IN RE: ABANDONED MOBILE HOME OF BRIANNA KENNETT & PAUL TURCOTTE

NOTICE OF HEARING

A hearing on Ship Sevin II, LLC’s Verified Complaint to declare abandoned and uninhabitable the mobile home of Brianna Kennett & Paul Turcotte located at the Pinecrest Mobile Home Park, Lot #19, 8 Third Street in Morrisville, Vermont has been set for March 11, 2025 at 1:00 p.m. You may participate in the hearing either in person at the Vermont Superior Court, Lamoille Unit, Civil Division located at 154 Main Street in Hyde Park, Vermont or remotely via WEBEX video. The WEBEX Login Information is as follows:

App: Cisco Webex Meeting
Website: https://vtcourts.webex.com
Meeting Number: 2335 590 2963
Password: LamoilleCR1

If you do not have a computer or sufficient bandwidth, you may call (802) 636-1108 to appear by phone. (This is not a tollfree number). When prompted enter the meeting ID number listed above, followed by the pound symbol (#). You will be prompted to enter your attendee number (which you do not have). Instead, press pound (#). If you have technical difficulties, call the Court at (802) 888-3887.

Date: February 14, 2025
Ashley Harvey, Judicial Assistant
Lamoille Unit

VERIFIED COMPLAINT FOR ABANDONMENT
PURSUANT TO 10 V.S.A. § 6249(i) (Uninhabitable)

NOW COMES Ship Sevin II, LLC (“Ship Sevin”), by and through its Counsel Nadine L. Scibek, and hereby complains pursuant to 10 V.S.A. § 6249(i) as follows:

1. Ship Sevin, a Vermont limited liability company with a principal place of business in South Burlington, County of Chittenden, State of Vermont, is the record owner of a mobile home park known as the Pinecrest Mobile Home Park (the “Park”), located in Morrisville, Vermont.

2. Brianna Kennett (“Kennett”) and Paul Turcotte (“Turcotte”) are the record owners of a certain mobile home described as a 1988 Champion, Titan, 14′ x 70′, bearing serial number 9065 (the “Mobile Home”) located at the Pinecrest Mobile Home Park, Lot #19, 8 Third Street in Morrisville, Vermont according to the Town of Morristown Land Records. See attached Bill of Sale.

3. Kennett & Turcotte leased a lot in the Park from Ship Sevin pursuant to a written lease. Kennett & Turcotte paid Ship Sevin a security deposit of $268.00. See attached Lease.

4. Kennett & Turcotte’s last known mailing address is 8 Third Street, Morrisville, VT 05661.

5. Kennett & Turcotte were evicted from the Park for nonpayment of rent on or about July 25, 2024 by the Lamoille County Sheriff’s Department. The mobile home has been vacant since that time. The Court issued a Judgment and Writ of Possession to Ship Sevin on July 1, 2024. See Ship Sevin II, LLC v. Kennett, et. al., Vermont Superior Court, Lamoille Civil Unit, Case No. 24-CV-02301. See attached.

6. The mobile home has been abandoned and is empty. The last known residents of the mobile home were Kennett and Turcotte. All of Kennett & Turcotte’s personal property is believed to have been removed from the mobile home and utility services have been terminated. On August 7, 2024, the Park’s Counsel communicated with Kennett & Turcotte with respect to their intentions with their mobile home. See attached.

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

a. Kennett & Turcotte are in arrears on obligations to pay property taxes to the Town of Morristown, Vermont in the aggregate amount of $89.56, plus interest and penalties. See attached copy of Tax Bill and Delinquent Tax Report.

8. Mobile home storage fees continue to accrue at the rate of $415.00 per month. Rent/ storage fees due Ship Sevin through February, 2025 total $6,578.35. Lot rent increases to $435.00 as of March 1, 2025. Attorney’s fees and court costs incurred by Ship Sevin currently exceed $3,000.00.

9. Ship Sevin sent written notice by certified mail to the Town of Morristown on October 31, 2024 of its intent to commence this action. See attached.

10. The mobile home is uninhabitable. Cindy Whitham, Property Manager, will testify under oath as to the poor and unlivable condition of this mobile home at the abandonment hearing.

WHEREFORE, Ship Sevin 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 which is unfit for human habitation to the Park owner

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 February 14, 2025

SHIP SEVIN II, LLC
BY: Nadine L. Scibek
Attorney for Ship Sevin II, LLC

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.

February 14, 2025 BY: Cindy Whitham
Duly Authorized Agent for Ship Sevin II, LLC