In Re: Abandoned Mobile Home of Bill Rublee, Jr. Verified Complaint
Now comes Sunset Lake Cooperative (hereafter "Plaintiff") by and through counsel Steven J. Kantor, and hereby makes this complaint:

1. Plaintiff is a Vermont Cooperative Housing Corporation which was formed by the owners of mobile homes to purchase Sunset Lake Villa Mobile Home Park (the "Park").

2. Plaintiff is the record owner of the Park located in town of Hinesburg, Vermont.

3. Defendant Bill Rublee, Jr. is the record owner of a certain mobile home in the Park, described as a 1983 Commodore, 14x56, Serial Number 81573 and located in Sunset Lake Villa Mobile Home Park at 38 Wile Street in Hinesburg, Vermont.

4. Defendant Rublee's last known mailing address is 38 Wile Street, Hinesburg, Vermont.

5. Defendant leased a lot in Sunset Lake Villa Mobile Home Park under the terms of a written Member Occupancy Agreement.

6. On June 29, 2023 this Court evicted Bill Rublee, Jr. and Danielle Rublee from the Park, in the case Sunset Lake Cooperative vs. Bill Rublee and Danielle Rublee, Docket No. 23-CV-01286. The Judgment of Eviction ordered that the Defendants sell or remove the mobile home from the Park within three (3) months pursuant to 10 V.S.A. Section 6237(e).

7. The Rublees failed to remove or sell the mobile home and have instead abandoned the mobile home in the Park.

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

a. Delinquent property taxes to the Town of Hinesburg in the amount of $460.69.

9. Mobile home lot rent has not been paid since October 2022 and continues to accrue at the rate of $480.00 per month. Late fee charges are $25/month. Rent and other charges due to Sunset Lake Cooperative as of October 31, 2023 are $13,562.02. Court costs and attorney's fees incurred by Sunset Lake Cooperative continue to accrue.

10. Plaintiff sent written notice on September 26, 2003 to the Town Clerk of the Town of Hinesburg of Plaintiff's intent to commence this action.

11. Charles Bolton is a person disinterested in the mobile home or mobile home park who is able to sell the mobile home at a public auction.

WHEREFORE, Plaintiff respectfully requests that the Honorable Court enter an order as follows:

1. declaring that the mobile home has been abandoned; and

2. approving 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. granting judgment in favor of Plaintiff and against the mobile home for past due and unpaid rent and other charges through the date of judgment, together with Plaintiff's court costs, publication and mailing costs, and Plaintiff's counsel fees incurred in connection with this matter, pursuant to 10 V.S.A. 6249(h)(7)(B).

DATED AT Burlington, Vermont this 14th day of November, 2023.
Sunset Lake Coopertive
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 Sunset Lake Cooperative

DATED AT Chittenden, Vermont this 14th day of November, 2023. STATE OF VERMONT, CHITTENDEN COUNTY, SS. At South Burlington, in said County and State, this 14th day of November, 2023, personally appeared Maura Fitzgerald, Duly Authorized Agent of Sunset Lake Cooperative and he/she/they swore to the truth of the foregoing.

Before me, Ashley Heather Cousino Notary Public
Print Name: Ashley Cousino
Commission Expires 1/31/2025
Commission No. 157.0013843