NOTICE REGARDING SERVICE

Due to prior improper service, misdated notices, and violations of required procedures, I do not accept informal or improperly served communications from Rose Hall Apartments.

All communications regarding rent or tenancy must be made through proper Virginia Residential Landlord and Tenant Act (VRLTA) channels, including lawful written notice or proceedings through the Virginia Beach General District Court.
Improperly served materials will not be accepted.

— Thomas Coates
January 5, 2026

Hello,

 

Attached is the 5 – day pay or quit notice which is enclosed in the envelope that will be redelivered to your door. This email is sent as a copy in the event the envelope is again returned to our office.

 

Thank you

 

Krystal Elder

Leasing Manager

Rose Hall Apartments

3301 Eamon Court Virginia Beach, VA 23452

(757) 463-0844 DIRECT

(877) 883-0790 TOLL FREE

(757) 498-7004 FAX

www.RentWithRoseHall.com 

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This communication does not constitute lawful service under the VRLTA.

It was not accepted, not read for notice purposes, not acted upon, and is void for purposes of service.

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Mr. Coates,

This notice is not void. My clients have followed the proper procedure, and it is their duty to provide you with this notice under Virginia Code. You refusing to accept it as well as even read or acknowledge it is your own doing and does not make the notice unenforceable. I cannot give you legal advice, but your attempts to intervene in my client performing their duties under the Code are inexcusable and will be notated for purposes as relevant to the pending proceeding. Furthermore, your refusal to accept service and acknowledge this pay or quit notice does not circumvent your responsibility and duty as a tenant to resolve undue balances and pay your monthly rent to my client at this point in time. 

Respectfully,

 

Debtors: Federal Law requires me to inform you that my office is engaged in debt collection. Therefore, this communication and others from my office are in an attempt to collect a debt and any information you provide us will be used for that purpose.


This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that the dissemination, distribution or copying of this message is strictly prohibited and is not a waiver of any attorney-client, work product, or other applicable privilege. If you have received this message in error, please notify the sender at taylor@tlgva.com or 757-904-1061 and delete this message.


Our firm cannot provide legal advice to anyone with whom we have not formed an attorney-client relationship. Therefore, nothing in this e-mail should be construed as legal advice unless you have executed an engagement agreement with our firm appointing us as your counsel. 

 

From: Thomas - <tdcoates@gmail.com>
Sent: Tuesday, January 6, 2026 2:00 PM
To: RoseHall <rosehall@perrel.com>
Cc: Leasing Agent <rosehallleasing@perrel.com>; customerservice@perrel.com <customerservice@perrel.com>; Taylor Frontera <Taylor@tlgva.com>
Subject: Re: NOTICE REGARDING SERVICE RoseHall Apts
 

[EXTERNAL E-MAIL]

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FORMAL RESPONSE — DEMAND FOR SUBSTANTIATION (RECORD-PRESERVING)

Counsel,

Your position is noted. However, the underlying issue remains unresolved and must be addressed before any notice or enforcement action can be meaningfully evaluated.

To date, no accurate or complete ledger has been provided substantiating the amounts claimed. This includes, but is not limited to:

• A complete rent ledger reflecting all charges, payments, credits, and adjustments; and

• A complete water billing ledger, including meter readings, billing periods, rates applied, and any recalculations or retroactive adjustments.

Despite prior written requests, these materials have not been furnished, and the figures asserted continue to vary and remain unsupported.

 Absent substantiation, the claimed balances cannot be verified, disputed, or resolved in good faith.

Accordingly, this correspondence serves as a formal request for substantiation of all amounts asserted. If no response or documentation is provided, that omission will be noted as part of the record for purposes of any pending or future proceedings.

This request is made in good faith and is intended to facilitate resolution based on accurate, documented information.

Regards,

Thomas Coates
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Mr. Coates, 

It is my understanding that they have provided those as necessary and applicable. If not, then they will address that. 

 

Debtors: Federal Law requires me to inform you that my office is engaged in debt collection. Therefore, this communication and others from my office are in an attempt to collect a debt and any information you provide us will be used for that purpose.


This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that the dissemination, distribution or copying of this message is strictly prohibited and is not a waiver of any attorney-client, work product, or other applicable privilege. If you have received this message in error, please notify the sender at taylor@tlgva.com or 757-904-1061 and delete this message.


Our firm cannot provide legal advice to anyone with whom we have not formed an attorney-client relationship. Therefore, nothing in this e-mail should be construed as legal advice unless you have executed an engagement agreement with our firm appointing us as your counsel. 

 

From: Thomas - <tdcoates@gmail.com>
Sent: Tuesday, January 6, 2026 2:45 PM
To: Taylor Frontera <Taylor@tlgva.com>
Cc: RoseHall <rosehall@perrel.com>; Leasing Agent <rosehallleasing@perrel.com>; customerservice@perrel.com <customerservice@perrel.com>
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Mr. Coates,

 

When previously asked of us, we provided the requested rental ledger and water ledger. You have been supplied those several times or told how to access them via your portal. However, we will send an updated rental ledger and water ledger to your door since there have been additional charges to date. Both of these ledgers are accurate. If placing these items on your door or emailing them are not acceptable, then it is your responsibility to stop by the office for a printed copy.

 

Respectfully,

 

Janell Lee

General Manager

Rose Hall Apartments

3301 Eamon Court Virginia Beach, VA 23452

(757) 463-0844 DIRECT

(877) 883-0790 TOLL FREE

(757) 498-7004 FAX

www.RentWithRoseHall.com 

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Subject: Record Status and Anticipated Review
To: Janell Lee, General Manager, Rose Hall Apartments

Cc: Taylor Frontera, RoseHall Leasing, Customer Service

Dear Ms. Lee,

Thank you for your message indicating that updated rental and water ledgers will be provided.
For the record, as of today, the materials necessary to fully evaluate the claims asserted remain incomplete.

 You have now indicated that additional or updated ledgers are forthcoming. Because any newly produced financial records must be carefully reviewed for accuracy, completeness, and consistency with prior representations, meaningful preparation cannot occur until such review is completed.

Accordingly, it is anticipated that the January 13 proceeding cannot reasonably proceed on a complete and verified record. This is not a matter of preference, but of due process and basic record integrity.

Please confirm the exact method and date of delivery of the updated ledgers so that the record accurately reflects when production occurred.
Thank you for your attention to this matter.

Respectfully,

Thomas D. Coates
Virginia Beach, VA
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The ledgers have been delivered.

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Subject: Outstanding Documentation and Record Confirmation

To: Taylor Law Group – Taylor Frontera Taylor@tlgva.com

Cc: Rose Hall Apartments rosehall@perrel.com, Leasing Agent rosehallleasing@perrel.com, customerservice@perrel.com

Dear Ms. Frontera,

Per prior communications and the October 21, 2025 court ruling, the following materials remain unproduced or unverified:

Complete and accurate written rental ledger substantiating all claimed amounts.
Complete and accurate water ledger, including itemization of any late fees or charges.

A copy of the governing lease relied upon for enforcement.

Any written policy regarding non-renewal or refusal to renew.

Identification of the principals of Rose Hall Apartments, including any relevant ownership or management entities.

If these documents have already been provided, please specify the date, method of transmission, and exact document reference. Otherwise, please provide verified copies no later than [insert 5 business days from today’s date].

Please note that failure to provide these materials in the stated timeframe will be noted in the official court record. This request is made to preserve the accuracy of the record and ensure compliance with statutory and procedural requirements.

Thank you for your prompt attention to this matter.

Respectfully,

Thomas D. Coates
Virginia Beach, VA
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Subject: Request for Outstanding Documentation and Verification

To: Rose Hall Apartments – Janell Lee rosehall@perrel.com


Dear Ms. Lee,

Following prior communications and the October 21, 2025 ruling of the Virginia Beach General District Court, the following documents have not been received or verified:

A complete and accurate rental ledger, including all charges, payments, credits, and any adjustments.

A complete and accurate water ledger, including itemization of late fees or other charges.

A copy of the governing lease relied upon for enforcement.

Any written policy regarding non-renewal or refusal to renew.

Identification of the principals and management entities of Rose Hall Apartments.

If these materials have already been provided, please specify the date, method of transmission, and exact document reference.

This request is made to ensure compliance with the Virginia Residential Landlord and Tenant Act and to preserve an accurate record for any pending or upcoming proceedings. Failure to provide these materials within five (5) business days will be formally noted in the court record.

Please provide verified copies or a clear plan for production within the stated timeframe.

Thank you for your prompt attention.

Respectfully,

Thomas D. Coates
Virginia Beach, VA
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Mr. Coates,

Do you have access to an online portal? How do you typically view charges and make your payments to my client? You have lived at the property for several years. None of this is new information, and any charges and payments would be reflected in your portal which is viewable to you, so I do not understand the disconnect. My client can provide full ledgers and account history upon request which they have done numerous times throughout this process, but you still have access to what you are referencing as 'new material' and are still liable for those charges when due. Furthermore, had you reviewed the 5-day notice provided to you rather than refuse service and return it to the leasing office that would have also assisted you in having the material you inaccurately allege is incomplete. Your continued actions to circumvent your responsibilities as a tenant, including and not limited to the bare minimum of paying monthly rent, are being notated. We will deny any continuance request and argue for the matter to be handled and resolved on the currently scheduled court date. 

In the midst of typing this email, you have sent two additional emails, both, with a large list of requests which, to my knowledge, have already been satisfied by my client. 

Respectfully, 

 

Debtors: Federal Law requires me to inform you that my office is engaged in debt collection. Therefore, this communication and others from my office are in an attempt to collect a debt and any information you provide us will be used for that purpose.


This message is confidential, intended only for the named recipient(s) and may contain information that is privileged, attorney work product or exempt from disclosure under applicable law. If you are not the intended recipient(s), you are notified that the dissemination, distribution or copying of this message is strictly prohibited and is not a waiver of any attorney-client, work product, or other applicable privilege. If you have received this message in error, please notify the sender at taylor@tlgva.com or 757-904-1061 and delete this message.


Our firm cannot provide legal advice to anyone with whom we have not formed an attorney-client relationship. Therefore, nothing in this e-mail should be construed as legal advice unless you have executed an engagement agreement with our firm appointing us as your counsel. 

 

From: Thomas - <tdcoates@gmail.com>
Sent: Tuesday, January 6, 2026 3:34 PM
To: RoseHall <rosehall@perrel.com>
Cc: Taylor Frontera <Taylor@tlgva.com>; Leasing Agent <rosehallleasing@perrel.com>; customerservice@perrel.com <customerservice@perrel.com>
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Subject: Formal Record – Portal Access and Account Accuracy

Ms. Frontera,

For the record, I have repeatedly notified your office that the online tenant portal is not functioning properly and does not accurately reflect charges or payments. This issue has been raised multiple times in prior correspondence, and this email serves to document that fact formally.

For example, in a prior letter, your office acknowledged:




Jun 6, 2025, 9:07 AM




to tdcoates


Hi Thomas,

 

Our system had a glitch that had been allowing you to make online payments even though your ACH payments were disabled due to your returned check back in January. The system was still allowing you to make a payment via debit card which is not allowed per your lease. If you would like to pay by credit card (not debit) per the notice that you received on January 13, 2025, please let us know so that we can activate your account. The system is not able to disallow debit card payments but per the notice, you must pay by certified funds such as a cashier’s check, money order, or credit card. Please make your payment by 5 PM today, June 6, 2025.

 

Please note that if your payment is made by a debit card, Rose Hall Apartments will disable your ability to make online payments until February of 2026.

 

We will not assess a late fee to your account if you are able to make your payment by 5 PM today, June 6, 2025.

 

Please let us know if you have any questions.

 

Chrissy Waters

Leasing Manager

Rose Hall Apartments

3301 Eamon Court Virginia Beach, VA 23452

(757) 463-0844 DIRECT

(877) 883-0790 TOLL FREE

(757) 498-7004 FAX

www.RentWithRoseHall.com 



As a result, any reliance on the portal as a sole source for notice, account verification, or calculation of amounts due is unreliable and legally insufficient.

This email is being sent to ensure the record is complete and to preserve my position regarding disputed amounts. I remain willing to resolve any undisputed amounts upon receipt of a complete, verified ledger in a format that is accurate and accessible.

Regards,
Thomas Coates


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Subject: Verification of Outstanding Documentation and Procedural Considerations

To: Taylor Frontera – Taylor@tlgva.com
Cc: Rose Hall Apartments – rosehall@perrel.com; Leasing Agent – rosehallleasing@perrel.com; Customer Service – customerservice@perrel.com

Dear Ms. Frontera,

For the record and in follow-up to prior communications and the October 21, 2025 Virginia Beach General District Court ruling, the following issues remain unresolved:

  1. Outstanding Documentation

    • A complete and verified rental ledger reflecting all charges, payments, credits, adjustments, and retroactive corrections.

    • A complete and verified water ledger including meter readings, billing periods, late fees, and retroactive adjustments, if any.

    • A copy of the governing lease relied upon for enforcement.

    • Written policies regarding non-renewal or refusal to renew.

    • Identification of the principals and management entities of Rose Hall Apartments.

Despite repeated prior requests, the above materials have not been substantively verified. Portal access alone does not satisfy statutory production requirements under the VRLTA, nor does it constitute sufficient documentation for accurate review or preparation.

  1. Procedural and Due Process Considerations

    • Because additional or updated ledgers and supporting documentation must be fully reviewed for accuracy and consistency with prior submissions, it is not possible to meaningfully prepare for the January 13, 2026 proceeding on a complete or verified record.

    • In order to protect due process and ensure integrity of the record, this email formally notifies all parties that, absent verified production of the materials above, it is anticipated that the proceeding cannot fairly proceed on the currently scheduled date.

  2. Required Verification and Delivery

    • Please provide verified copies of all outstanding materials or a clear plan and confirmed timeline for delivery within five (5) business days from the date of this communication.

    • Each item must include date of initial production (if any), method of delivery, and specific document reference.

    • Failure to provide verified documentation will be formally noted in the court record to preserve an accurate and complete record for any pending or upcoming proceedings.

This communication is intended to facilitate compliance with statutory obligations, preserve the integrity of the record, and allow all parties to proceed based on accurate and verified information.

Respectfully,
Thomas D. Coates
Virginia Beach, VA

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