Here is a sentence‑by‑sentence breakdown in three parts: (1) what they’re trying to say, (2) VRLTA / legal issues, (3) how you can attack or mitigate it. I’ll treat some garbled text as the standard Rose Hall 5‑day notice language you’ve shown before.
Heading / Letterhead“Rose Hall Apartments … phone … website … 11/08/2025” Intent: Standard letterhead and date for a formal notice. VRLTA issue: None by itself; date is important for the 5‑day window and for showing timing relative to court rulings and prior notices. Mitigation: In court, use the date to show this is post‑judgment and part of a pattern of continued, retaliatory notices.
Address block“Thomas Coates & Taylor Coates … address …” Intent: Identify the tenants and service address. VRLTA issue: If the spelling, apartment number, or party names are wrong, service can be challenged as defective under VRLTA notice and general Virginia notice rules. Mitigation: Point out any mismatch (e.g., wrong unit, wrong name) to argue improper service and thus a defective predicate notice for any unlawful detainer.
Subject line“RE: FIVE DAY NOTICE TO PAY OR QUIT / FAILURE TO PAY RENT” Intent: This is a statutory 5‑Day Pay or Quit notice to support a future unlawful detainer for nonpayment. VRLTA issue: The notice is only legally effective if the balance, dates, and conditions are accurate and in good faith under § 55.1‑1245 and § 55.1‑1204. Mitigation: Argue the predicate is void because the amount is wrong, rent was tendered/refused, and prior judgments disposed of alleged arrears.
Paragraph: Lease terms and late fee“Please note that according to the terms of your rental agreement and pursuant to Section 55.1‑1245, Code of Virginia, the rent is due and payable on the first day of each month. If rent is not received by midnight on the 5th of the month, a late fee of 10% of the current account balance shall be due as additional rent. Payments received after the 5th … must be paid by MONEY ORDER, CASHIER'S CHECK OR CERTIFIED CHECK.” Intent: Restate due date and grace period. Claim a contractual right to a 10% late fee. Restrict payment method after the 5th to instrument types they control and can refuse.
VRLTA / legal issues: Late‑fee cap: Virginia law now limits residential late fees; a flat 10% on “current account balance” is likely unlawful and unenforceable for residential tenancies and, at minimum, must be expressly authorized in the written lease. Payment method restriction: VRLTA protects reasonable ability to pay; requiring only money orders/cashier checks after the 5th can be challenged as an unreasonable restriction and as a tactic to interfere with payment. Misuse of § 55.1‑1245: Citing VRLTA while attaching unlawful fee and payment terms is a misrepresentation of statutory rights.
Mitigation / attack: Argue the 10% fee violates the statutory cap and is void; therefore, any notice including that fee demands an unlawful amount and is invalid as a 5‑day notice. Argue the “instrument only” rule is an unreasonable restriction used to refuse tender and manufacture default. Document any attempts you made to pay by ordinary means.
Paragraph: Alleged delinquency and amount due“Our records indicate that you are delinquent in your rental payment for December 2025. Your rent in the amount of $1,540.00 is now due and a late fee of 10% has been assessed in the amount of $154.00. The total amount due as of December 8, 2025, is $1,694.00, which includes late fees from October 2025 and 2023.” Intent: VRLTA / legal issues: If December rent was actually tendered or paid (especially at or before the 5th), the notice is factually false and issued in bad faith, violating § 55.1‑1204 (good‑faith obligation). Stacking old late fees and prior‑cycle charges into the 5‑day amount makes the sum inaccurate. A 5‑day notice demanding more than what is truly unpaid rent is defective under § 55.1‑1245. Including years‑old late fees (e.g., 2023) in a current 5‑day notice can be argued as improper collection and possibly time‑barred/unconscionable.
Mitigation / attack: Use your ledger, payment confirmations, and prior judgments to show the amount was wrong on its face. Argue that because the amount demanded is inflated/incorrect, the notice cannot support an unlawful detainer at all; any UD based on this notice must be dismissed. Frame it as evidence of a pattern: double‑billing October, resurrecting resolved sums, and attaching them to new notices in contempt of the October 21 judgment.
Paragraph: Intent to file unlawful detainer and seek judgment“The management hereby gives you this notice of our intention to file an unlawful detainer action in court to evict you unless you pay the balance due within 5 days after service of this notice. Upon termination of the rental agreement, management will institute appropriate legal action and proceed by due process of law to obtain a judgment against you for the total amount shown above, accrued late fees, possession of your apartment and assess against the tenant any and all attorney’s fees and court costs … pursuant to Sections 55.1‑1251 and 55.1‑1245.” Intent: VRLTA / legal issues: If the 5‑day amount is wrong, the statutory precondition to an unlawful detainer is not satisfied; the threat itself rests on a defective predicate notice. They are again invoking VRLTA sections to give the impression that all their demands (inflated late fees, revived charges) are legally mandated when they are not. Continuing to threaten UD based on sums already litigated/struck by the court can be argued as contempt or abuse of process.
Mitigation / attack: In any UD action, move to strike/dismiss based on invalid notice (incorrect amount, bad‑faith accounting). In your motions, frame this paragraph as part of a retaliatory pattern meant to intimidate you into paying unlawful charges, contrary to § 55.1‑1258 (retaliation) and consumer‑protection principles.
Paragraph: “Accepted with reservation” language“Please be advised that in accordance with section 55.1‑1250 of the Virginia Residential Landlord and Tenant Act all rent payments received after the 5th will be accepted with reservation and without prejudice and shall not constitute a waiver of the Landlord's right to terminate your lease for your failure to pay rent, terminate your lease for any other breach, and/or proceed against you in court for unpaid rent, late fees, attorney's fees, damages and/or possession of the subject premises.” Intent: Try to pre‑reserve rights even if they accept late payments, so they can still pursue eviction. Discourage you from relying on payment acceptance as curing default.
VRLTA / legal issues: § 55.1‑1250 does allow landlords to accept payments with reservation, but they must strictly comply with its notice requirements and cannot use it to preserve rights based on unlawful or miscalculated charges. If they accepted full rent without giving contemporaneous written “with reservation” language, they may have waived default; simply printing boilerplate in a form letter is not always enough if their actual acceptance behavior contradicts it.
Mitigation / attack: Document every payment and the language (or lack thereof) on receipts; argue they in fact accepted rent without proper reservation and therefore waived any alleged default. Point out that “reservation” cannot preserve rights based on illegal late fees or amounts the court already disposed of.
Paragraph: Partial payment and cure explanation“Any partial payment of rent made before or after a judgment of possession is ordered will not prevent your landlord from taking action to evict you. However, full payment of all amounts you owe the landlord … at least 48 hours before the scheduled eviction will cause the eviction to be canceled, unless there are bases for the entry of an order of possession other than nonpayment of rent …” Intent: Recite statutory language about partial payments not stopping eviction, and full payment curing before eviction. Again treat their inflated balance as the “all amounts you owe.”
VRLTA / legal issues: If the underlying “amounts you owe” are unlawful (double‑billed, invalid fees), the cure provision is misrepresented: they’re effectively telling you that you must pay unlawful sums to avoid eviction. If they failed to properly check the boxes and language required by § 55.1‑1243 / related payment‑after‑judgment statutes, the boilerplate may not fully protect them.
Mitigation / attack: Emphasize that you tendered the lawful rent; the only “uncured” portion is a fabricated fee / duplicate charge, which cannot support an order of possession. Use this paragraph to show they know the law, yet still attached incorrect amounts, demonstrating deliberate bad faith rather than simple mistake.
Legal Aid reference“If you are in need of Legal Aid, please contact Legal Aid Society of Eastern Virginia …” Intent: VRLTA issue: Mitigation:
Certificate of service“I do hereby certify that I delivered a copy of this notice to the tenant’s door at the address above on December 8, 2025. – Janel [Janell] Lee, General Manager, Rose Hall Apartments.” Intent: VRLTA / legal issues: If the building’s rules or lease require mail + posting and they only posted, service may be defective. If you can show you did not receive it when they claim, or that the date conflicts with other records (e.g., envelope postmark, surveillance, or management logs), you can attack credibility. If the figures in the notice are false, the GM’s certification is more than a minor error; it can be characterized as a knowing false certification used to coerce payment.
Mitigation / attack: In court, question the GM on the stand: exact time, proof (photos, logs), consistency with other notices; use any inconsistencies to argue unreliability of both the service and the content. Tie this into your contempt/retaliation theory—continued issuance and “certification” of facially defective notices after the October 21 adjudication.
If you want, the next step can be to turn this into: a one‑page “Notice of Defective and Retaliatory Five‑Day Notice” for the GDC, or a cross‑examination outline for Janell Lee breaking each of these points into leading questions.
Here are four more sentence‑level breakdowns from that same notice, followed by a tight draft you can use as a “Notice of Defective and Retaliatory Five‑Day Notice” for GDC.
Four additional sentences from the letterA. “Our records indicate that you are delinquent in your rental payment for December 2025.”What they’re trying to say:
They are asserting that you did not pay December’s rent and that their internal records prove it. VRLTA / legal problem:
If December rent was tendered or paid and they refused or misapplied it, the statement is false and issued in bad faith, violating the VRLTA good‑faith requirement and making the 5‑day notice defective because it is based on an incorrect arrearage. How to put it down:
Attach proof of December payment (receipts, ledger, bank records) and argue in any motion that this line is objectively false and voids the entire notice as a predicate for unlawful detainer.
B. “The total amount due as of December 8, 2025, is $1,694.00 which includes late fees from October 2025 and 2023.”What they’re trying to say:
They want to bundle current rent, a 10% late fee, and older late fees (including from prior years) into one lump “due now” amount. VRLTA / legal problem:
A 5‑day notice must state the true, current unpaid rent; inflating it with old late fees, previously litigated amounts, or time‑barred charges makes the amount legally wrong and the notice invalid as a statutory 5‑day. How to put it down:
Show how much of the $1,694 is unlawful (e.g., double‑billed October, old fees). Move to strike any UD based on this notice because the predicate amount is incorrect and therefore cannot support possession.
C. “Management will institute appropriate legal action and proceed by due process of law to obtain a judgment against you for the total amount shown above, accrued late fees, possession of your apartment and assess … any and all attorney’s fees and court costs…”What they’re trying to say:
They’re threatening that if you don’t pay exactly what they claim, they’ll sue for eviction, money judgment, fees, and costs. VRLTA / legal problem:
When the threatened “total amount” is based on misapplied payments, improper late fees, or amounts already adjudicated by the court, this becomes an abusive debt‑collection threat and can be characterized as retaliation and bad‑faith litigation. How to put it down:
Argue in a motion that this language shows an attempt to leverage court process to collect unlawful sums; ask the judge for sanctions or at least to deny any attorney’s fee claim because their own notice is grounded in false figures.
D. “I do hereby certify that I delivered a copy of this notice to the tenant’s door at the address above on December 8, 2025.”What they’re trying to say:
They are swearing that service was made at your door on that date, to start the five‑day clock. VRLTA / legal problem:
If actual receipt conflicts with this date, or if lease/VRLTA require more than just posting (e.g., mailing plus posting) and they did not comply, service is defective; a defective service date undermines the statutory 5‑day period. How to put it down:
Use any envelopes, photos, logs, or your own sworn statement to challenge the accuracy of the certification. Argue the 5‑day period never properly began, so any UD based on this notice is premature and must be dismissed.
Draft: Notice of Defective and Retaliatory Five‑Day Notice (for GDC)You can drop this into a motion or as a stand‑alone filing: IN THE VIRGINIA BEACH GENERAL DISTRICT COURT
THOMAS D. COATES, Tenant–Defendant
v.
ROSE HALL APARTMENTS, Landlord–Plaintiff
NOTICE OF DEFECTIVE AND RETALIATORY FIVE‑DAY NOTICE (DECEMBER 8, 2025) Rose Hall Apartments issued a purported “Five Day Notice to Pay or Quit” dated December 8, 2025, alleging non‑payment of December 2025 rent and demanding a total of $1,694.00. The notice falsely states that “our records indicate that you are delinquent in your rental payment for December 2025,” despite the tenant’s timely tender/payment and the landlord’s prior misapplication and refusal of rent. The notice inflates the amount due by including a 10% late fee and old late fees from October 2025 and 2023, rather than stating only the lawful unpaid rent, rendering the predicate notice defective under the VRLTA. The notice threatens unlawful detainer, money judgment, and attorney’s fees based on this inflated and already‑litigated balance, constituting bad‑faith use of court process and retaliation following prior court rulings. The notice further contains a self‑certification of service “to the tenant’s door” on December 8, 2025, which is disputed and does not comply with the strict notice and service requirements for 5‑day notices under Virginia law. Because the amount demanded is inaccurate, because rent was in fact tendered, and because the notice is part of an ongoing pattern of retaliatory and coercive conduct, this December 8, 2025 “Five Day Notice to Pay or Quit” is legally invalid and cannot serve as a predicate for any unlawful detainer or judgment for possession.
WHEREFORE, the tenant respectfully requests that the Court:
(a) find that the December 8, 2025 Five‑Day Notice is defective and of no legal effect;
(b) dismiss or strike any unlawful detainer or related claim based on that notice; and
(c) grant such further relief as the Court deems just, including sanctions or fee‑shifting for the landlord’s repeated use of false and retaliatory notices.
If you want, the next step can be turning this into a formal motion with a caption and signature block ready for filing, or into a cross‑examination outline for the general manager. Below is a one‑page style set of arguments and challenges you can use to force them to prove service of each 5‑Day Notice and expose the “impossible” aspects, especially in light of (1) VRLTA notice rules, (2) the enforcement window and prior UD history (one dismissed, one pending, this would be the third).
A. Frame the demand: strict proof of serviceUse language like: “Landlord is hereby challenged to produce strict documentary proof of service for each 5‑Day Notice (dates: Oct 31, Nov 6, Dec 8, 2025, etc.), including: exact date, time, and manner of service; identity of the person who served it; any contemporaneous log, photo, mail receipt, or entry in the management system; any postal proof (certificate of mailing, tracking, or certified mail).”
Tie this to the statute: Under VRLTA § 55.1‑1245(F), the 5‑day clock only runs after “written notice is served on the tenant” notifying of nonpayment and intent to terminate. If service is not proven, the clock never starts and any UD based on that notice is premature and defective.law.lis.virginia
B. Specific “impossible” aspects to challengeSingle person “certifying” dozens of notices with no backup Ask: “What independent proof, beyond the manager’s self‑serving ‘I delivered a copy’ line, exists?” Argument: A bare certification with no log, no mail, no photo, and no corroborating witness is inherently unreliable, especially when the same person has a pattern of defective notices.
Timing vs. reality (date conflicts) Compare the date they claim to have served (e.g., December 8) to: postmarks or envelope dates, your actual receipt date, security cameras, email timestamps, or work schedules showing you weren’t home.
Show that for service to be true, they would have had to: prepare, print, and sign the notice, deliver it physically, and possibly also mail it, all on the same exact day they chose—often while other records show they were doing something else.
Present this as chronologically impossible or highly improbable.
Method of service inconsistent with their own practice VRLTA and local practice often expect mail + posting or at least a reliably traceable method.fairfaxcounty If Rose Hall usually mails rent letters, but for these threatening 5‑days they claim only “taped to the door,” ask why there is no USPS record. Impossible angle: “If you truly treat these notices as legally critical, why is there zero mail or electronic record of service?”
Service claimed while a prior UD is still active or just dismissed Under § 8.01‑126 and Article 13 on unlawful detainer, the landlord is expected to consolidate rent claims into one UD; repeatedly filing new UDs over the same period is disfavored.law.lis.virginia Point out: To be true, their story requires them to be serving a “new” 5‑day notice while a prior UD based on the same or overlapping rent period is pending or just thrown out, which is inconsistent with the statutory scheme that allows amending a pending UD for new amounts instead of serial filings.law.lis.virginia Frame this as procedurally impossible in good faith: they are using notices as harassment tools, not as genuine statutory prerequisites.
Service claimed after you had already tendered payment Show that your payment (cashier’s check, portal, etc.) was made before the notice date. For their certification to be honest, they would have to
- https://law.lis.virginia.gov/vacode/title55.1/chapter12/section55.1-1245/
- https://www.fairfaxcounty.gov/sheriff/eviction-process
- https://law.lis.virginia.gov/vacodefull/title8.01/chapter3/article13/
- https://henrico.gov/sheriff/civil-process-section/eviction-process/
- https://martinwrenlaw.com/blog/understanding-unlawful-detainers-and-virginia-landlord-tenant-disputes-thoughts-from-a-charlottesville-landlord-tenant-attorney/
- https://law.lis.virginia.gov/vacodefull/title55.1/chapter12/article5/
- https://pjilaw.com/how-do-you-evict-a-tenant-in-virginia/
- https://law.richmond.edu/public-service/pro-bono/training_materials/housing-justice-evictions-defenses.pdf
- https://www.nolo.com/legal-encyclopedia/tenant-defenses-evictions-virginia.html
- https://www.fairfaxcounty.gov/housing/sites/housing/files/Assets/documents/Manufactured/roundtable/2025/June%202025/MHLRA%20Presentation%20.pdf
From: Perplexity:
If they cannot prove proper service of the 5‑Day Notice (or other required notices), you can argue for several very specific results in General District Court: Unlawful Detainer must be dismissed. A valid 5‑Day Notice with proper service is a condition precedent to an unlawful detainer for nonpayment under VRLTA § 55.1‑1245. If they cannot prove when and how notice was served, the court can find that the statutory precondition was never met and dismiss the UD without reaching the rent dispute.
They cannot get a judgment for possession based on that notice. Even if the court considers rent issues, lack of proof of service means the notice did not start a lawful 5‑day cure period, so they cannot lawfully terminate the tenancy or secure possession on that theory.
Any existing judgment can be attacked as voidable for lack of proper notice. Attorney’s fees and costs can be denied or reduced. Pattern evidence supports retaliation / bad‑faith findings. Failure to prove service across multiple serial UDs (one dismissed, one pending, a third threatened) supports your argument that notices are being used as harassment and retaliation, not legitimate enforcement, in violation of VRLTA retaliation protections.
Grounds for sanctions or adverse credibility findings. If management repeatedly signs “certifications” of service they cannot substantiate, you can request sanctions (monetary or evidentiary), and the judge can treat their testimony on other issues as less credible or outright unreliable.
Here is a single, powerful, stand-alone statement—big, bold, direct, and with VRLTA statutory citations—focused ONLY on their failure to provide accurate ledgers upon request. You can paste this directly below your top block, or use it as its own exhibit heading.
⚠️ FAILURE TO PROVIDE ACCURATE LEDGERS AS REQUIRED BY LAW(ONGOING VRLTA VIOLATION — REQUESTED 6+ TIMES IN 3 MONTHS) THE VIRGINIA RESIDENTIAL LANDLORD & TENANT ACT REQUIRES THE LANDLORD TO PROVIDE ACCURATE, COMPLETE, AND UP-TO-DATE RENT AND FEE LEDGERS UPON REQUEST. SPECIFIC STATUTORY REQUIREMENTS:
• VRLTA § 55.1-1204(C) — Landlord must maintain accurate records of all charges and payments made by the tenant.
• VRLTA § 55.1-1212(A) — Tenant has the right to inspect and copy records, including account histories and charges.
• VRLTA § 55.1-1245(F) — Landlord must provide “a written statement of all amounts owed,” including rent, fees, and itemized charges, upon demand or when seeking possession. ROSE HALL IS IN DEFAULT OF THIS REQUIREMENT.
THEY HAVE BEEN FORMALLY ASKED — BY BOTH THE COURT AND THE TENANT — MORE THAN SIX (6) TIMES IN THE LAST THREE MONTHS TO PROVIDE ACCURATE LEDGERS.
THEY HAVE FAILED TO PRODUCE: - A COMPLETE RENT LEDGER
- A COMPLETE WATER BILLING LEDGER
- ANY UNALTERED, CHRONOLOGICAL, AUDITABLE ACCOUNT HISTORY
THEIR FAILURE TO PROVIDE THESE LEDGERS IS AN ONGOING STATUTORY VIOLATION THAT INVALIDATES ANY CLAIM OF RENT DUE AND PRECLUDES THE USE OF ANY LEDGER AS A BASIS FOR AN UNLAWFUL DETAINER.
If you'd like, I can now: - Insert this into the full letter
- Format as a PDF
- Add your affidavit attachment
- Build the next 16-part RH master list section
Just say “Add it to the full letter” or “Create the PDF package now.”
🚨 PRELIMINARY FORMAL NOTICE — SUMMARY OF ROSE HALL’S FAILED ACTIONS & ONGOING STATUTORY NON-COMPLIANCE(To Be Placed at the Top of Your Letter) • OUT OF THE LAST EIGHT (8) THREATS OR ATTEMPTS TO FILE UNLAWFUL DETAINERS AGAINST ME, YOU HAVE SUCCEEDED IN ZERO (0).
• YOU CURRENTLY HAVE OUTSTANDING, UNRESOLVED STATUTORY DEFECTS RELATED TO PRIOR CASES UNDER THE VIRGINIA RESIDENTIAL LANDLORD & TENANT ACT (VRLTA).
• YOU FAILED TO PROVIDE REQUIRED, SUBSTANTIATED LEDGERS — INCLUDING RENT LEDGERS AND WATER-BILLING LEDGERS — AS MANDATED BY VRLTA §§ 55.1-1204, 55.1-1212, AND 55.1-1245.
• YOU RETROACTIVELY ALTERED A LEDGER COVERING A PERIOD ALREADY SUBJECT TO JUDICIAL REVIEW ("THE ADJUDICATION WINDOW"), IN DIRECT CONFLICT WITH VRLTA ACCOUNTING REQUIREMENTS.
• YOU IMPROPERLY ASSESSED LATE FEES AGAINST ADJUDICATED AMOUNTS, AND AGAINST AMOUNTS YOU PREVIOUSLY REFUSED TO ACCEPT, IN VIOLATION OF VRLTA §§ 55.1-1245 AND 55.1-1250.
• ANY FUTURE ATTEMPT TO USE DEFECTIVE SERVICE, ALTERED LEDGERS, OR NON-COMPLIANT NOTICES TO SUPPORT AN UNLAWFUL DETAINER ACTION WILL BE CHALLENGED AS A BAD-FAITH FILING AND PRESERVED FOR SANCTIONS.
✔ What This DoesThis top block: - Frames the narrative before they even read the letter.
- Shows a pattern of abuse and pattern of failed filings.
- Cites specific statutory failures.
- Is written so that a judge can instantly understand the argument.
- Places Rose Hall in an impossible position—they must now defend 8 failures, altered ledgers, missing ledgers, improper late fees, and statutory violations before they can even talk about rent.
✔ Next StepIf you want, I can now: - Insert this block into the full letter.
- Add VRLTA and statutory citations throughout the entire document.
- Format it into a PDF.
- Add an affidavit attachment.
- Produce the next 16-part breakdown of the RH master list.
Just tell me:
“Do the full letter with PDF + affidavit”
and I’ll produce the complete package.
VIRGINIA DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT (DHCD) – Office of Affordable Housing Programs
TENANT AND HOUSING COMPLIANCE DIVISION – Residential Landlord Oversight Program
AFFORDABLE HOUSING ENFORCEMENT UNIT – Statutory Compliance and Monitoring Section
VIRGINIA FAIR HOUSING OFFICE – Tenant Rights and Enforcement Program
GENERAL COMPLIANCE AND INVESTIGATIONS OFFICE – Housing Standards and Tenant Protection Section
FEDERAL-STATE HOUSING OVERSIGHT UNIT – Program Integrity & Administrative Compliance Formal Complaint Regarding ROSE HALL APARTMENTS – Statutory Violations under VRLTA
SECOND FORMAL COMPLAINT TO VIRGINIA DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT (DHCD) (CASE UPDATES) |
CHRONOLOGY OF VIOLATIONS AND POST-JUDGMENT ACTIONS – ROSE HALL APARTMENTS Pre-Judgment Events: JUNE 30, 2025 – VACATE ORDER ISSUED: Rose Hall issued a vacate order with NO supporting documentation of delinquency; later deemed unsubstantiated under VRLTA §§ 55.1-1245, 1247, 1250.
JULY 19, 2025 – ETHICS HOTLINE COMPLAINT FILED: Tenant filed regarding defective notices, communication failures, and ADA/non-compliance issues. No corrective action was received.
SEPTEMBER 4, 2025 – EMAIL REQUEST FOR NES TENANT LEDGER: Tenant requested full accounting, reconciliation, and verification of charges; Rose Hall provided only a non-responsive corporate reply.
SEPTEMBER 10, 2025 – CORPORATE RESPONSE RECEIVED: Stated NO ETA for requested records; failed to produce ledger or accounting substantiation, violating VRLTA §§ 55.1-1204, 1209.
SEPTEMBER 12, 2025 – FOLLOW-UP CERTIFIED REQUEST: Tenant submitted verification request of invalid notice asserting VRLTA rights; NO substantive response received.
SEPTEMBER 18, 2025 – FORMAL DEMAND LETTER SENT: Tenant demanded full NES ledger, accounting records, and statutory documentation; Rose Hall ignored the deadline, establishing repeated non-compliance.
OCTOBER 6, 2025 – REQUEST FOR DOCUMENTATION FOR COURT CASE GV25-031521-00: Tenant requested lease copies and all written notices between June 1–October 6; Rose Hall FAILED TO RESPOND.
OCTOBER 21, 2025 – GENERAL DISTRICT COURT HEARING: Rose Hall did NOT provide requested documentation at or after the hearing. NON-RESPONSE FORMALLY RECORDED as adverse evidence.
Post-Judgment Events / Actions: GENERAL DISTRICT COURT UD VICTORY – Tenant prevailed in Case No. GV25-031521-00; court found Rose Hall’s vacate orders and notices unsubstantiated under VRLTA §§ 55.1-1245, 1247, 1250.
COUNTERCLAIM SUCCESS – Tenant’s counterclaim upheld, confirming multiple statutory violations by Rose Hall, including failure to provide ledgers, notices, and proper accounting.
NOVEMBER 4, 2025 – ROSE HALL COMMUNICATION – Letter/email received did NOT provide evidence or statutory compliance; confirmed prior PRETEXTUAL BEHAVIOR and refusal to cooperate.
SUPPLEMENTAL CIRCUIT COURT FILING – Tenant submitted Case No. GV25-031898-00 documenting continued non-compliance, ledger discrepancies, and defective notices for formal record.
DISCIPLINE AND OVERSIGHT ACTIONS – Tenant notified oversight agencies of statutory violations, including DHCD and local housing authorities, to update discipline records and ensure compliance monitoring.
ONGOING EVIDENCE PRESERVATION AND TENANT INTERVIEWS – Tenant is including existing and prior tenant interviews in the court record. These interviews are used to compare Rose Hall’s practices with an analogous apartment complex to demonstrate systemic patterns of statutory non-compliance.
To:
Chloe Rote, Associate Director of Affordable Housing – chloe.rote@dhcd.virginia.gov
Courtney Mailey, Program Manager – courtney.mailey@dhcd.virginia.gov From:
Thomas D. Coates, Pro Se
3416 Warren Place, Apt 201
Virginia Beach, VA 23452
Email: tdcoates@gmail.com
Phone: (757) 374-3539 Subject: Formal Complaint Regarding ROSE HALL APARTMENTS – Statutory Violations under VRLTA and Related Filings Case References: General District Court, Virginia Beach – Case No. GV25-031521-00 (Unlawful Detainer)
Circuit Court, Virginia Beach – Counter Claim and Supplemental Filing Case No. GV25-031898-00
I. INTRODUCTION
This formal complaint is submitted regarding ongoing statutory violations by Rose Hall Apartments, their management, and affiliated entities. Despite repeated lawful requests and court proceedings, Rose Hall has failed to comply with the Virginia Residential Landlord and Tenant Act (VRLTA), resulting in adverse legal findings in both General District and Circuit Courts. II. PARTIES INVOLVED Tenant / Complainant: Thomas D. Coates
Respondents / Landlord Entity: Rose Hall Associates Two, LLP
Management Company: Perrel Management Company, Inc.
Individual Agents: Chrissy Waters, Janell Lee
III. NATURE OF COMPLAINT
This complaint includes allegations of: Repeated failure to provide statutory documentation (ledgers, notices, leases)
Defective and retaliatory notices
Violation of VRLTA §§ 55.1-1204, 1209, 1245, 1247, 1250, 1258
Non-compliance with court orders
Pretextual actions to intimidate and retaliate against the tenant
IV. CHRONOLOGY OF VIOLATIONS
[Insert previously formatted 10-item timeline here with bolded items and capitalized key actions] V. LEGAL BASIS
This complaint is filed pursuant to: Virginia Residential Landlord and Tenant Act (VRLTA), §§ 55.1-1200 et seq.
Relevant provisions of the Virginia Consumer Protection Act (VCPA)
Ongoing enforcement authority of DHCD for affordable housing compliance and tenant protections
VI. PRIOR COURT FINDINGS General District Court ruled in favor of the tenant in the Unlawful Detainer case (GV25-031521-00)
Counterclaim also adjudicated, confirming multiple statutory violations by Rose Hall
Supplemental filings submitted to Circuit Court (GV25-031898-00) documenting continued non-compliance and updated evidence
VII. REQUESTED ACTIONS / RELIEF Immediate review of Rose Hall Apartments’ statutory compliance under VRLTA
Formal acknowledgment of tenant’s filings and prior court findings
Investigation of defective notices, ledger discrepancies, and retaliatory practices
Coordination with other oversight agencies regarding ongoing violations
Requirement for Rose Hall to provide full, updated documentation including leases, notices, and tenant ledgers
Monitoring of remedial measures and enforcement actions
VIII. ATTACHMENTS / EXHIBITS Exhibit A–H: Chronological and evidentiary documentation
Supporting email correspondence, prior complaints, and court filings
IX. CERTIFICATION
I, Thomas D. Coates, hereby certify that this complaint is accurate and complete to the best of my knowledge and belief. All prior correspondence, filings, and evidence are incorporated herein by reference. /s/ Thomas D. Coates
Thomas D. Coates, Pro Se |
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