VERIFIED COMPLAINT FOR ABANDONMENT

PURSUANT TO 10 V.S.A. 6249i (UNINHABITABLE)

NOW COMES Plaintiff North Avenue Cooperative, Inc. by and through counsel Steven J. Kantor, and hereby makes this complaint:

1. Plaintiff North Avenue Cooperative, Inc. is a Vermont Cooperative Housing Corporation which was formed by the owners of mobile homes to own and manage the North Avenue Mobile Home Park (the “Park”).

2. Defendant Linda Pidgeon (deceased) is the record owner of a certain mobile home in the Park, described as a 1969 Belveder, 10′ x 50′, located at 28 Avenue C in Burlington, Vermont.

3. Defendant’s last known mailing address is 28 Avenue C in Burlington, VT.

4. Defendant leased a lot in the Park under the terms of a written uniform Mobile Home Lot Lease. She passed away on May 5, 2025 and no one has resided in the mobile home since that time.

5. The last known resident at the mobile home was Defendant Linda Pidgeon.

6. Upon information and belief, surviving family members have abandoned any interest in the mobile home. No petition to open a probate estate has been filed for Pidgeon per the Chittenden Probate Division.

6. No liens or encumbrances appear of record with respect to the mobile home.

7. The mobile home is unsafe and unfit for habitation. The attached Affidavit of Timothy Seagroves serves as verification of the uninhabitable condition of the mobile home.

8. Mobile home storage fees have not been paid since April 24, 2025 and continue to accrue at the rate of $430.00 per month. Rent and storage fees owed to North Avenue Cooperative, Inc. as of July 18, 2025, total $1,315.00. A true and accurate statement of amounts owed is attached as Exhibit A. Court costs and attorneys’ fees incurred by North Avenue Cooperative, Inc. continue to accrue.

9. Plaintiff sent written notice by certified mail to the Burlington City Clerk on June 10, 2025 of Plaintiffs intent to commence this action, as required by statute.

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

1. declaring that the mobile home has been abandoned; and

2. declaring that the mobile home is unfit for human habitation pursuant to 10 V.S.A. §6249(i); and

3. approving transfer of the mobile home to the Plaintiff without a public sale in “as is” condition, free and clear of all liens, taxes and all other encumbrances of record pursuant to 10 V.S.A. 6249(j).

DATED AT Burlington, this 22nd day of July, 2025.

NORTH AVENUE COOPERATIVE, INC.

/s/ Steven J. Kantor

Steven J. Kantor, Esq. Doremus Kantor & Zullo
346 Shelburne Road, Suite 603
P.O. Box 445
Burlington, VT 05402-0445
(802) 863-9603

Attorney for NORTH AVENUE COOPERATIVE, INC.

I understand that the statements in the above Complaint are true and accurate to the best of my knowledge and belief.

DATED AT Burlington, Vermont this 22nd day of July, 2025

/s/ Timothy Seagroves

Timothy Seagroves, Duly Authorized Agent of NORTH AVENUE COOPERATIVE, INC
STATE OF VRMONT
CHITTENDEN COUNTY, SS.

At Burlington, in said County and State, this 22nd day of July, 2025, personally appeared Timothy Seagroves, Duly Authorized Agent of NORTH AVENUE COOPERATIVE, INC., and he swore to the truth of the foregoing.

Before me,

/s/ James Edward Kiley

James Edward Kiley
Notary Public State of Vermont
Commission Expires: 1/31/2027
Commission No.: 157.0015317