Bill of Particulars – Rose Hall Apartments

On June 30, 2025, Rose Hall Apartments, through Leasing Manager Chrissy Waters, issued a threatening and intimidating notice which mischaracterized a routine water billing matter as a lease violation. This notice misapplied VRLTA §55.1-1245 by ignoring the statutory right to cure, misrepresented tenant payment history, and attempted to escalate a cured balance into grounds for eviction. The defects in this initial notice triggered subsequent improper notices, ledger manipulations, and retaliatory actions, all of which are detailed below.

I. Management Response Analysis – June 30, 2025 Complaint

Tenant Complaint Point Management Response Deficiency / Failure to Address Consequential Violation
Late payments cured within statutory window (§55.1-1245(A)) Claimed water bill was a lease violation; referred to lease section 45 Ignored statutory right to cure June 30, 2025 notice threatening eviction without proper cure (§55.1-1245(A))
Misrepresentation / bad faith (§55.1-1242) Stated “haven’t misused any language” Did not address eviction threat or escalation Threatening eviction despite full payment (§55.1-1242; §55.1-1245)
Submetered water fee limits (§55.1-1212(D)) Claimed “do not use ratio billing” Did not address statutory cap or misapplied fees Imposition of non-statutory late fees (§55.1-1212(D); §55.1-1213)
Inconsistent notices Claimed friendly reminders escalate Did not resolve conflicting June 18 vs June 30 notices Issuance of inconsistent/contradictory notices (§55.1-1245; §55.1-1247)
Misleading tenants / consumer protection (§59.1-200(A)(14)) Claimed actions are lawful Failed to recognize eviction threats as misleading Defective notices causing undue stress (§55.1-1245; §55.1-1247; §55.1-1251)
Longstanding payment history Attached but interpreted as habitual non-compliance Ignored 14-year payment record Misstatement of prior compliance (§55.1-1247; §55.1-1221)
Elderly community impact Not addressed No acknowledgment or mitigation of risk Failure to consider community impact (§55.1-1204)
Auto-conversion to 30-day notice (§55.1-1245(A)) Referenced prior notice of like nature clause Did not correct misleading auto-escalation language Improper conversion of partial payment into breach (§55.1-1245; §55.1-1247)

II. Original June 30, 2025 Notice

Rose Hall Apartments – 06302025 NOTICE

Address: 3301 Eamon Court Virginia Beach, VA 23452
Office: 877-883-0787 | Fax: 757-498-7004 | Website: www.rentwithrosehall.com

Date: June 30, 2025

To: Thomas Coates / Taylor Coates, 3416 Warren Pl., Apt 201, Virginia Beach, VA 23452

It has been brought to the attention of the rental office that your water bill is again 30+ days past due. This is a violation of your signed lease with Rose Hall Apartments, paragraph 45 "Submetering Water and Wastewater". The full amount of your water bill will be added to your ledger as of July 1, 2025. You will have an additional balance of $149.90 due with your rent.

In accordance with section 55-248.31 of the VRLTA: The above referenced lease violation is to be remedied immediately. Should another lease violation occur within 21-days; this notice will convert to a 30-day notice to vacate from the date this notice was issued. Subsequently, should a like lease violation occur during your residency this notice will be referenced and a 30-day notice to vacate will be issued.

Respectfully,
Chrissy Waters
Leasing Manager
Rose Hall Apartments

Cc: Resident File

III. Management Response Analysis – August 13, 2025 Notice

Tenant Complaint Point Management Response Deficiency / Failure to Address Consequential Violation
Late payments cured within statutory window (§55.1-1245(A)) Notified NES payment is overdue; added to next month’s rent Ignored statutory right to cure and prior payment history 08132025 notice threatens improper ledger addition (§55.1-1245(A))
Misrepresentation / bad faith (§55.1-1242) Described notice as “friendly reminder” despite prior notices Minimized previous notice pattern and failed to acknowledge escalation Mischaracterizes prior compliance; threatens potential retaliation (§55.1-1242)
Submetered water fee limits (§55.1-1212(D)) Directed payment to NES without addressing ratio billing concerns Did not clarify statutory cap or accuracy of submetering fees Potential imposition of improper fees (§55.1-1212(D); §55.1-1213)
Inconsistent notices Referred to NES payment procedures without reconciling prior notices Did not resolve conflicting notice dates or prior threats Creates inconsistent obligations (§55.1-1245; §55.1-1247)
Misleading tenants / consumer protection (§59.1-200(A)(14)) Framed notice as friendly reminder; implied urgency Failed to recognize cumulative stress and misleading presentation Potentially deceptive notices causing undue stress (§55.1-1245; §55.1-1247)
Longstanding payment history Did not account for 14-year positive payment record Ignored historical compliance evidence Misrepresentation of tenant payment history (§55.1-1247; §55.1-1221)

IV. Original August 13, 2025 Notice

Rose Hall Apartments – 08132025 NOTICE

Date: August 13, 2025

To: Thomas Coates, Taylor Coates
3416 Warren Place #201
Virginia Beach, VA 23452

National Exemption Service (NES) notified our office that your water bill payment is 30-60 days past due. Please make your payment to NES or it will be added to your next month's rent.

You may pay by phone at 1-877-UTILPAY (1-877-884-5729) or by Visa, MasterCard, American Express, Discover, or E-check on their website at www.submeter.com, or mail your payment to National Exemption Service (NES), P.O. Box 926, Safety Harbor, FL 34695-0926.

We highly recommend setting your account up on autopay with NES so that you never miss a payment.

Please disregard this notice if payment has already been made. This is sent as a friendly reminder, and we thank you for your immediate attention to this matter.

Regards,
Management
Rose Hall Apartments

V. Subsequent Retaliatory Notices Triggered

VI. Conclusion

Management’s response failed to address statutory rights, misrepresented payment history, and allowed misleading notices. These failures precipitated retaliatory actions directly traceable to the initial complaint, actionable under VRLTA §§55.1-1245, 1247, 1251, 1258.

II. Original 08292025#1 Notice

Rose Hall Apartments – 08292025#1 NOTICE
~Thomas Coates & Taylor Coates
3416 Warren Pl., Apt 201
Virginia Beach, VA 23452

Re: 30-Day Notice to Vacate
Dear Resident,

A 21-30 notice was sent to you on June 30, 2025, regarding a violation of Rose Hall's Lease Agreement concerning "Submetering Water and Wastewater". The report we pulled today shows you are over 30 days past due again.

Pursuant to the Virginia Landlord Tenant Act; Article: E 55.1-1245, let this serve as your notice that we are terminating your lease agreement with Rose Hall Apartments. Your rental agreement with Rose Hall Apartments will terminate on September 28, 2025. Your prorated rent for September 2025 will be $1,437.33. You are to vacate the premises located at 3416 Warren Pl., Apt 201, Virginia Beach, VA 23452 on or before September 28, 2025.

We will proceed with court actions if the keys are not turned in by this date. Enclosed you will find a partially filled-out notice to vacate form; please fill out the highlighted areas and return it to the rental office with your keys. Please note that failure to return this form does not void the notice we are serving you to vacate. Failure to comply will result in legal proceedings against you to declare a forfeiture of the lease and to recover possession thereof, with rents owed and any charges allowable under law.

Respectfully,
Rose Hall Management
Rose Hall Apartments
Cc: FILE

III. Subsequent Retaliatory Notices Triggered

IV. Conclusion

Management’s response escalated directly to a 30-day eviction notice, ignored statutory rights and prior cure periods, misrepresented tenant payment history, and created undue stress through conflicting notices. These actions are retaliatory and actionable under VRLTA §§55.1-1245, 1247, 1251, 1258.

Submission Report: Retaliation Commencement – Past Due Water Bill Notice

Case Information
RE: Past Due Water Bill Notice – 08292025#2
Response: Rose Hall Apartments Management
Tenant: Thomas Coates & Taylor Coates
Property: Rose Hall Apartments
Notice Date: August 29, 2025

I. Management Response Analysis

Tenant Complaint PointManagement ResponseDeficiency / Failure to AddressConsequential Violation
Late payments cured within statutory window (§55.1-1245(A))Applied balance to rental account despite prior payment historyIgnored statutory right to cure and prior notice complianceImproper ledger addition and late fee threat (§55.1-1245(A))
Misrepresentation / bad faith (§55.1-1242)Claimed unpaid balance despite prior 08/13 noticeDid not acknowledge prior notice and payment disputePotentially retaliatory and misleading notice (§55.1-1242)
Submetered water fee limits (§55.1-1212(D))Directed payment to Rose Hall Apartments; NES cannot acceptDid not clarify statutory cap or verify correctness of chargesPotential noncompliant billing and improper fee application (§55.1-1212(D); §55.1-1213)
Inconsistent noticesEscalated balance to rental account without reconciling 08/13 noticeDid not resolve discrepancies between prior notices and account postingsConfusing and inconsistent notices causing undue stress (§55.1-1245; §55.1-1247)
Misleading tenants / consumer protection (§59.1-200(A)(14))Implied legal threat for non-paymentFailed to recognize cumulative misleading effect of repeated noticesDefective notice causing undue stress and potential consumer protection violation
Longstanding payment historyDid not account for previous timely payments and dispute historyIgnored historical compliance evidenceMisrepresentation of tenant payment record (§55.1-1247; §55.1-1221)

II. Original 08292025#2 Notice

Rose Hall Apartments – 08292025#2 Past Due Notice
08/29/2025
Thomas Coates, Taylor Coates
3416 Warren Place #201
Virginia Beach, VA 23452

Dear Thomas Coates, Taylor Coates,

RE: PAST DUE WATER BILL CHARGES
On 08/13/2025 you received notice from this office that your water bill was delinquent and must be paid to NES. As of today that balance has not been paid.

Your entire water bill balance will be applied to your Rose Hall Apartments rental account on September 1, 2025. Your full water account balance of $147.37 is due no later than September 5th. This payment should be made to Rose Hall Apartments. National Exemption Service (NES) WILL NOT accept this payment or payment arrangements for this past due balance.

If this balance is not paid by September 5, 2025, your account will be subject to late and legal fees.

If you have any questions, please feel free to contact the leasing office.

I do hereby certify that I delivered a copy of this notice to the tenant at the address of the dwelling unit on 08/29/2025.

Sincerely,
Management
Rose Hall Apartments
www.rentwithrosehall.com

III. Subsequent Retaliatory Notices Triggered

IV. Conclusion

Management’s response escalated the 08/29/2025#2 notice to ledger addition and legal threats, ignored statutory rights and prior notice compliance, misrepresented tenant payment history, and created undue stress through conflicting and cumulative notices. These actions are retaliatory and actionable under VRLTA §§55.1-1245, 1247, 1251, 1258.