IN RE: ABANDONED MOBILE HOME

OF RANDY LAVALETTE

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, Esq., of Doremus Kantor & Zullo, 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”) located in the City of Burlington.

2. Randy Lavalette (“Randy”) is the record owner of a certain mobile home in the Park, described as a 1963 Princess Homes Model No. 1513, 10’ x 60’, Serial No. 029-2-052-042 (the “Mobile Home”) located at 47 Avenue B in Burlington, Vermont (the “Lot”). A true and accurate copy of the Bill of Sale from Theresa Lavalette conveying the Mobile Home to Randy is attached hereto as Exhibit 1 and made a part of the Complaint.

3. Randy’s last known mailing address is 47 Avenue B in Burlington, VT.

4. Unauthorized occupant Sonya Hamner (“Sonya”) also resided in the Mobile Home, without prior approval or notice of Plaintiff.

5. On October 2, 2025 Randy verbally informed the Park that he and occupant Sonya Hamner had vacated the Mobile Home and would be taking down a shed on the property. He authorized the Park to shut off water and power to the home, indicating they did not intend to return nor to remove the Mobile Home from the lot.

6. On or about October 10, 2025, the Park inspected the Mobile Home and Lot and, upon information and belief, confirmed that Randy, Sonya, and all other occupants had vacated the Mobile Home and Lot. Furthermore, the Park discovered that the heating system had been removed from the Mobile Home, the windows were broken, and large holes had been made in the floors and walls, rendering the Mobile Home uninhabitable.

7. Upon information and belief, the Mobile Home has been abandoned.

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

9. The Mobile Home is unsafe and unfit for habitation. The Affidavit of Timothy Seagroves verifying the uninhabitable condition of the Mobile Home is attached hereto as Exhibit 2 and made a part of the Complaint.

10. Lot Rent was last current on July 15, 2025, with a past due balance of $861.00. Rent is delinquent by two months and continues to accrue at the rate of $435.00 per month. A true and accurate statement of amounts owed is attached as Exhibit 3 and made a part of the Complaint.

10. Plaintiff sent written notice by certified mail to the Burlington City Clerk on October 21, 2025 of Plaintiff’s intent to commence this action, more than 20 days prior the filing of this Complaint.

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 11 day of November, 2025.

NORTH AVENUE COOPERATIVE, INC.

/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 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 11 day of November, 2025.

/s/ Timothy Seagroves

Timothy Seagroves, Duly Authorized Agent of NORTH AVENUE COOPERATIVE

STATE OF VERMONT

CHITTENDEN COUNTY, SS.

At Burlington, in said County and State, this 11th day of November, 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/ Erin L. Anderson

Notary Public
Print Name: Erin L. Anderson
Commission Expires: 1/31/2027
Commission No.: 157-0015691