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DRAFT FOR ATTORNEY REVIEW — NOT FINAL

§ 4467

Citation
§ 4467
Parent Document
E & E Properties, Inc. v. Tatro (2012)
Jurisdiction
Vermont (state)
Effective Date
2012-04-11

Other Sections in This Document (197)

Full Text

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2
 The court in Andrus noted that landlords are entitled to evict on multiple, independent theories, using multiple
notices with multiple termination dates, but found the principle inapplicable to the facts presented. Andrus, 2005
VT 48 at ¶ 14. The Vermont legislature confirmed that landlords are entitled to seek eviction on multiple theories
using multiple notices when it enacted 9 V.S.A. § 4467(i) in 2007.
3
  While not dispositive, it should be noted that the court in Andrus was faced with an eviction proceeding for
failure to pay rent, a curable ground for eviction. 9 V.S.A. § 4467(a). In this case, neither of plaintiff’s theories for
eviction may be cured under the statutes. Id. § 4467(j)(1). Because defendant could not have cured the conditions
that gave rise to the eviction, there is reason to believe that the concerns underlying Andrus are not as relevant
here.