PRELIMINARY NOTICE REGARDING COURT-FILED RECORD AND DEMAND FOR IMMEDIATE COMPLIANCE

This document is being submitted to the Court and incorporated into the official case record contemporaneously with today’s filings. It addresses material representations made by the Plaintiff and its agents regarding alleged prior production of documents required by statute, discovery, and due process.

The information demanded herein concerns records that were required to exist, be preserved, and be producible: (a) during the statutory pre-filing period, (b) at the time the unlawful detainer was initiated, and (c) upon prior written discovery requests already served and docketed with the Court.

Accordingly, the recipients of this notice are directed to:

• Immediately review this document in full;
• Provide written confirmation of receipt identifying the date, time, and method by which this notice was received;
• State affirmatively whether you intend to comply with each request contained herein; and
• Produce the demanded substantiating materials without delay.

The Virginia Residential Landlord and Tenant Act requires landlords and their agents to maintain and, upon request, produce accurate ledgers, billing records, notices, and related documentation relied upon in asserting possession or monetary claims. Such records are not optional, discretionary, or post hoc. They are foundational to any lawful unlawful detainer action.

Failure to produce these materials prior to filing an unlawful detainer constitutes non-compliance with statutory duties and frustrates the tenant’s right to meaningful notice and defense. Continued non-production after formal discovery requests—already served and reflected in court filings—constitutes an ongoing violation and will be presented to the Court for appropriate relief.

This notice is issued to memorialize the record, eliminate ambiguity, and afford one final opportunity for precise, documented compliance. Generalized statements, assumptions, or representations of belief are insufficient. Only specific, verifiable evidence responsive to each request will be accepted.

Immediate confirmation of receipt and compliance intent is required.

DEFENDANT’S COURT-DIRECTED EVIDENTIARY SUBSTANTIATION DEMAND

Court: Virginia Beach General District Court
Case No.: GV25031521-00
Parties: Rose Hall Apartments / Perrel Management, LLC v. Thomas D. Coates

This demand is issued in direct response to the statement attributed to Janelle Lee that the Defendant “was given” the requested records. The Defendant formally disputes that assertion. Accordingly, the Plaintiff and its agents are hereby required to substantiate each claimed delivery with specific, verifiable proof.

Generalized statements, assumptions, or conclusory claims of production are expressly rejected. Each claimed instance must be documented independently and completely.

NON-GENERALIZATION REQUIREMENT

• Statements such as “you were given,” “we thought you had it,” or “it was available in the portal” are expressly insufficient.
• Each claimed transmission must include document name, exact contents, date sent, delivery method, and proof of receipt.
• If a document was sent more than once, each transmission must be separately itemized.
• If no proof exists, that fact must be affirmatively stated.

COURT NOTICE & PRESERVATION

This demand is issued for submission to the Court as part of the evidentiary record. Failure to substantiate prior claims of production will be relied upon to demonstrate:

• Non-compliance with VRLTA statutory duties
• Lack of evidentiary foundation for Plaintiff’s claims
• Bad-faith litigation conduct

Responses must be provided in full by [DATE CERTAIN].

Respectfully submitted,
Thomas D. Coates
Defendant, pro se
3416 Warren Place #201
Virginia Beach, VA 23452
Email: tdcoates@gmail.com
Phone: (757) 374-3539