IN RE: ABANDONED MOBILE HOME OF TINA M. ROMPREY

NOTICE OF HEARING

A hearing on The Housing Foundation, Inc.’s Verified Complaint to declare as abandoned and uninhabitable the mobile home of Tina Romprey located at the Windemere Mobile Home Park, Lot #62, 16 Camels Hump Road in Colchester, Vermont has been set for Thursday April 24, 2025 at 2:00 p.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 Meeting

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: April 1, 2025

Nancy L. Bean, Judicial Assistant

Chittenden Civil Division

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 Windemere Mobile Home Park (the “Park”), located in the Town of Colchester, Vermont. The Park is managed by the Vermont State Housing Authority.

2. Tina M. Romprey (“Romprey”) is the record owner of a certain mobile home described as a 1964 Fleetwood, FB3, 10′ x 56′, bearing Serial #50615, (the “Mobile Home”) located at the Windemere Mobile Home Park, Lot #62, 16 Camels Hump Road in Colchester, Vermont according to the Town of Colchester Land Records. See attached Vermont Mobile Home Bill of Sale.

3. Romprey leased a lot in the Park from HFI pursuant to a written lease. Romprey paid a security deposit in the amount of $407.00 to HFI. See attached Lease.

4. Romprey’s last known mailing address is 16 Camels Hump Road in Colchester, VT

05446.

5. The mobile home has been abandoned and is empty/unoccupied. The last known resident of the mobile home was Romprey. All of Romprey’s personal property is believed to have been removed from the mobile home and utility services have been terminated. The Park’s Counsel has communicated with Romprey with respect to her intentions with her mobile home. HFI has received no response from Romprey. See attached.

6. Romprey was evicted from the Park for nonpayment of rent on or about October 22, 2024 by the Chittenden County Sheriff’s Department. The mobile home has been vacant since that time. The Court issued a Partial Judgment for Possession and Writ of Possession to HFI on August 23, 2024 and a Judgment Order on November 20, 2024. See The Housing Foundation, Inc. v. Romprey, Vermont Superior Court, Chittenden Civil Unit, Case No. 24-CV-01268. See attached.

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

a. Romprey is in arrears on obligations to pay property taxes to the Town of Colchester, Vermont in the aggregate amount of $1,526.05, plus interest and penalties. See attached copy of Tax Bill and Delinquent Tax Report.

8. Mobile home storage fees continue to accrue at the rate of $505.00 per month. Rent/ storage fees due HFI through March, 2025 total $10,676.25. Attorney’s fees and court costs incurred by HFI currently exceed $2,000.00.

9. HFI sent written notice by certified mail to the Town of Colchester on January 28, 2025 of its intent to commence this action. See attached.

10. The mobile home is uninhabitable. Susan Batchelder, 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 March 28, 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.

March 28, 2025 BY: Susan Batchelder

Duly Authorized Agent for HFI