetta, Duly Authorized Agent for CDI