State of Vermont Superior Court Civil Division Orleans Unit Case No. 25-CV-03224

IN RE: ABANDONED MOBILE HOME

OF TAMMY COREY

NOTICE OF HEARING

A hearing on The Housing Foundation, Inc.’s Verified Complaint to declare as abandoned the mobile home of Tammy Corey located at the Derby Mobile Home Park, Lot #D-15, 2477 US Route 5 in Derby, Vermont and to authorize the sale by auction has been scheduled on September 4, 2025 at 11:00 a.m. You may participate in the hearing either in person at the Vermont Superior Court, Orleans Unit, Civil Division located at 247 Main Street in Newport, Vermont or remotely via WEBEX video. The WEBEX Login Information is as follows:

App: Cisco Webex Meetings

Website: https://vtcourts.webex.com

Meeting Number: 2338 917 6288

Password: OrleansCivil

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) 334-3305.

Date: August 5, 2025 Judicial Assistant

VERIFIED COMPLAINT FOR ABANDONMENT

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

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 Derby Mobile Home Park (the “Park”) located in the Town of Derby, Vermont. HFI purchased the Park from the Vermont State Housing Authority (“VSHA”) on December 31, 2023. The Park is managed by VSHA.

2. Tammy Corey (“Corey”) is the record owner of a certain mobile home described as a 1983 Skyline, JAY7302F, 14′ x 56′, bearing serial number 1816-0302T (the “Mobile Home”), located on Lot #D-15, Derby Mobile Home Park, 2477 US Route 5, Lot D-15 in Derby, Vermont (the “Lot”). See attached Vermont Mobile Home Uniform Bill of Sale.

3. Corey leased Lot #D-15 in the Park from VSHA pursuant to a written lease. Corey paid a security deposit in the amount of $332.00 to VSHA. See attached Lease.

4. Corey’s last known mailing address is 19 Upper Welden Street, Unit #2, St. Albans, VT 05478 per USPS. However, HFI was been notified that Corey has moved and left no forwarding address when HFI’s Counsel’s letter to Corey dated March 28, 2025 was returned by USPS. See attached.

5. The mobile home has been abandoned and is empty/unoccupied. The last known resident of the mobile home was Corey. Corey vacated the Mobile Home sometime in 2024. The mobile home has been unoccupied since that time.

6. HFI and HFI”s Counsel have attempted to contact Corey via first class mail, email and telephone with respect to her intentions regarding her mobile home. HFI has received no response from Corey. Corey has stopped communicating with HFI. See attached correspondence.

7. HFI’s Counsel has communicated with Corey with respect to her intentions with her mobile home via first class mail and email on March 28, 2025. Corey’s email address was valid as Corey had previously emailed HFI’s Counsel. HFI has received no response from Corey. 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 Town of Derby were abated according to the Town Clerk. See attached Tax Bill.

9. Uriah Wallace, a duly licensed Vermont auctioneer, 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 $455.00 per month. Rent, storage fees and late charges due the Park as of July, 2025 total $4,380.63. Court costs and attorney’s fees incurred by the Park in this action currently exceed $800.00.

11. The Park sent written notice by certified mail to the Town of Derby on March 25, 2025 of its intent to commence this abandonment action. See attached.

WHEREFORE, the Park Owner 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 15 days of the date of judgment, pursuant to 10 V.S.A. § 6249(h); and

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

DATED this 31st day of July, 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.

July 31, 2025 By: Susan M. Kuegel, Duly Authorized Agent for HFI