VIRGINIA BEACH GENERAL DISTRICT COURT

City of Virginia Beach, Virginia

Rose Hall Apartments / Perrel Management, LLC – Plaintiff
v.
Thomas D. Coates – Defendant

Case No.: GV25031521-00

DEFENDANT'S MOTION FOR CONTINUANCE

Comes now the Defendant, Thomas D. Coates, pro se, and respectfully moves this Honorable Court for a continuance of the hearing currently scheduled on [insert date]. This request is made in good faith and for the purpose of ensuring complete access to required discovery, verification of evidence, and proper preparation for the hearing.

Grounds for Continuance

  1. Outstanding Discovery: As documented in prior filings and correspondence, the Plaintiff has not produced complete discovery required by the Virginia Residential Landlord-Tenant Act (VRLTA), including but not limited to tenant ledger records, billing statements, payment confirmations, and portal logs. Substantiation materials with tables have been prepared and will be submitted contemporaneously with this motion.
  2. Portal Access and Record Issues: Defendant has repeatedly attempted to access records via the Rose Hall Apartments tenant portal. Multiple submissions have reported incomplete, inconsistent, or inaccessible records. These issues materially affect Defendant’s ability to review billing and ledger data prior to the hearing. While access to the portal exists in theory, in practice it is insufficient to provide complete discovery. This matter has been separately documented in previous filings and is hereby incorporated by reference.
  3. Preparation for Court: The Defendant requires reasonable time to review the substantiated records, reconcile discrepancies, and ensure that all arguments are fully supported by evidence. Without this continuance, Defendant’s ability to respond accurately and completely is compromised.
  4. Prevention of Procedural Prejudice: Granting this continuance is necessary to prevent any prejudice arising from incomplete record production and to allow the Court to consider the matter on a fully informed basis. Defendant has made repeated good faith efforts to obtain the required documentation and reconcile records prior to this request.

Preemptive Clarifications

Defendant submits this motion to preemptively address any attempts by the Plaintiff to oppose the continuance on the following possible grounds:

  1. Assertion that Defendant has sufficient portal access – this is inaccurate due to repeated portal failures.
  2. Claim that discovery was previously requested and Defendant should have prepared – the record shows multiple instances of non-production.
  3. Allegation of undue delay or bad faith by Defendant – the request is made solely to ensure complete and accurate evidence for the Court.
  4. Attempt to rely on incomplete or unverified records – the continuance allows proper verification.
  5. Assertions that the hearing can proceed without full substantiation – such a course would materially prejudice Defendant.
  6. Argument that documents were provided – Plaintiff has not produced evidence of full delivery or receipt confirmations.
  7. Claim that prior filings or communications suffice for preparation – Defendant still requires full substantiated documentation to respond effectively.
  8. Any procedural objection to the timing of this request – the motion is submitted in accordance with local rules and in good faith.

Request

Defendant respectfully requests that this Court:

  1. Grant a continuance of the hearing to a date at least [insert time period, e.g., 14 days] following the Court’s ruling, to allow Defendant sufficient time to review and reconcile complete discovery materials;
  2. Direct the Plaintiff to provide immediate confirmation of receipt of this motion and compliance with all pending discovery obligations;
  3. Take notice of prior filings, including substantiation letters and tables, as part of the record supporting this request.

Conclusion

Granting this motion will ensure a fair and just consideration of the matters at issue, allow full compliance with statutory and procedural requirements, and prevent undue prejudice to the Defendant. This continuance is reasonable, necessary, and submitted in good faith.

Respectfully submitted,
Thomas D. Coates, Defendant pro se
3416 Warren Place #201
Virginia Beach, VA 23452
📧 tdcoates@gmail.com 📞 (757) 374-3539
Date: [Insert Date]