State of Vermont Superior Court Civil Division Chittenden Unit Case No. 22-Cv-03666 

In Re: Abandoned Mobile Home of Joshua Senna, Renata Prim & Bradley Senna
NOTICE OF HEARING
A hearing on The Housing Foundation, Inc.'s Verified Complaint to declare abandoned the mobile home of Joshua Senna, Renata Prim and Bradley Senna located at the Windemere Mobile Home Park, Lot #47, 54 Mount Sterling Avenue in Colchester, Vermont to authorize the transfer without a public auction, so it may be removed and disposed of has been set for November 16, 2022 at 1:45 PM. To participate in this hearing, the WEBEX Login Informationis as follows:

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If you do not have a computer or sufficient bandwidth, you may call (408) 418-9388 to appear by phone. (This is not a tollfree number). You will then enter the meeting number and password listed above. If you have technical difficulties, call the Court at (802) 863-3467.
Date: October 17, 2022
Nancy L. Bean, Judicial Assistant
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. Joshua Senna ("J. Senna"), Renata Prim ("Prim") and Bradley Senna ("B. Senna") are the record owners of a certain mobile home described as 1995 Oakland, 12' x 56', bearing Serial #PAFL522A67751-OLI (the "Mobile Home") located on Lot #47 at the Windemere Mobile Home Park, 54 Mount Sterling Avenue in Colchester, Vermont according to the Town of Colchester Land Records. See attached Bill of Sale.

3. J. Senna leased Lot #47 in the Park from HFI pursuant to a written lease. J. Senna paid a security deposit in the amount of $421.00 to HFI. Prim and B. Senna neither signed a lease with HFI nor resided in the Mobile Home. See attached Lease.

4. J. Senna's last known mailing address is 54 Mount Sterling Avenue, Colchester, VT 05446. Prim's last known mailing address is 3 Keel Road, Grand Isle, VT 05458. B. Senna's last known mailing address is 220 Main Street, Apt. C, Winooski, VT 05404.

5. J. Senna was evicted from the Park for non-payment of lot rent on June 23, 2022. A Judgment Order for the outstanding lot rent and court costs was entered against J. Senna on May 10, 2022 in the amount of $4,891.62. See The Housing Foundation, Inc. v. Senna, Vermont Superior Court, Chittenden Civil Unit, Docket No. 22-CV-01452. See attached Judgment Order, Writ of Possession & Sheriff's Return of Service.

6. The last known resident of the mobile home was J. Senna. J. Senna is believed to still be residing in the mobile home despite the execution of the Writ of Possession on June 23, 2022. He is trespassing. All utility services have been terminated to the Mobile Home.

7. HFI's counsel has attempted to communicate in writing with J. Senna by first class mail regarding his intentions with the mobile home. He has failed to respond. See attached.

8. The following security interests, mortgages, liens and encumbrances appear of record with respect to the mobile home:
a. J. Senna, Prim & B. Senna are in arrears on obligations to pay property taxes to the Town of Colchester, Vermont in the amount of $4,819.04, plus interest and penalties for delinquent taxes. See attached Tax Bill & Delinquent Tax Report.

9. Mobile home lot rent/storage fees continue to accrue at the rate of $476.00 per month. Monies due to HFI as of October, 2022 total $6,179.32. Attorney's fees and court costs incurred by HFI currently exceed $1,000.00. See attached Account History.

10. HFI sent written notice by certified mail to the Town of Colchester on September 8, 2022 of Plaintiff's intent to commence this action. See attached.

11. The mobile home is uninhabitable. Property Manager Thomas Young, duly authorized agent for HFI, 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 that is unfit for human habitation to Park owner HFI 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 this 14 th day of October, 2022.
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.
October 14, 2022
By: Thomas Young, Duly Authorized Agent for HFI