In Re: Abandoned Mobile Home

Of Jake Pyper & Liza Domingue

NOTICE OF HEARING

A hearing on The Housing Foundation, Inc.’s Verified Complaint to declare as abandoned the mobile home (Serial #260G2LA32193) of Jake Pyper & Liza Domingue located at the Mountain View Mobile Home Park, Lot #5, 158 Buck Hill Road East in Hinesburg, Vermont and to authorize the sale at public auction has been set for November 20, 2024 at 11:30 a.m. in person at the Vermont Superior Court, Chittenden Unit, Civil Division located at 175 Main Street in Burlington, Vermont.

Date: November 04, 2024 Nancy L. Bean, 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 Mountain View Mobile Home Park (the “Park”) located in the Town of Hinesburg, Vermont. The Park is managed by the Vermont State Housing Authority.

2. Jake Pyper (“Pyper”) and Liza Domingue (“Domingue) are the record owners of a certain mobile home described as a 1969 Richardson, bearing serial No. 260G2LA32193 (the “Mobile Home”), located on Lot #5, Mountain View Mobile Home Park, 158 Buck Hill Road East in Hinesburg, Vermont (the “Lot”). See attached Vermont Mobile Home Uniform Bill of Sale.

3. Pyper & Domingue leased Lot #5 in the Park from HFI pursuant to a written lease. Pyper & Dominque paid a security deposit in the amount of $411.00 to HFI. See attached Lease.

4. Pyper’s last known mailing address is 158 Buck Hill Road East, Hinesburg, VT 05461.

5. Domingue’s last known mailing address is 43 Avian Lane, Starksboro, VT 05482.

6. The mobile home has been abandoned and is empty/unoccupied. The last known resident of the mobile home was Pyper. Pyper is believed to have removed his personal belongings. Utility services have been terminated to the Mobile Home.

7. Pyper & Domingue were evicted from the Park for non-payment of lot rent on June 17, 2024. A Judgment Order for the outstanding lot rent and court costs was entered against Pyper & Domingue on April 18, 2024 in the amount of $4,071.54. See The Housing Foundation, Inc. v. Pyper, et. al., Vermont Superior Court, Chittenden Civil Unit, Case No. 24-CV-00935. See attached Judgment Order, Writ of Possession & Sheriff’s Returns of Service.

8. HFI’s Counsel has attempted to communicate with Pyper & Domingue with no response. See attached letter.

9. The following security interests, mortgages, liens and encumbrances appear of record with respect to the mobile home:

a. Pyper & Domingue are in arrears on obligations to pay property taxes to the Town of Hinesburg, Vermont in the aggregate amount of $351.58, plus interest and penalties. The delinquent property taxes are now a lien on the property. See attached Tax Bill & Delinquent Tax Report.

10. Uriah Wallace, a duly licensed 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.

11. Mobile home storage fees continue to accrue at the rate of $491.00 per month. Rent, storage fees and late charges due the Park as of October, 2024 total $5,866.25. Court costs and attorney’s fees incurred by the Park exceed $2,000.00.

12. The Park sent written notice by certified mail to the Town of Hinesburg on September 30, 2024 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 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 AT Burlington, Vermont this 30th day of October, 2024.

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 30, 2024 By: Thomas Young

Duly Authorized Agent for HFI