IN RE: ABANDONED MOBILE HOME OF MARGARET CASTLE

VERIFIED COMPLAINT FOR ABANDONMENT

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

NOW COMES Plaintiff SMHP, LLC by and through counsel Steven J. Kantor, and hereby makes this complaint:

1. Plaintiff, with a principal business located in Sheldon, County of Franklin, State of Vermont, is the record owner of a mobile home park known as Simonds Mobile Home Park (the “Park”), located in the Town of St. Albans, Vermont.

2. Defendant Margaret Castle is the record owner of a certain mobile home in the Park, described as a 1981 Skyline, Serial Number 0316-013412 and located at 151 Crosby Drive Lot #32 in St. Albans, Ve1mont.

3. Defendant’s last known mailing address is 151 Crosby Drive Lot #32 in St. Albans, VT.

4. Defendant leased a lot in the Park under the tetms of a written uniform Mobile Home Lot Lease. Defendant paid a security deposit in the amount of $ (N/A). She last occupied the home on May 15, 2024 when she was evicted by Order of Superior Court, Franklin Unit, in Docket No. 23-CV-05127.

5. The last known resident at the mobile home was Defendant Margaret Castle. The Defendant failed to sell or remove the mobile home and instead abandoned it in the Park.

6. The following liens and encumbrances appear of record with respect to the mobile home:

a. Delinquent Property taxes to the Town of St. Albans in the amount of $708.95 through May 15, 2025.

7. The mobile home is unsafe and unfit for habitation. The Affidavit of Brandon Chadwick is attached as Exhibit A as verification of the uninhabitable condition of the mobile home.

8. Mobile home storage fees have not been paid since October, 2024 and continue to accrue at the rate of $430 per month. Rent and storage fees owed to SMHP, LLC as of June 10, 2025, total $4,005.00. Court costs and attorneys’ fees incurred by SMHP, LLC continue to accrue.

9. Plaintiff sent written notice by certified mail to the Town Clerk of St. Albans on May 8, 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 12th day of June, 2025.

SMHP,LLC

/s/ Steven J. Kantor, Esq.

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 SMHP, LLC

I understand that the statements in the above Complaint are true and accurate to the best of my knowledge and belief.Dated at Highgate, Vermont this 11 day of June, 2025.

/s/ Brandon Chadwick
Brandon Chadwick, Duly Authorized Agent of SMHP, LLP

STATE OF VERMONT
FRANKLIN COUNTY, SS.

At Highgate, in said County and State, this 11 day of June, 2025, personally appeared Brandon Chadwick, Duly Authorized Agent of SMHP, LLC, and he swore to the truth of the foregoing.

Before me,

/s/ Wendi S. Dusablon
Notary Public
Wendi S. Dusablon
Commission Expired: 1/31/2027Commission No.” 1570001116