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VERMONT SUPERIOR COURT Bennington Unit 207 South St Bennington VT 05201 802-447-2700 www.vermontjudicary.org CIVIL DIVISON Case No. 20-CV-00956 Date: April 12, 2021 NOTICE OF HEARING Garden Homes Management Corporation d/ba Garden Homes Vermont Limited Partnership v. Cindy M. Shortt This is to notify you to appear at the Court named above in connection with the above-named case on: DATE: May 03, 2021 TIME: 10:00 AM DURATION: 30 Minutes HEARING RE: Bench Trial Civil Division Clerk If parties personally appear in court a mask will be required. Any individual with a disability requiring assistance accessing the services, programs, and/or activities at the Courthouse should contact the Clerk's office at the above address for further assistance. STATE OF VERMONT SUPERIOR COURT BENNINGTON COUNTY CIVIL DIVISION Case No. 20-CV-00956 In Re: Abandoned Mobile Home of Cindy M. Shortt (Estate of) VERIFIED COMPLAINT NOW COMES Garden Homes Management Corporation d/b/a. Garden Homes Vermont Limited Partnership, by and through their attorneys, Bennett & Zaikowski, P.C., and hereby makes this their complaint: 1. Garden Homes Vermont Limited Partnership is a Vermont limited partnership which is the record owners of a mobile home park known as Mountain View Mobile Home Park, located in the Town of Bennington, Vermont ("the Park"). 2. Garden Homes Management Corporation is a duly authorized Connecticut Corporation and General Partner of Garden Homes Vermont Limited Partnership. (collectively "Garden Homes") 3. Cindy M. Shortt ("Shortt") is the owner of a certain mobile home, described as a 2000 Titan 28' x 58' with a Serial Number of 54190061901927AB (the "Mobile Home"), located on a lot at the Park. Exhibit 1. 4. Upon information and belief, Shortt is deceased as of August 28, 2010. 5. The last known mailing address for "Shortt" is 61 Bell Street, Bennington, Vermont 05201. 6. "Shore leased a lot in the Park from Garden Homes under the terms of a Lease Agreement and occupied the mobile home lot known as 61 Bell Street, Lot #B-061, Bennington, Vermont. Exhibit 2. 7. The mobile home has been abandoned. The last known resident at the mobile home was Cindy M. Shortt. 8. The following security interests, mortgages, liens and encumbrances appear of record with respect to the mobile home: a. Upon information and belief, Cindy M. Shortt is in arrears on obligations to pay property taxes to the Town of Bennington, Vermont. b. Upon information and belief, Cindy M, Shortt is in arrears on obligations to Pay Garden Homes Management Corporation pursuant to a Manufactured Home Conditional Sales Contract. Exhibit 3. 9. Upon information and belief, the mobile home is fit for human habitation. 10. The last known employer of "Shortt" is unknown. 11. Robert Prozzo is a person disinterested in the mobile home or mobile home park who is able to sell the mobile home at a public auction. 12. Lot rent has not been paid since October 2019 and the outstanding amount owed is $6,258.00 through December 2020. 13. Garden Homes sent written notice to the Town Clerk of the Town of Bennington on December 1, 2020, of Plaintiffs' intent to commence this action. See copy of certified letter to Cassandra Barbeau dated November 30, 2020, attached as Exhibit 4. 14. Garden Homes sent written notice to the Delinquent Tax Collector of the Town of Bennington on December 1, 2020, of Plaintiffs' intent to commence this action. See copy of certified letter to Joan Pinsonneault dated November 30, 2020, attached as Exhibit 5. WHEREFORE, Plaintiff respectfully requests that the Honorable Court enter an order in Plaintiff's favor as follows: 1. Declaring that the mobile home has been abandoned; 2. Granting judgment in favor of Plaintiff and against the mobile home owner for past due and unpaid rent through the date of judgment, together with Plaintiffs court costs, publication and mailing costs, and Plaintiff's counsel fees incurred in connection with this matter. 3. 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). Dated at Shelburne, Vermont, this 23rd day of December, 2020 By: Angela N. Zaikowski, Esq. Attorney for Plaintiffs VERIFICATION I declare that the above statements are true and accurate to the best of my knowledge and belief, understand that if the above statement is false, I will be subject to the penalty of perjury. Dated at 5:36 pm, Vermont, this 22 day of December, 2020. Thomas O'Brien
Apr 22, 2021 (Expired).
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