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IN RE: ABANDONED MOBILE HOMES OF ROBERT R. RUSSELL, JR, MARIA DOUGLAS AND EDWIN DOUGLAS VERIFIED COMPLAINT NOW COMES Plaintiff, St. George Community Cooperative, Inc., by and through counsel Steven J. Kantor, and hereby makes this complaint: 1. Plaintiff, with a principal business located in St George, County of Chittenden, State of Vermont, is the record owner of a mobile home park known as St. George Villa , (the Park ), located in the Town of St. George, Vermont. 2. Defendant Robert R. Russell Jr. is the owner of a certain mobile home in the Park identified as a 1980 Skyline 14 x 72 , serial number: 0316-0645N, presently located at 89 Birch Road, St. George, Vermont. ....