Loading...
HomeMy WebLinkAboutMS-11-0000 - Supplemental - 0131 Patchen RoadLAW OFFICES OF FRED V. PEET, P.C. Fred V. Peet Richard C. Maxson Christopher M. Perra Kevin J. Shortell Paula J. LeBlanc, Registered Law Clerk Doreen T. Guthrie, Paralegal Sherry Morin Barton, Paralegal Karen Eddy, Paralegal Amy S. Benway, Real Estate Closing Coordinator February 25, 2011 Raymond Belair City of South Burlington 575 Dorset Street South Burlington, VT 05403 Re: 131 Patchen Road, South Burlington Dear Ray, 55 Patchen Road South Burlington, VT 05403 Telephone: (802)-860-4767 Facsimile: (802)-860-2822 Toll Free: (800)-683-3903 Email:officeCtDpeetlaw.com Please find enclosed a Lien Release and associated documents showing proof of payment in regards to the above -referenced property. The City was required to release the lien from June 2010 within 30 days of receipt of payment, but to date that has not happened. The property has since changed ownership and the title remains clouded with this lien. Upon execution of the release, please have it recorded in the Land Records of South Burlington to clear title and forward a copy of the document to me for my records. I would appreciate your prompt attention to this matter. Let me know if you have any questions or if you need anything else to take care of this. Kindest egards, Paula LeBlanc RELEASE OF LIEN I, , a duly authorized agent of the CITY OF SOUTH BURLINGTON, hereby certify that the following lien is paid in full and satisfied, viz: Lien against Benjamin Lee and Cortlandt Sener by the City of South Burlington dated June 23, 2010 and recorded in Book 940, Page 338 of the City of South Burlington Land Records. Dated this day of , 2011. Witness State of Vermont County of: Chittenden, ss A duly authorized agent of the City of South Burlington On this day of , 2011, personally appeared , a duly authorized agent of the City of South Burlington, signer and sealer of the foregoing written instrument, and he/she acknowledged the same to be his/her free act and deed and the free act and deed of the City of South Burlington. Before me: Notary Public Commission Expires: 2/10/15 /,2/92ff DEC -14 _2010 10_58A FROM _CITY OF SOUTH BURL I N 8028464101 TO : 98634587 P.1 Aw southburlington PLANNING 8 ZONING July 6, 2010 Re: Docket No. 77-5-10 Vtec The City of South Burlington received check no. 1583 in the amount of $900.00. Ray o J. elair 7 Administrative Officer City of South Burlington Post -IN Fax Note 7671 °a`B� ! pages► To /V1( //G� �, From Go./Dept. GO Phone N Phone w Fax w [ Fax N 515 Dorset Strout South Burlington, VT 06403 tel 802A46.4106 lax 802.846.4101 www.sburt.com i City of SoL,h Burlington, Plaintiff V 4.1 IMWI Y 1 NVIRONIVIENTAL COURT V. Benjamin Lee and Cortlandt Sener, Defendants Environmental Court Docket No. 77-5-10 Vtec STIPULATION AND V.R.C.-P. 58 JUDGMENT ORDER 'NOW COME the City of South Burlington, by and through its attorneys, Stitzel, Page & Fletcher, P.C., and Benjamin Lee and Cortlandt Sener by and through their attorneys Ward & Babb, and hereby stipulate and agree that the Environmental Court may issue the following Judgment Order: 1. Defendants shall pay a penalty totaling__ 900.007to the City on or before July 31, 2010. Upon receipt of payment in full, the City shall execute, in a form that is mutually agreeable to the parties, a release evidencing satisfaction of this component of the stipulation; such release shall be in a form customarily employed to discharge real property from the effect of a judgment lien. 2. The building located on Defendants' property at 131 Patchen Road, South Burlington shall not be occupied by more than four (4) unrelated individuals. DATED at Burlington, Vermont, this Z3tJ day of June, 2010. STITZEL, PAGE & FLETCHER, P.C. j Attorneys for the City of South Burlington B�"/� Y• William E, Flender n �]08E:AT�S 1 0 1'-) 1223 2 0 " ;-j 7�' V z 9 8 P Gi - ST1rFZEL, PAGE & FLETCHER, P.C. ATTOPMYS AT LAW 171 BArl't,RY STREMT Y.O. BOX 1507 BURLINGTON, VFRMONT 06402-1607 STATE OF VERMONT SUPERIOR COURT City of South Burlington, Plaintiff V. Benjamin Lee and Cortlandt Sener, Defendants. ENVIRONMEb U-%bN-PIVISION SUPERIOR GoUfTr ENVIR0MIENTA1. DIW0,10N Docket No. 77-5-10 Vtec PARTIAL SATISFACTION OF JUDGMENT The City of South Burlington hereby acknowledges satisfaction in full by Defendants of the penalty payment requirements of paragraph (1) of the Court's June 24, 2010 Judgment. DATED at Burlington, Vermont, December 20, 2010. STITZEL, PAGE & FLETCHER, P.C. t rneys for the City of South Burlington By: J K.\WPD0C\L1T\S0N 10 087 Sener C. Lee Soj.dac.docx . Klesch 111� 11 7111111 ip� 11 111, pil 49?ko qT,1qF0T0RAW0C0 OF -n� OPIG4X AlqTiA &W Pf,, rtll faOWE X" STEVEN F. STITZEL PATTI R. PAGE ROBERT E.FLETCHER JOSEPH S. McLEAN AMANDA S. E. LAFFERTY JOHN H. KLESCH DAVID W.RUGH• '(ALSO ADMITTED IN MD) STITZEL, PAGE & FLEMIER, P.C. ATTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 BURUNGTON, VERMONT 05402-1507 (802) 660-2555 (VOICEITDD) FAX (802) 660-2552 or 660-9119 W W W.FIRMSPF.COM E-MAIL(FIRM25 55 @FIRMSPF. COM) WRITER'S E-MAIL (JKLESCH@FIRMSPF.COM) WRITER'S FAX (802) 660-9119 December 28, 2010 Raymond Belair, Planning & Zoning City of South Burlington 575 Dorset Street South Burlington, VT 05403 Re: City of South Burlington v. Lee & Sener Docket No. 77-5-10 Vtec Dear Ray: OF COUNSEL DINA L. ATWOOD Please find enclosed for recording in the land records, a certified copy of the Partial Satisfaction of Judgment in connection with the above -captioned matter. Once the judgment. has been recorded, please send me a copy for our records. Thank you. Enclosure cc: William Towle, Esq. son10-095 JHK to City - Lee&Sener.cor STITZEL, PAGE & FLETCHER, P.C. ATTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 BURLINGTON, VERMONT 05402-1507 (802) 660-2555 (VOICEITDD) STEVEN F. STITZEL FAX (802) 660-2552 or 660-9119 PATTI R. PAGE W W W.FIRMSPF.COM ROBERT E. FLETCHER E-MAEL(FHMU555@FIRMSPF.COM) JOSEPH S. McLEAN WRITER'S E-MAIL (JKLESCH@FIRMSPF.COM) AMANDA S. E. LAFFERTY WRITER'S FAX (802) 660-9119 JOHN H. KLESCH DAVID W.RUGH• *(ALSO ADMITTED IN MD) December 23, 2010 Jacalyn M. Fletcher, Court Manager Vermont Superior Court Environmental Division 2418 Airport Road, Ste. 1 Barre, VT 05641-8701 Re: City of South Burlington v. Lee & Sener Docket No. 77-5-10 Vtec Dear Jacalyn: I am writing to request a certified copy of the City's Partial Satisfaction of Judgment dated December 20, 2010. Enclosed please find a check in the amount of $5.25. in6prely, H. Klesch Enclosure Cc: William Towle, Esq. (w/o encl.) Raymond Belair, Planning & Zoning (w/o encl.) son10-094 JHK to Court - Lee & Sener.cor OF COUNSEL DINA L. ATWOOD STITZEL, PAGE & FLETCHER, P.C. ATTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 BURLINGTON, VERMONT 05402-1507 (802) 660-2555 (VOICE/TDD) STEVEN F. STITZEL FAX (802) 660-2552 or 660-9119 PATTI R. PAGE W W W.FIRMSPF.COM ROBERT E. FLETCHER E-MAHXFH M2555@FERMSPF.COM) JOSEPH S. McLEAN WRITER'S E-MAIL (JKLESCH@FIRMSPF.COM) AMANDA S. E. LAFFERTY WRITER'S FAX (802) 660-9119 JOHN H. KLESCH DAVID W. RUGH• -(ALSO ADMITTED IN MD) December 20, 2010 Jacalyn M. Fletcher, Court Manager Vermont Environmental Court 2418 Airport Road, Ste. 1 Barre, VT 05641-8701 Re: City of South Burlington v. Lee & Sener Docket No. 77-5-10 Vtec Dear Jacalyn: OF COUNSEL DINA L. ATWOOD Enclosed please find a Partial Satisfaction of Judgment for filing in the above -referenced matter. S n erel , Jo n H. Klesch Enclosure cc: William B. Towle, Esq. Raymond Belair, Planning & Zoning son10-092 JHK to Court - Lee&Sener.cor MTZEL, PAGE & FLETCHER, P.C. 1TTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 :URLINGTON, VERMONT 05402-1507 STATE OF VERMONT SUPERIOR COURT ENVIRONMENTAL DIVISION City of South Burlington, Plaintiff V. Docket No. 77-5-10 Vtec Benjamin Lee and Cortlandt Sener, Defendants. PARTIAL SATISFACTION OF JUDGMENT The City of South Burlington hereby acknowledges satisfaction in full by Defendants of the penalty payment requirements of paragraph (1) of the Court's June 24, 2010 Judgment. DATED at Burlington, Vermont, December 20, 2010. STITZEL, PAGE & FLETCHER, P.C. t rneys for the City of South Burlington By: J n H. Klesch K:\WPDOC\LIT\SON 10-087 Sener & Lee SOJ.doc.docx 1 r southburlington PLANNING & ZONING July 6, 2010 Re: Docket No. 77-5-10 Vtec The City of South Burlington received check no. 1583 in the amount of $900.00. Ray o J. elair Administrative Officer City of South Burlington 575 Dorset Street South Burlington, VT 05403 tel 802.846.4106 fax 802.846.4101 www.sburi.com STITZEL, PAGE & FLETCHER, P.C. ATTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 BURLINGTON, VERMONT 05402-1507 (802) 660-2555 (VOICE/TDD) STEVEN F. STITZEL FAX (802) 660-2552 or 660-9119 PATTI R. PAGE WWW.FlPMSPF.COM ROBERT E. FLETCHER E-MAIL(FIRM2555@FIRMSPF.COM) JOSEPH S. McLEAN WRITER'S E-MAIL (WFLENDER@FIRMSPF.COM) AMANDA S. E. LAFFERTY WRITER'S FAX (802) 660-2552 JOHN H.KLESCH WILLIAM E. FLENDER June 23, 2010 Jacalyn i Fletcher, Court Manager Vermont Environmental Court 2418 Airport Road, Ste. 1 Barre, VT 05641-8701 Re: City of South Burlington v. Lee & Sener Docket No. 77-5-10 Vtec Dear Jacalyn: OF COUNSEL DINA L. ATWOOD Enclosed for filing in the above -captioned matter is Stipulation and V.R.C.P. 58 Judgment Order for signing by the Court. Once the Court has signed the Order, please return a certified copy to me for filing in the City of South Burlington Land Records. Thank you. Sincerely, j � // William E. Flender WEF/gmt Enclosure CC: Raymond Belair, Planning & Zoning William B. Towle, Esq. SON10-044.COR STATE OF VE RMONT ENVIRONMENTAL COURT City of South Burlington, ) Plaintiff ) V. ) Benjamin Lee and Cortlandt ) Sener, ) Defendants ) Environmental Court Docket No. 77-5-10 Vtec STIPULATION AND V.R.C.P. 58 JUDGMENT ORDER NOW COME the City of South Burlington, by and through its attorneys, Stitzel, Page & Fletcher, P.C., and Benjamin Lee and Cortlandt Sener by and through their attorneys Ward & Babb, and hereby stipulate and agree that the Environmental Court may issue the following Judgment Order: 1. Defendants shall pay a penalty totaling $900.00 to the City on or before July 31, 2010. Upon receipt of payment in full, the City shall execute, in a form that is mutually agreeable to the parties, a release evidencing satisfaction of this component of the stipulation; such release shall be in a form customarily employed to discharge real property from the effect of a judgment lien. 2. The building located on Defendants' property at 131 Patchen Road, South Burlington shall not be occupied by more than four (4) unrelated individuals. DATED at Burlington, Vermont, this2 3rj day of June, 2010. STITZEL, PAGE & FLETCHER, P.C. Attorneys for the City of South Burlington 1 By: ��' -� William E. Flender 1 DATED at South Burlington, Vermont, this 21" day of June, 2010. WARD & BABB Attorneys for Benjamin Lee and Cortlandt Sener B y : (-,- ( illiam B. Towle SO ORDERED: Environmental Judge Date: son10-038 Sener & Lee stip.lit: 2 STITZEL, PAGE & FLETCHER, P.C. ATTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 BURLINGTON, VERMONT 05402-1507 (802) 660-2555 (VOICE/TDD) STEVEN F. STITZEL FAX (802) 660-2552 or 660-9119 PATTI R. PAGE WWW.FIRMSPF.COM ROBERT E. FLETCHER E-MAIL(FIRM2555@FIRMSPF.COM) JOSEPH S. McLEAN WRITER'S E-MAIL (WFLENDER@FIRMSPF.COM) AMANDA S. E. LAFFERTY WRITER'S FAX (802) 660-2552 JOHN H.KLESCH WII.LIAM E. FLENDER May 17, 2010 Jacalyn M. Fletcher, Court Manager Vermont Environmental Court 2418 Ai rnort Road., Ste. 1 Barre, VT 05641-8701 Re: City of South Burlington v. Lee & Sener Docket No. 77-5-10 Vtec Dear Jacalyn: OF COUNSEL DINA L. ATWOOD Enclosed for filing in the above -captioned matter are two (2) Returns of Service issued in connection with the service of Summons and Compliant to both Mr. Lee and Mr. Sener. Sincerely, William E. Olkr WEF/j lg Enclosures CC: Raymond Belair, Planning & Zoning (w/o encl.) son10-037 WEF to Court - Lee & Sener.cor.wpd STEVEN F. STITZEL PATTI R. PAGE ROBERT E.FLETCHER JOSEPH S. McLEAN AMANDA S. E. LAFFERTY JOHN H. KLESCH WILLIAM E. FLENDER STITZEL, PAGE & FLETCHER, P.C. ATTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 BURLINGTON, VERMONT 05402-1507 (802) 660-2555 (VOICE/TDD) FAX (802) 660-2552 or 660-9119 W W W.FIRMSPF.COM E-MAIL(FIRM2555 @FIRMSPF. COM) WRITER'S E-MAIL (WFLENDER@FIRMSPF.COM) WRITER'S FAX (802) 660-2552 May 10, 2010 Sheriff Kevin M. McLaughlin Chittenden County Sheriff's Department PO Box 1426 Burlington, VT 05402 OF COUNSEL DINA L. ATWOOD Re: City of South Burlington v. Benjamin Lee and Cortlandt Sener Dear Sheriff McLaughlin: Please find enclosed two copies of a summons and complaints for service upon Benjamin Lee and Cortlandt Sener. Mr. Lee and Mr. Sener may be served at their residence, located at 131 Patchen Road, South Burlington. Should you have any questions, please feel free to contact US. Sincerely William E. Flender WEF/jg Enclosures CC: Raymond Belair, Planning and Zoning son10-036 05-10-10 WEF to Sheriff - Lee&Sener.cor.wpd 3TITZEL, PAGE & FLETCHER, P.C. .TTORNEYS AT LAW 171 BATTERY STREET PO. BOX 1507 URLINGTON, VERMONT 05402-1507 STATE OF VERMONT ENVIRONMENTAL COURT City of South Burlington, ) Plaintiff ) V. ) Benjamin Lee and Cortlandt ) Sener, ) Defendants ) Environmental Court Docket No. -5-10 Vtec SUMMONS THIS SUMMONS IS DIRECTED TO: CORTLANDT SENER 1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The Plaintiff's Complaint against you is attached to this summons. Do not throw these papers away. They are official papers that affect your rights. 2. YOU MUST REPLY WITHIN 20* DAYS TO PROTECTIVE YOUR RIGHTS. You must give or mail the Plaintiff a written response called an Answer within 20* days of the date on which you received this Summons. You must send a copy of your Answer to the Plaintiff's Attorney, William E. Flender, Esq., at 171 Battery Street, P.O. Box 1507, Burlington, Vermont 05402- 1507. You must also give or mail your Answer to the Court located at: 2418 Airport Road, Suite 1, Barre, VT 05641. 3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written response to the Plaintiff's Complaint. In your Answer you must state whether you agree or disagree with each paragraph of the Complaint. If you believe the Plaintiff should not be 1 given everything asked for in the Complaint, you must say so in your Answer. 4. YOU WILL LOSE YOUR CASE IF YOU DO NOT GIVE YOUR WRITTEN ANSWER TO THE COURT. If you do not Answer within 20* days and file it with the court, you will lose this case. You will not get to tell your side of the story, and the Court may decide against you and award the Plaintiff everything asked for in the complaint. 5. YOU MUST MAKE ANY CLAIMS AGAINST THE PLAINTIFF IN YOUR REPLY. Your Answer must state any related legal claims you have against the Plaintiff. Your claims against the Plaintiff are called Counterclaims. If you do not make your Counterclaims in writing in your Answer, you may not be able to bring them up at all. Even if you have insurance and the insurance company will defend you, you must still file any Counterclaims you may have. 6. LEGAL ASSISTANCE. You may wish to get legal help from a lawyer. If you cannot afford a lawyer, you should aks the court clerk for information about places where you can get free legal help. Even if you cannot get legal help, you must still give the Court a written Answer to protect your rights or you may lose the case. 3TITZEL, PAGE & FLETCHER, P.C. ,TTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 URLINGTON, VERMONT 05402-1507 2 3TITZEL, PAGE & FLETCHER, P.C. XTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 URLINGTON, VERMONT 05402-1507 Dated: May 10, 2010 �- William E. Flender, Esq. *Served on Date Deputy Sheriff * Use 20 days, except that in the exceptional situations where a different time is allowed by the court in which to answer, the different time should be inserted. 3 3TITZEL, PAGE & FLETCHER, P.C. XTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 URLINGTON, VERMONT 05402-1507 STATE OF VERMONT ENVIRONMENTAL COURT City of South Burlington, ) Plaintiff ) V. ) Benjamin Lee and Cortlandt ) Sener, ) Defendants ) Environmental Court Docket No. -5-10 Vtec SUMMONS THIS SUMMONS IS DIRECTED TO: BENJAMIN LEE 1. YOU ARE BEING SUED. The Plaintiff has started a lawsuit against you. The Plaintiff's Complaint against you is attached to this summons. Do not throw these papers away. They are official papers that affect your rights. 2. YOU MUST REPLY WITHIN 20* DAYS TO PROTECTIVE YOUR RIGHTS. You must give or mail the Plaintiff a written response called an Answer within 20* days of the date on which you received this Summons. You must send a copy of your Answer to the Plaintiff's Attorney, William E. Flender, Esq., at 171 Battery Street, P.O. Box 1507, Burlington, Vermont 05402- 1507. You must also give or mail your Answer to the Court located at: 2418 Airport Road, Suite 1, Barre, VT 05641. 3. YOU MUST RESPOND TO EACH CLAIM. The Answer is your written response to the Plaintiff's Complaint. In your Answer you must state whether you agree or disagree with each paragraph of the Complaint. If you believe the Plaintiff should not be 1 given everything asked for in the Complaint, you must say so in your Answer. 4. YOU WILL LOSE YOUR CASE IF YOU DO NOT GIVE YOUR WRITTEN ANSWER TO THE COURT. If you do not Answer within 20* days and file it with the court, you will lose this case. You will not get to tell your side of the story, and the Court may decide against you and award the Plaintiff everything asked for in the complaint. 5. YOU MUST MAKE ANY CLAIMS AGAINST THE PLAINTIFF IN YOUR REPLY. Your Answer must state any related legal claims you have against the Plaintiff. Your claims against the Plaintiff are called Counterclaims. If you do not make your Counterclaims in writing in your Answer, you may not be able to bring them up at all. Even if you have insurance and the insurance company will defend you, you must still file any Counterclaims you may have. 6. LEGAL ASSISTANCE. You may wish to get legal help from a lawyer. If you cannot afford a lawyer, you should aks the court clerk for information about places where you can get free legal help. Even if you cannot get legal help, you must still give the Court a written Answer to protect your rights or you may lose the case. 3TITZEL, PAGE & FLETCHER, PC. NTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 URLINGTON, VERMONT 06402-1507 W 3TITZEL, PAGE & FLETCHER, P.C. ,TTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 URLINGTON, VERMONT 05402-1507 Dated: May 10, 2010 William E. Flender, Esq. *Served on Date Deputy Sheriff * Use 20 days, except that in the exceptional situations where a different time is allowed by the court in which to answer, the different time should be inserted. 3 STITZEL, PAGE & FLETCHER, P.C. ATTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 BURLINGTON, VERMONT 05402-1507 (802) 660-2555 (VOICE/TDD) STEVEN F. STITZEL FAX (802) 660-2552 or 660-9119 PATTI R. PAGE WWW.FIRMSPF.COM ROBERT E. FLETCHER E-MAIL(FUZM2555@FIRMSPF.COM) JOSEPH S. McLEAN WRITER'S E-MAIL (WFLENDER@FIRMSPF.COM) AMANDA S. E. LAFFERTY WRITER'S FAX (802) 660-2552 JOHN H. KLESCH WILLIAM E. FLENDER May 10, 2010 Jacalyn M. Fletcher, Manager Vermont Environmental Court 2418 Airport Road, Ste. 1 Barre, VT 05641-8701 OF COUNSEL DINA L. ATWOOD Re: City of South Burlington v. Benjamin Lee & Cortlandt Sener Docket No. -5-10 Vtec Dear Jacalyn: Enclosed is a Complaint for filing in the above -captioned matter. Also enclosed is a check in the amount of $250.00 for the filing fee. Thank you for your assistance. Sincerely, ,� o William E. Flender WEF/jg Enclosures cc: Raymond Belair, Planning and Zoning aon10-034 05-10-10 WEF to Court filing Complaint - Sener&Lee.cor.wpd 3TITZEL, PAGE & FLETCHER, P.C. ATTORNEYS AT LAW 171 BATTERY STREET P.O. BOX 1507 URLINGTON, VERMONT 05402-1507 STATE OF VERMONT ENVIRONMENTAL COURT City of South Burlington, ) Plaintiff ) V. ) Benjamin Lee and Cortlandt ) Sener, ) Defendants ) Environmental Court Docket No. -5-10 Vtec COMPLAINT NOW COMES the City of South Burlington, by and through its attorneys, Stitzel, Page & Fletcher, P.C., and for its complaint states as follows: 1. The City of South Burlington (hereinafter the "City") is a Vermont municipality located in Chittenden County. 2. At all times material to this Complaint, the City has had duly adopted Land Development Regulations in effect. 3. Defendants, Benjamin Lee and Cortlandt Sener, own and/or occupy real property located at 131 Patchen Road in South Burlington, Vermont, (hereinafter the "Property"). 4. On or before January 4, 2010, Defendants commenced land development by changing the use of the building on the Property from a single family dwelling. 5. Defendants did not obtain a zoning permit for the activity referenced in paragraph 4 above. 6. Defendants violated sections 17.02 of the City of South Burlington Land Development Regulations and 24 V.S.A. section 1 3TITZEL, PAGE & FLETCHER, P.C. 1TTORNEYS AT LAW 171 BATTERY STREET EO. BOX 1507 :URLINGTON, VERMONT 05402-1507 4449(a)(1) by commencing land development without first obtaining a zoning permit for the activity referenced in paragraph 4 above. 7. On or about January 4, 2010, the City's Administrative Officer provided Defendant Lee a written Notice of Violation pertaining to the violation described in paragraphs 4 above. A true and correct copy of the January 4, 2010, Notice of Violation is attached hereto as Exhibit A. 8. On or about January 4, 2010, the City's Administrative Officer provided Defendant Sener a written Notice of Violation pertaining to the violation described in paragraph 4 above. A true and correct copy of the January 4, 2010, Notice of Violation is attached hereto as Exhibit B. 9. Defendants did not remedy the violation referenced in paragraph 4 above, within 7 days of the date of the Notices of Violation. 10. Neither Defendant appealed his respective written Notice of Violation to the Development Review Board and the time for taking such an appeal has passed. 11. To date, Defendants have failed and/or refused to remedy the violation referenced in paragraph 4 above. N WHEREFORE, the City requests that this Court grant it the following relief: A. Enter an Order requiring Defendants to cease the change of use of the Property from a single family dwelling; B. Enter an Order limiting the occupancy of the Property to four or fewer unrelated individuals; C. Enter an Order awarding the City fines of $100.00 per day for each day that each of the Defendants have been in violation of the Land Development Regulations from January 11, 2010; and D. Award such other relief as the Court deems proper. DATED at Burlington, Vermont this loth day of May 2010. STITZEL, PAGE & FLETCHER, P.C. Attorneys for the CITY OF SOUTH BURLINGTON William E. Flender SON10-015 sener & Lee complaint.lit STITZEL, PAGE & FLETCHER, PC. 1TTORNEYS AT LAW 171HATTERYSTREET P.O. BOX 1507 :URLINGTON, VERMONT 054024507 3 Re: Zoning Violation — 131 Patchen Road Dear Mr. Lee: Please be advised that based on information available to the City, you have commenced land development on your property at the above address without obtaining a zoning permit from the City as required by Section 17.02 of the Land Development Regulations and 24 VSA 4449 (a) (1). Specifically, you have initiated the following activities on the above -described property: Changed_the use, of the 'building from single:family dwelling, without a zoriing permit. You have seven (7) days from the date of this letter to discontinue this violation and take appropriate remedial action. Specifically, you must accomplish the following: Reduce the number of unrelated individuals that occupy the building to four (4) or fewer. If you do not accomplish the actions directed in this letter within seven (7) days of the date of this letter, the City may pursue this matter in court. In such court proceedings, the City will be entitled to seek appropriate injunctive relief and fines of up to $100.00 per day for each day your violation continues beyond the seven (7) day period provided in this letter. If the violation described in this letter occurs within twelve (12) months of the date of this letter, you will not be entitled to receive a further Notice of Violation from the City before the City pursues further enforcement proceedings. You may appeal this Notice of Violation to the Development Review Board by filing a written notice of appeal (see enclosed) and one hundred ten ($113) dollars within fifteen (15) days,of the date of this letter with the Clerk of the 575 Dorset Street South Burlington, VT 05403 tel 802.846.4106 fax 802.846.4101 www.sburI.com No Text Dear Mr. Sener: Please be advised that based on information available to the City, you have commenced land development on your property at the above address without obtaining a zoning permit from the City as required by Section 17.02 of the Land Development Regulations and 24 VSA 4449 (a) (1). Specifically, you have initiated the following activities on the above -described property: - - Changed the use of the building from single family dwelling, without a zoning permit. You have seven (7) days from the date of this letter to discontinue this violation and take appropriate remedial action. Specifically, you must accomplish the following: Reduce the number of unrelated individuals that occupy the building to four (4) or fewer. If you do not accomplish the actions directed in this letter within seven (7) days of the date of this letter, the City may pursue this matter in court. In such court proceedings, the City will be entitled to seek appropriate injunctive relief and fines of up to $100.00 per day for each day your violation continues beyond the seven (7) day period provided in this letter. If the violation described in this letter occurs within twelve (12) months of the date of this letter, you will not be entitled to receive a further Notice of Violation from the City before the City pursues further enforcement proceedings. You may appeal this Notice of Violation to the Development Review Board by filing a written notice of appeal (see enclosed) and one hundred ten ($113) dollars within fifteen (15) days of the date of this letter with the Clerk .of the 575-Dorset Street South Burlington, VT 05403 tel 802.846,4106 fax 802.846.4101 www.sburl.com ----- «-- -.z—_ ..................—..— — --- - ---- - - /..--- 1 C Development Review Board at the following address: 575 Dorset Street, South L �s W20 ��� southburlington PLANNING & ZONING February 9, 2010 Amanda S.E. Lafferty, Esq. Stitzel Page and Fletcher, PC PO Box 1507 Burlington, VT 05402-1507 Re: Zoning Violation — Patchen Road Dear Amanda: Enclosed please find two (2) Notices of Violation mailed via Certified Mail to the two (2) property owners of 131 Patchen Road. Neither owner appealed the issuance of the Notice of Violation. Therefore, please commence legal action to obtain a court order to cure the violation described in the Notices of Violation. Should you need additional information, please let me know. Since FramondBelair- Addainistrative Officer 575 Dorset Street South Burlington, VT 05403 tell 802.846.4106 fax 802.846.4101 www.sburl.com #/ill-/0--r( southburfington PLANNING & ZONING January 4, 2010 Cortlandt Sener 131 Patchen Road South Burlington, VT 05403 Re: Zoning Violation — 131 Patchen Road Dear Mr. Sener: Please be advised that based on information available to the City, you have commenced land development on your property at the above address without obtaining a zoning permit from the City as required by Section 17.02 of the Land Development Regulations and 24 VSA 4449 (a) (1). Specifically, you have initiated the following activities on the above -described property: Changed the use of the building from single family dwelling, without a zoning permit. You have seven (7) days from the date of this letter to discontinue this violation and take appropriate remedial action. Specifically, you must accomplish the following: Reduce the number of unrelated individuals that occupy the building to four (4) or fewer. If you do not accomplish the actions directed in this letter within seven (7) days of the date of this letter, the City may pursue this matter in court. In such court proceedings, the City will be entitled to seek appropriate injunctive relief and fines of up to $100.00 per day for each day your violation continues beyond the seven (7) day period provided in this letter. If the violation described in this letter occurs within twelve (12) months of the date of this letter, you will not be entitled to receive a further Notice of Violation from the City before the City pursues further enforcement proceedings. - - You may appeal this Notice of Violation to the Development Review Board by filing a written notice of appeal (see enclosed) and one hundred ten ($113) dollars within fifteen (15) days of the date of this letter with the Clerk of the 575 Dorset Street South Burlington, VT 05403 tel 802.846.4106 fax 802.846.4101 www.sburi.com Development Review Board at the following address-. 575 Dorset Street, South Burlington, Vermont 05403. Since .aymond J. Belair Administrative Officer Encl. CC- Amanda S. E. Lafferty, Esq. Certified Mail Receipt # 7009 0080 0001 4401 5652 Track & Confirm Search Results Label/Receipt Number: 7009 0080 0001 4401 5652 Class: First -Class Mail Track & Confirm Service(s): Certified Mail'" Enter Label/Receipt Number. Return Receipt Status: Delivered CF-O a ? Your item was delivered at 9:45 AM on January 6, 2010 in SOUTH BURLINGTON, VT 05403. Detailed Results: • Delivered, January 06, 2010, 9:45 am, SOUTH BURLINGTON, VT 05403 • Arrival at Unit, January 06, 2010, 7:30 am, BURLINGTON, VT 05401 • Acceptance, January 05, 2010, 9:07 am, BURLINGTON, VT 05401 Notification Options Track & Confirm by email Get current event information or updates for your item sent to you or others by email. Gay Sltv..MaR C.c7.mera. NrI.Y.AGy..N4.ti.cy I.erms_of_use. f}LI.Sin0..Mw_ .Iy. E� Ft t Copyright© 2009 USPS. All Rights Reserved. No FEAR Act EEO Data FOIA http://trkcnfrm 1. smi.usps. com/PTSIntemetWeb/InterLabelInquiry.do 1 /7/2010 southburlington PLANNING & ZONING January 4, 2010 Benjamin Lee 131 Patchen Road South Burlington, VT 05403 Re: Zoning Violation — 131 Patchen Road Dear Mr. Lee: Please be advised that based on information available to the City, you have commenced land development on your property at the above address without obtaining a zoning permit from the City as required by Section 17.02 of the Land Development Regulations and 24 VSA 4449 (a) (1). Specifically, you have initiated the following activities on the above -described property: Changed the use of the building from single family dwelling, without a zoning permit. You have seven (7) days from the date of this letter to discontinue this violation and take appropriate remedial action. Specifically, you must accomplish the following: Reduce the number of unrelated individuals that occupy the building to four (4) or fewer. If you do not accomplish the actions directed in this letter within seven (7) days of the date of this letter, the City may pursue this matter in court. In such court proceedings, the City will be entitled to seek appropriate injunctive relief and fines of up to $100.00 per day for each day your violation continues beyond the seven (7) day period provided in this letter. . If the violation described in this letter occurs within twelve (12) months of the date of this letter, you will not be entitled to receive a further Notice of Violation from the City before the City pursues further enforcement proceedings. You may appeal this Notice of Violation to the Development Review Board by filing a written notice of appeal (see enclosed) and one hundred ten ($113) dollars within fifteen (15) days of the date of this letter with the Clerk of the 575 Dorset Street South Burlington, VT 05403 tel 802.846.4106 fax 802.846.4101 www.sburl.com Development Review Board at the following address- 575 Dorset Street, South Burlington, Vermont 05403. S R Administrative Officer Encl. CC- Amanda S. E. Lafferty, Esq. Certified Mail Receipt # 7009 0080 0001 4401 5669 Tuck & Confirm Search Results Label/Receipt Number: 7009 0080 0001 4401 5669 - Class: First -Class Mail® Track & Confiri'n Service(s): Certified Mai ITM Enter Label/Receipt Number. Return Receipt Status: Delivered Your item was delivered at 9:45 AM on January 6, 2010 in SOUTH BURLINGTON, VT 05403. Detailed Results: • Delivered, January 06, 2010, 9:45 am, SOUTH BURLINGTON, VT 05403 • Arrival at Unit, January 06, 2010, 7:30 am, BURLINGTON, VT 05401 • Acceptance, January 05, 2010, 9:07 am, BURLINGTON, VT 05401 Notification Options Track & Confirm by email Get current event information or updates for your item sent to you or others by email. f Go w 5.ite..Map. _CV. ato.mfx. 5 e ry E.a..= riov'.L.5.0n/Ices. C.araera Copyright0 2009 LISPS. All Rights Reserved. No FEAR Act EEO Data FOI A Pri.vracy..Policx IQ.m.s..af_lts.¢ GO > fi61.S.Ir?.Q.S.S...G.u.Sto.L�7.Q.r..G.atgY.V..2.Y http://trkcnfrm 1. smi.usps.com/PTSIntemetWeb/InterLabellnquiry.do 1 /7/2010 March 6, 2009 Cortlandt G. Sener Benjamin E. Lee 131 Patchen Road South Burlington, VT 05403 Re: Zoning Violation Dear Mr. Cortlandt and Mr. Lee: It has been brought to my attention that more than four (4) unrelated individuals are occupying your single family dwelling, located on 131 Patchen Road. Please be advised that more than four (4) unrelated individuals occupying a dwelling unit constitutes a zoning violation. Please contact me within 10 days from the date of this letter to discuss what steps you will be taking to correct this violation. I look forward to hearing from you soon. Since , aymond J. Be air Administrative Officer 575 Dorset Street South Burlington, VT 05403 te1 802.846.4106 fax 802.846.4101 www.sbur1.com 03/09/2009 1.2:13 FAX 31585331/76 POWE.RLINE CONSTRUCTORS Q 001/001 l March 90, 2009 Raymond J. Belair 575 Dorset Street South Burlington, VT 05403 Dear Raymond J. Belair, In an effort to clarify compliance with South Burlington zoning regulations I would like to provide the following information: There are only four individuals living at the residence located at 131 Patchen Road, South Burlington, Vermont. Their names are Benjamin Lee (co-owner), Kristy Haflett, Beatrice Galassi, and Elizabeth Luce. There are four bedrooms and ample parking for nine cars on the paved driveway not including space for one additional in the attached one -car garage. I, Cortlandt Sener (co-owner) work as a project manager on windfarms all over the country and travel full-time. I receive mail at this address, but typically only stop by once or twice a month to fix problems and collect my mail. I store one car, some summer clothes, tools, and camping gear in the basement, but do not keep any food, toiletries, or any other personal items at the residence. I keep one vehicle in the garage (Silver Audi) and frequently drive a large truck or van. Benjamin Lee owns one personal vehicle (Brown Audi) and frequently has a work vehicle (either Domino's car or rental car). Elizabeth Luce owns one personal vehicle (Saturn) and frequently drives a rental car since she works at Rent -a -Wreck. Kristy Haflett owns one personal vehicle (Red Pontiac). Each of these people also has a boyfriend or girlfriend who visit regularly, but they each have their own respective residences. By chance, Elizabeth Luce has notified me that she plans to move out at the end of this month to move back in with her family in Southern Vermont. I have not arranged for any new tenants. If you have any further questions, please feel free to contact me via e-mail: cort.sener@email.com or my cell phone number is 802-318-3248 for the quickest response. Sincerely, Cortlandt Sener i .� ICE G��e L✓4\f`p�I� �all-lll © W 3 RC; I3f Gf II 1 p 7 - lU/i'� NL'� �� Ca��(I �Cu -feJa/ ��{-0� J Cr CL c r Q I/vTOrM,t,+i'iCi✓ rLJ oi�ic� t C)/ —K ,L ;R*-FfC`�•- ► VI'r-c� Oelal'r` — h� TC/vl fhc a �G«i The S."(5c h [A/OrctS J jCOr+ !'-e ncf` Str'T Y�Ii`�l jti r�S�on�Ser'y,.._ SJf h � "�+� to �IC�v � Lvi �-� GZ V S� fCj � Iciw le r . 0 44e.- 7 ^ 1c- Q/L-�C I i'G� r� iJl e/ v� Idj.� l� 4, C r-e W Gi/ 131 ;Cr'�� .-+-� � CG � +% / 2 -�'tti v- f �C (�� j� �e r M � ,�.� I i; C�-r-c( � 0 V✓ /�l C:..v �J eG� f e c� r c Y' a c- a �` I/I r- � /�f.a i`l �J •1-h e r � / i !� � y 5�..�- -�' O � i- GL �i rl'� a G �l� ► e .S S 5 e cz v r.�. T h ro,�51. � l p Sf� ( �e ► v;` � e , 45, �`c (ti CC' -"/ j5'ee, j�- SeeMS fTU 4 reo+1/ C,pj,, {I�eil�"� CO��'� Ser ergs s'7ctje�lr��f 4;rl, ©,-/ 3 C+ C,,Z (/iI/-e- I,ter-e.1 �swho"t iv/T1� �l( Gctr_S IA- f e �lcr�i /t✓ilv�`I! /vfi�CSf'�r -� ] / f� I / 1 Gcn K '11i e/ Q. r T r. cJ GL 6 vU-t-A t, S j� 0 t"Se, l e r o c l � boii-Ijer Dr G-/,-cf 0- Cc"y1-f- O� ��7���5 (. AO CL.S O� ��r�-' I/"''f f- CrCLA r-'t f) fl-'A'07 lve4e--d-5 o�'f t30 Per N�S�// %t"j(L �aV� ec/✓ eS+lMci�tGC j�C/+�A// (NCGpl-e- �� �lJ�dv 9 0c) (-- li �►ce /���w Yow cL�� fufK�'`5 t L2i/c� Si'G �`�� eVc�si or of i-POM S AIO fv /`'r e.�-Fi of✓ ✓; -� t ef- r-elafe ,vc \'v� cpu IS ..I�f e-- e roc-F i� 1vid�a-iic.� p{ G!`f/bcLSl�-CSSI�s j jN ` 1 O wn� CG.-n + p� O I SCz ct u� 1 b Ol�_r � /wOr e- �{'f\ U-r✓ Or- Of �Irt aIIL~w Xtt,— /c fo C'r,.Lcl< I e of V 4P-- 11-17 /ear- o -I Lt, il h4Er e- 4- 16Lr e- 4.- cL (YC7&Lr. A-C'-e rl e- "4ere -T, 4tic( i-ic-e -C r <- a- A-c r kc i- oi/ /'l o-,, e '�r) Crl-lf-'6L'-f4e-,S kat-f- Sty ck CL Cc 01" c; A-14t, 4-v te-00-^c- ('##SSerSv CLI-'t �e 15 C!J1 OP le 1 1 f ra it -g 2 5 Jderriil-e Ae- ElJ,-+ dot,, rerl-ovc,4�ois kowl /Lia" rp, oo' It /-/ -13 q 3-13 1 (5,, 3,,-Iq 3 -,20 +c N PC Incident Report Print Date/Time: 03/23/2009 14:22 Login ID: dgreaves Incident Date/Time: 03/13/2009 6:37PM Location: 131 PATCHEN RD South Burlington VT 05403 Phone Number: Report Required: Y Prior Hazards: N LE Case Number: Unit/Personnel Unit Personnel 637 637 Favreau 662 662 Namdar 679 679 Traynor Person(s) Role Name Complainant Vehicles ... ............. Role Type Year Dispositions Disposition Count Gone / Quiet on Arrival 1 Property Date Code Type Make Incident:2009-00001836 Make Model Incident Type: Arrest on Warrant Venue: South Burlington Source: Telephone Priority: 1 Status: In Progress Nature of Call: Address <UNKNOWN> Model Description Color Tag No. 662 Narrative Attempt to locate Eric S. Blaisdell (12-27-1979), wanted subject. Negative contact. SOUTH BURLINGTON POLICE DEPARTMENT ORI Number: VT0040300 Phone License State Item No. Page: 1 of 1 JOHNSON & FINNIGAN, LLP ATTORNEYS AT LAW 80 Midas Drive South Burlington, VT 05403 Telephone (802) 660-9393 Fax (802) 660-9396 March 16, 2009 Postmaster South Burlington, VT 05403 Re: Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Christie Haflett 131 Patchen Road South Burlington, VT 05403 The name and last know.. address are required For change of address information. The nume, if known, and post alike box address are required fur hosholder inrunualian. The following information is provided in accordance with 39 CFR 25.6(d)(6)(11). There is no fee for providing boxholder information. The tee for providing change of address lalbnnation is waived in accordance with 39 CFR 265.6(d)(i) and (2) and corresponding Administrative Support Manual 352.44a and b. Capacity of requestor: Attorney. 2. The names of all known parties to the litigation: City of South Burlington 3. The Court in Which the tease has been or will be heard: Chittenden Superior, Burlington, Vermont 4. The docket or other identifying number if one has been issued: TBD 5. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING: The submission offal se information to obtain and use change ofaddress information or boxholder infunnation for any purpose other than the service of legal process in connection with actual or prospective litigation could result in criminal penalties including tine of up to $10,000 or imprisonment or (2) to avoid payment oI'the fee for change of address information of not more than 5 years, or both (title 18 U.S.C. § 1001. Postmaster -2- March 16, 2009 I certify that the above information is true and that the address information is needed and will be used solely for ervice of legal process in connection with actual prospective litigation. Cordly, 2 n: J Esq. No change of address order on file. Not known at address given. Moved. Left no forwarding address No such address. C \\Kim\new legal\Legals\FORMS\POSTMASTER.1&F.wpd FOR POST OFFICE USE ONLY NEW ADDRESS OR BOXHOLDER'S POSTMARK NAME AND STREET ADDRESS JOHNSON & FINNIGAN, LLP ATTORNEYS AT LAW 80 Midas Drive South Burlington, VT 05403 Telephone (802) 660-9393 Fax (802) 660-9396 March 16, 2009 Postmaster South Burlington, VT 05403 Re: Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Beatrice Galassi 131 Patchen Road South Burlington, VT 05403 The name and last known address are required for change of address information. The name, if known, and post ollice box address are required liar boxholder inlbrnation. The following information is provided in accordance with 39 CFR 25.6(d)(6)(ii). There is no fee for providing boxholder information. The fee Ibr providing change ofaddress information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352A4a and b. 1. Capacity of requestor: Attorney. 2. The names of all known parties to the litigation: City of South Burlington 3. The Court in Which the case has been or will be heard: Chittenden Superior, Burlington, Vermont 4. The docket or other identifying number if one has been issued: TBD 5. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING: The submission of false information to obtain and use change ofaddress information or boxholder information for any purpose other than the service of legal process in connection with actual or prospective litigation could result in criminal penalties including a fine of up to $10,000 or imprisonment ur (2) to avoid payment of the fee for change of address information of not more than 5 years, or both (title 18 U.S.C. § 1001. C Postmaster -2- March 16, 2009 I certify that the above information is true and that the address information is needed and will be used solely for the service of legal process in connection with actual prospective litigation. jr No change of address order on file. Not known at address given. Moved. Left no forwarding address No such address. \\Kim\new legal\Legals\FORMS\POSTMASTER.1&F.wpd FOR POST OFFICE USE ONLY NEW ADDRESS OR BOXHOLDER'S POSTMARK NAME AND STREET ADDRESS � C JOHNSON & FINNIGAN, LLP ATTORNEYS AT LAW 80 Midas Drive South Burlington, VT 05403 Telephone (802) 660-9393 Fax (802) 660-9396 March 16, 2009 Postmaster South Burlington, VT 05403 Re: Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the lollow[HO' Name: Elizabeth Luce 131 Patchen Road South Burlington, VT 05403 The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder infbrtna tint. The following inlbnnation is provided in accordance with 39 CFR 25.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address iolornation is waived in accordance with 39 CFR 265.6(d)(i) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requestor: Attorney. 2. The names of all known parties to the litigation: City of South Burlington 3. The Court in Which the case has been or will be heard: Chittenden Superior, Burlington, Vermont 4. The docket or other identifying number if one has been issued: TBD 5. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING: The submission of false information to obtain and use change ofaddress information or boxholder information for any purpose other than the service of legal process in connection with actual or prospective litigation could result in criminal penalties including a fine of up to $10,000 or imprisonment or (2) to avoid payment of the fee for change of address information of not more than 5 years, or both (title 18 U.S.C. § 1001. C Postmaster -2- March 16, 2009 I certify that the above information is true and that the address information is needed and will be used sole the service of legal process in connection with actual prospective litigation. / (�;ordially, — Jos ph Xnfi­ija-7n, jrb FOR POST OFFICE USE ONLY No change of address order NEW ADDRESS OR BOXHOLDER'S POSTMARK on Ele. Not known at address given. NAME AND STREET ADDRESS Moved. Left no forwarding address No such address. 'G1 O gR 4 mq a Ca 2U 9 --------- --------.__ us P - \\Kim\new legai\Legals\FORMS\POSTMASTER.1&F.wpd JOHNSON & FINNIGAN, LLP ATTORNEYS AT LAW 80 Midas Drive South Burlington, VT 05403 Telephone (802) 660-9393 Fax (802) 660-9396 March 16, 2009 Postmaster South Burlington, VT 05403 Re: Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Cortland Senner Ben Lee 131 Patchen Road South Burlington, VT 05403 The name and last known address are required for change ofaddress infornnatlon. The name, if known, and post office box address are required for boxholder information. The following information is provided In accordance with 39CFR 25.6(d)(6)(ii). There is no fee for providing boxholder in l'urmn[ion. The fee fur providing change ofaddress information is waived in accordance with 39 CFR 265.6(d)(i) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requestor: Attorney. 2. The names of all known parties to the litigation: City of South Burlington 3. The Court in Which the case has been or will be heard: Chittenden Superior, Burlington, Vermont 4. The docket or other identifying number if one has been issued: TBD 5. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING: The submission of false information to obtain and use change ofaddress information or boxholder information for any purpose other than the service of legal process in connection with actual or prospective litigation could result in criminal penalties including a tine of up to $10,000 or imprisonment or (2) to avoid payment of the fee for change of address intbnnation of not more than 5 years, or both (title 18 U.S.C. § 1001. Postmaster -2- March 16, 2009 I certify that the above information is true and that the address information is needed and will be used solely for the service of legal process in connection with actual prospective litigation. Cordially, Josh M. Finnigan, E :jrb No change of address order on file. Not known at address given. Moved. Left no forwarding address No such address. FOR POST OFFICE USE ONLY NEW ADDRESS OR BOXHOLDER'S POSTMARK NAME AND STREET ADDRESS - L Act) \\Kim\new legal\Legals\FORMS\POSTMASTER.J&F. wpd '�� Ping Co co- o wr- -e�-_S w,k v, Lem Y- e S 1' 14, +S o .� _ CoIrr-f szn-er 04 -r r-c sl, ),, s C, .4 40 'e. Lict �t•SS1 Nam- l 31 C,4 4tA. P'c4 , } ece IVY / co ( CA r C_ k2 11 4ev-'.'— Dt� e r r y ��Cvv-r,/ WA UY be �oj�5;'r S "fD �e�✓ �ee, h�. 5 cl� � j rt�� Y eJ i S�rc �� o ✓%l e e— Afro �2vo8 60 C47S L�,e� vJ\ f,��� F � 03/02/2009 C�. y of South Burlington Grand __st Page 1 of 1 08:47 am Parcel Report jbeagley For Parcel: 1290-00131. SENER CORTLANDT G Name SENER CORTLANDT G LEE BENJAMIN E 131 PATCHEN RD S BURLINGTON VT 05403 Location 911 131 PATCHEN RD Tax Map 16-027-000 Desc. 1.07 AC & DWL Codes: (1) (Category) Rl (Equipment) (Owner) T Wood Crop Pasture Other Site Total Acres: 0.00 0.00 0.00 0.00 0.00 1.07 Real Land Building Equipment Inventory Values: 338,600 68,200 270,400 0 0 Homestead Veterans Farm Stab. L.U. Acres Land Use 338,600 0.00 0.00 0.00 0.00 Contract Lease Prev. Eqpm Land Use Amt Prev. Real 0 0.00 0 0.00 338,600 Housesite Special Exmp Grand List 338,600.00 0.00 3,386.00 Misc: Status: T Bill #: 56125 Updated: 07/16/2008 Last sale was: Valid on 04/30/2008 for $269500 recorded on 814/54 Grievance Info: Flag: N Remarks: (1) Misc Fields: (0): 105022000 (8) : N (9) : 0 SPAN: 600-188-15677