IN RE: ABANDONED MOBILE HOME
OF GARY J. RAVLIN
NOTICE OF HEARING
A hearing on The Housing Foundation, Inc.'s Verified Complaint to declare as abandoned and uninhabitable the mobile home of Gary J. Ravlin, located at the Birchwood Manor Mobile Home Park, Lot #48, 28 Owen Court in Milton, Vermont has been set for March 24, 2022 at 1:00 p.m. To participate in this hearing, the WEBEX Login Information is as follows:
App: Cisco Webex Meeting
Meeting Number: 129 647 6521
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: March 7, 2022 Nancy Bean, Docket Clerk
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 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 Birchwood Manor Mobile Home Park located in the Town of Milton, Vermont (the "Park"). The Park is managed by the Vermont State Housing Authority.
2. Gary J. Ravlin ("Ravlin") is the record owner of a certain mobile home, described as a 1974 Champion, 14' x 65', bearing serial number 58-5-995-0448 (the "Mobile Home"), located on Lot #48, Birchwood Manor Mobile Home Park, 28 Owen Court in Milton, Vermont. See attached Bill of Sale.
3. Ravlin leased a lot in the Park for his mobile home from HFI pursuant to a written lease. Ravlin paid a security deposit in the amount of $250.00 to HFI. See attached Lease.
4. Ravlin is deceased. His date of death is April 2, 2020. See attached Death Certificate.
5. No petition to open a probate estate has been filed for Ravlin per the Chittenden County Probate Court.
6. The last known resident of the mobile home was Ravlin. The mobile home has been abandoned and is unoccupied. After Ravlin's death, his sister Cheryl Belval contacted the Park Owner and indicated that she had cleaned out the mobile home, advised the family has no interest in the mobile home and she considered it abandoned.
7. The following security interests, mortgages, liens and encumbrances appear of record with respect to the mobile home:
a. Ravlin is in arrears on obligations to pay property taxes to the Town of Milton, Vermont in the aggregate amount of $873.48, plus any additional interest and penalties. The delinquent property taxes are now a lien on the property. See attached Tax Bill & Letter from Town.
b. Ravlin is in arrears on obligations to pay water bills to the Town of Milton, Vermont in the aggregate amount of $657.30, plus any additional interest and penalties. The delinquent water bills are now a lien on the property. See attached Notice from Town of Milton.
c. Mortgage Deed given by Ravlin to Champlain Housing Trust, Inc. dated August 6, 2013 and recorded in the Milton Land Records on September 16, 2013 in Volume 440 at Pages 382-383.
8. Mobile home storage fees continue to accrue at the rate of $343.00 per month. Rent, storage fees and late charges due HFI as of March, 2022 total $7,575.83. Court costs and attorney's fees from this action to date exceed $750.00. See attached Account History.
9. HFI sent written notice by certified mail to the Town of Milton on December 23, 2021 of HFI's intent to commence this abandonment action as required by statute. See attached.
10. The mobile home is uninhabitable. Thomas Young, Property Manager and duly authorized agent for the Park owner, 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 4th day of March, 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.
March 4, 2022 By: Thomas Young, Duly Authorized Agent for HFI